This Nxin App Privacy Policy (hereinafter referred to as the "Privacy Policy") is formulated by AgriChip Digital Intelligence International Limited (Business Registration Number: 77285239; Registered Address: Room B3, 19/F, Tung Lee Commercial Building, 91-97 Jervois Street, Sheung Wan, Hong Kong, China) (hereinafter referred to as "we" or "us"). It applies to users outside the Chinese Mainland who access and use the Nxin App. We attach great importance to the protection of users' privacy and personal data. Before you start using the Nxin App, please carefully read this Policy (with special attention to the bolded/underlined clauses) and confirm that you fully understand and agree to it before continuing to use the App. Your clicking "Agree", "Register" or actual use of the App Services shall be deemed as your having read, understood and agreed to all the terms of this Policy, including any subsequent revisions we make to this Policy. If you have any questions, comments or suggestions regarding the content of this Privacy Policy, you may contact us through the contact information set out in "11. Contact Us" of this Privacy Policy.
For the avoidance of doubt, "Overseas" as mentioned in this Privacy Policy refers to countries or regions other than the Mainland of the People's Republic of China, including Hong Kong, Macao and Taiwan of China; "Overseas Users" refer to users who have completed real-name authentication with overseas identities, registered Nxin App accounts via overseas mobile phone numbers, or registered Nxin App accounts via email or third-party accounts while located overseas, as well as other users deemed as Overseas Users based on reasonable circumstances, with the specific determination subject to the actual practice of the Nxin App. (Excluded are users who have completed real-name authentication with Mainland identities and users who have bound Mainland mobile phone numbers but not authenticated with overseas identities.)
This Policy aims to clarify the methods and scope of our collection, use, storage, sharing, transfer and protection of your personal data, as well as the rights and obligations of both parties in respect of personal data protection.
To provide you with stable and secure core services and ensure your user experience, we collect the following data only to the extent necessary for achieving specific legitimate purposes, in compliance with the "principle of minimum necessity":
The legal bases for our collection and processing of your personal data are based on the following circumstances, and you may refer to the specific scenarios for understanding:
Our use of your personal data will be strictly limited to the service purposes agreed in this Policy. If it is necessary to use the data for other purposes beyond the agreed scope, we will obtain your explicit consent again and clearly inform you of the new purpose and scope of use in writing (including electronic form).
We will only retain your personal data for the period necessary to achieve the purposes stated in this Policy, unless applicable laws and regulations stipulate mandatory storage periods. Upon expiration of the retention period, we will delete or anonymize your personal data in accordance with the requirements of applicable laws. If this is not feasible (for example, because your personal data has been stored in backup archives), we will securely store your personal data until it can be deleted.
The retention period of your data also depends on how you use the Nxin App (for example, whether you access the Nxin App as a visitor) and the purpose of the data you provide; for example, certain data will be retained for a period of time after your account is terminated or deleted to comply with applicable laws or in case of disputes. In other cases, the retention period may be determined based on your activities on the Nxin App or compliance with specific dispute resolution periods.
We store data on servers located within the Singapore. However, in some cases, your personal data may be stored on servers outside China, such as: 1) where specific data collection scenarios require special explanation or we have obtained your authorization; 2) where storage or backup outside the Chinese Mainland is required to comply with applicable laws and regulations.
We adopt appropriate organizational and technical measures to protect your personal data. For example, we restrict access to your personal data by employees, agents, contractors and other third parties, except where such access is necessary for them to perform their duties and contractual obligations. We implement physical access restrictions to data centers and logical access controls to data and systems.
In addition, we also adopt appropriate technical measures to prevent unauthorized access, use, disclosure, modification, disposal of the data we hold or similar risks, and to maintain the accuracy of the data. In the event of a data breach, we will notify you and the regulatory authorities within the time limit and scope prescribed by applicable data protection laws, and take necessary response measures.
Except for the following circumstances, we will not share your personal data with any third party:
We will not publicly disclose your personal data unless we have obtained your explicit consent or the disclosure is necessary for complying with laws and regulations, protecting public interests and the legitimate rights and interests of others.
We may use de-identified or anonymized data for data analysis, industry research and other purposes. Such processed data can no longer identify specific individuals and may be shared or disclosed independently or with third parties without obtaining your additional consent.
We will only transfer (including remote access to) your personal data across borders on the premise of legality and compliance. If the transfer is not subject to an adequacy decision or regulatory constraints, we will take appropriate measures to ensure that the recipient of your personal data fulfills its confidentiality obligations and implement appropriate measures to ensure that your personal data is protected in accordance with this Privacy Policy and applicable laws. Such measures include, for example, conducting necessary de-identification, encrypted transmission, regularly evaluating and auditing the security capabilities of the recipient, and entering into data processing agreements/clauses.
If you need to learn about the specific cross-border transfer mechanisms and relevant safeguard measures, you may consult us through the contact information set out in Article 7 of this Policy.
Pursuant to applicable laws, you are entitled to the following rights with respect to your personal data:
Upon receipt of your erasure application, we will complete the verification and erasure procedures within the time limit prescribed by laws and regulations and feed back the results to you.
To ensure the security of your data, when you exercise the above rights, we may require you to provide identity verification data to confirm your identity. We will not charge any fees for reasonable applications; for repeated applications or applications beyond a reasonable scope, we may charge corresponding fees based on actual costs or reject the application.
We do not intend to provide Services to minor users. If you are a minor pursuant to applicable laws, you are required to ask your parent or other guardian to carefully read this Policy and use our Services or provide data to us only with the consent of your parent or other guardian.
If a minor provides personal data to us without the consent of their parent or guardian, the parent or guardian may request the erasure of such data in accordance with "11. Contact Us" of this Privacy Policy.
We may update this Privacy Policy from time to time in light of changes in laws, technology or business development. When we update this Privacy Policy, we will take appropriate measures to notify you, such as publishing the revised Privacy Policy on the Nxin App. We recommend that you review this Policy regularly to stay informed of any updates or changes.
If we cease to operate the Products and/or Services, we will immediately stop collecting your personal data. We will notify you of the cessation of operation by means of individual notification or announcement, and delete or anonymize the personal data we hold in relation to the discontinued Products and/or Services in accordance with the methods set out in "3. Storage and Protection of Data" of this Privacy Policy.
The revised Policy shall take effect from the effective date specified in the notification. Your continued use of the App after the effective date of the revised Policy shall be deemed as your acceptance of the revised Policy; if you do not agree to the revised Policy, you shall immediately stop using the App and contact us to cancel your account, and we will process the relevant data in accordance with your request.
If you believe that our personal data processing activities have infringed your legitimate rights and interests, any dispute arising therefrom shall be submitted to the Hong Kong International Arbitration Centre ("HKIAC") for arbitration in accordance with the HKIAC Arbitration Rules in effect at the time of filing the arbitration notice. The arbitration shall be conducted by a sole arbitrator, the seat of arbitration shall be Hong Kong, China, and the arbitration shall be conducted in Chinese or English. The award of the HKIAC shall be final and binding on both you and us.
If the data you provide contains personal data of other users, you must ensure that you have obtained legal authorization before providing such personal data to us.
This Policy constitutes the entire agreement between you and us regarding the privacy protection of the App, and supersedes any prior oral or written agreements reached between the parties in respect of the relevant matters. If any clause of this Policy is deemed invalid or unenforceable, such invalidity or unenforceability shall not affect the validity of the other clauses, and the invalid or unenforceable clause shall be deemed to have been replaced with content that complies with laws and regulations and is closest to the original intent of the clause.
In the event of any conflict between the Chinese version and any other language version of this Privacy Policy, the Chinese version shall prevail.
If you have any questions or comments regarding this Privacy Policy, you may contact us via mobile@nxinmall.com. Please note that we may not respond to questions unrelated to this Policy or your rights in respect of personal data.