Last updated: January 26, 2021

Prompt clause

MarketingDesk Eastcom Marketing Cloud is affiliated to Shenzhen Eastcom Times Information Technology Co., Ltd. (hereinafter referred to as "we")， which will take corresponding security protection measures in accordance with the requirements of laws and regulations to try our best to protect your personal information in a safe and controllable manner. In view of this, we have formulated this "Privacy Policy" (hereinafter referred to as "the Policy") and remind you:

This policy applies to MarketingDesk products and services, including MarketingDesk product official website (domain name is marketingdesk.cn) and system platforms, mini programs, H5 pages, official accounts, and integration of some MarketingDesk functions/services as third-party services in our affiliated companies ( Details are in definition clause) and/or other third-party software or services. If the products or services provided by MarketingDesk are used in the products or services of our affiliated companies but there is no independent privacy policy, this policy also applies to that part of the products or services.

It is important to note that this privacy policy does not apply to services provided to you by other third parties through web pages, mini programs or official accounts. For example, when you use third-party applications or services through MarketingDesk, or services provided by third-party services and products relying on MarketingDesk products, this policy does not apply to the information you provide to them, the third parties.

Before using MarketingDesk products or services, please be sure to carefully read and thoroughly understand this policy, and use the relevant products or services after confirming your full understanding and consent. If you have any questions about this privacy policy, you can contact us through the contact information we announced. Once you start using our products or services, it means that you have fully understood and agreed to this policy, that is, you have agreed to our collection, processing, storage, use, sharing and protection of your personal information in accordance with this privacy policy.

Part One   Definition

MarketingDesk: A marketing SaaS platform developed by Shenzhen Eastcom Times Information Technology Co., Ltd. and providing corresponding services.

MarketingDesk service: refers to the SaaS product independently developed and served by Shenzhen Eastcom Times Information Technology Co., Ltd. to help customers improve operational efficiency and marketing effects in the marketing field.

Affiliated company: Refers to an affiliated company of “MarketingDesk” service provider that has equity or agreement control with Shenzhen Eastcom Times Information Technology Co., Ltd. Personal information: refers to various information recorded electronically or in other ways that can identify a specific natural person alone or in combination with other information or reflect the activities of a specific natural person.

Personal sensitive information: Refers to personal information including ID number, mobile phone number, personal biometric information, bank account number, property information, whereabouts, transaction information, minor information, etc. (We will mark sensitive information of specific individuals in this privacy policy in bold). Personal Information Deletion/Cancellation: Refers to the act of removing personal information from the system involved in the realization of daily business functions, so that it can be kept in a state where it cannot be retrieved or accessed. Unless otherwise agreed, the definitions used in this policy have the same meaning as those in the MarketingDesk Terms of Service.

Part Two   Privacy Policy

This privacy policy section will help you understand the followings:

1. How we collect and use your information

2. How do we use "Cookie" and similar technologies

3. How do we share, transfer, and publicly disclose your information

4. How do we protect your information

5. How do you manage your information

6. How do we deal with the information of minors

7. How to transfer your information globally

8. How to update and notify this privacy policy

9. How to contact us

1. How we collect and use your information

When you use our products and/or services, we need/may need to collect and use your personal information including the following two types:

1. In order to provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally;

2. In order to provide you with additional functions of our products and/or services, you can choose to authorize us to collect and use information. If you refuse to provide it, you will not be able to use the relevant additional functions or achieve the functional effects we intend to achieve, but it will not affect your normal use of the basic functions of our products and/or services. If you understand and agree:

(1) We are committed to creating a variety of products and services to meet your needs. Due to there are many types of products and services are provided, and different users may choose to use different specific product/service ranges, correspondingly, the basic/additional functions, the type and scope of personal information collected and used will be different. The specific product/service function shall prevail;

(2) In order to bring you a better product and service experience, we are constantly striving to improve our technology, and then we may launch new or optimized functions from time to time, so that it may be needed to collect and use new personal information or change the purpose or method of using personal information. In this regard, we will specially explain to you the collection purpose, scope and method of use of the corresponding information by updating this policy, pop-up windows, and page prompts, etc., and provide you with a way to freely consent or not. Only after obtaining your express consent, they will be collected and used. During this process, if you have any questions, comments or suggestions, you can contact us through the various contact methods provided on the “MarketingDesk” official website, and we will answer you as soon as possible.

We will collect and use your personal information to realize the following functions stated in this policy:

(1) Register an account

In order to register an account to use our services, you need to provide your mobile phone number, email address, name, company, industry, and purpose of use to create an account. For services that require a login account to use, we may verify your membership based on the above information provided by you to ensure that we are providing services for you in person.

(2) Provide the display of service information

During your use of our services, in order to identify the abnormal status of your account, understand the suitability of the product, and provide you with page displays as well as  search results that are more suitable for your needs, we may automatically collect your usage and store it as web log information. including but not limited to:

Device information: We will receive and record the device-related information you use based on your specific operations during registration and/or use as well as specific permissions granted. (Including browser type, operating system version, device settings, unique device identifiers, equipment environment and other software and hardware characteristics information).

Service log information: When you use the products or services provided by MarketingDesk, we will automatically collect your detailed usage of our services and save them as service logs, including but not limited to browsing, click to view, search queries, concerns, IP addresses, browser type, network operator, language used, and date and time of visit.

Please note that separate device information and service log information cannot identify a specific natural person. If we combine this type of non-personal information with other information to identify a specific natural person, or combine it with personal information, this type of non-personal information will be treated as personal information during the combined use period, unless we have obtained your authorization or unless otherwise provided by laws and regulations, we will anonymize and de-identify this type of information. In order to provide you with information display, search and push services that are more convenient and more in line with your individual needs, we will extract your preference features based on your personal registration information, device information and service log information, and output indirect crowd portraits based on feature tags to display and push information and/or functional services and/or possible commercial advertisements. If you do not want to accept the commercial advertisements sent to you by us, you can reply to unsubscribe through SMS prompts or by other means provided by us. In addition, we will also use your above-mentioned information in order to continuously improve and optimize the above-mentioned functions.

(3) Help you complete the activation of functional services and order management

When you order a specific service in our products and/or services, we will generate an order for you to purchase the service through the system. In the process of placing an order, we will collect your user name, nickname, mobile phone, and company information. At the same time, the order will contain the purchased service information, the specific order number, the order creation time, and the money to be paid. We collect this information to help you complete the transaction smoothly, protect your transaction security, query order information, provide customer service and after-sales service, and other purposes that we have clearly informed. In order to facilitate you to understand and query order information and then manage the order information, we will collect the order information generated during your use of our services to show you and facilitate your order management.

(4) Customer service and dispute handling

When you contact us or apply for after-sales and dispute settlement, in order to protect your account and system security, we need you to provide the necessary personal information to verify your membership. In order to facilitate contact with you and help you solve the problem as soon as possible or record the handling plan and result of related problems, we may save your communication/call records and related content. (Including account information, order information, and other information you provide to prove relevant facts or the contact information you left) If you consult, complain or provide suggestions for a specific order, we will use your account information and order information.

In order to provide services and improve the quality of services, which are reasonable need, we may also use other information about you, including relevant information you provide when you contact customer service.

(5) Provide you with security

In order to improve the security of your use of the services provided by us, our affiliates and partners, protect the personal and property safety of you, other users or the public from infringement, and better prevent phishing websites, fraud, network vulnerabilities, computer viruses, and network attacks, Network intrusion and other security risks, and more accurately identify violations of laws, regulations or MarketingDesk-related agreements, we may use or integrate your account information, transaction information, device information, service log information, and information that our affiliates and partners obtain under your authorization or share in accordance with the law to comprehensively determine your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

(6) Others

1. If the information you provide contains the personal information of other users, you need to ensure that you have obtained the legal authorization before providing this personal information to MarketingDesk.

2. If we use information for other purposes not specified in this policy, use information collected for specific purposes for other purposes, or we actively obtain your personal information from a third party, we will obtain your consent in advance. If we obtain your information indirectly from a third party, we will explicitly ask the third party in writing to collect personal information after obtaining your consent in accordance with the law, and inform you of the content of the shared information. If it involves sensitive information, it needs to be clearly confirmed by you before it is provided it to us, and we will require the third party to make a commitment to the legality and compliance of the source of personal information. If the third party violates the law, we will clearly require the other party to bear the corresponding legal responsibility; At the same time, our professional security team will strengthen the security of personal information. (Including the reporting of the sensitive information, the encrypted storage of the sensitive information, and access control, etc.) We will use no less than the same protection means and measures as our own users' personal information to protect personal information obtained indirectly.

3. Exceptions for obtaining authorization and consent

You fully understand and agree that we do not need your authorization or consent to collect and use your personal information under the following circumstances, and we may not respond to your requests for correction/modification, cancellation, withdrawal of authorization, and information request:

(1) Related to national security and national defense security;

(2) Related to public safety, public health, and major public interests;

(3) Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and execution of judgments;

(4) In order to protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to obtain the consent of the person;

(5) Your personal information disclosed to the public on your own;

(6) Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

(7) Necessary for signing and fulfilling relevant agreements or other written documents with you;

(8) Necessary for maintaining the safe and stable operation of the provided products and/or services, such as detecting and disposing of product and/or service failures;

(9) Necessary for legal news reports;

(10) When it is necessary for academic research institutions to conduct statistical or academic research based on the public interest, and when they provide academic research or description results to the outside, they de-identify the personal information contained in the results;

(11) Other circumstances stipulated by laws and regulations.

Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information, the data recipient cannot re-identify specific individuals and cannot be restored, or we may conduct de-identification research on the collected information, Statistical analysis and prediction, used to improve the content and layout of MarketingDesk services, provide product or service support for business decisions, and improve our products and services (including the use of anonymous data for machine learning or model algorithm training), then such use of later data after processing does not require separately notify you and acquire your consent.

4. If we stop operating MarketingDesk products or services, we will promptly stop continuing to collect your personal information, and will notify you of the suspension of operations in the form of one-by-one delivery or announcement, and we will also delete or anonymize the business-related personal information about what we hold but have been closed.

2. How do we use “Cookie” and similar technologies

(1) Cookie

In order to ensure the normal operation of MarketingDesk products and services, provide you with a more relaxed access experience, and recommend content that may be of interest to you, we will store Cookie, Flash Cookie, or other local storage provided by browsers (or associated applications) that usually contain identifiers, site names, some numbers and characters (collectively referred to as "Cookie"). With the help of cookies, data such as your preferences and login identity can be stored. If your browser or browser additional services allow it, you can modify your acceptance of Cookie or reject our Cookie. However, if you do this, in some cases it may affect your safe access to our system and/or fail to pass system identification and then access our system.

(2) Cookie’s similar technologies

In addition to cookies, we also use web beacons, pixel tags and other similar technologies on the system. For example, the email we send you may contain an address link that links to the content of our website. If you click on the link, we will track the click to help us understand your product or service preferences so that we can proactively improve our customers Service experience. A web beacon is usually a transparent image embedded in a website or email. With the help of the pixel tags in the email, we can know whether the email has been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time. Most browsers provide users with the function of clearing the cached data of the browser. You can perform the corresponding data clearing operation in the browser settings function. However, please note that if you disable it, you may not be able to enjoy a relatively better product or service experience.

3. How do we share, transfer, and publicly disclose your information

(1) Sharing

We will not share your personal information with companies, organizations and individuals other than MarketingDesk supplementary function service providers, except in the following cases:

1. Sharing under statutory circumstances: We may share your personal information externally in accordance with laws and regulations, litigation, dispute resolution needs, or requirements of administrative and judicial organs in accordance with the law.

2. Sharing with employees and contractors of MarketingDesk's internal entities: We will allow them to access your personal information on the basis of knowing that it is necessary. We have communicated our privacy and security guidelines to the relevant person and asked them to strictly abide by this privacy agreement.

3. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

4. Sharing in the case of your active choice: You purchase the service through MarketingDesk, and we will share the necessary information related to the transaction in your order information to the relevant service provider according to your choice to realize your transaction and after-sales service need.

5. Sharing with affiliated companies: In order to facilitate us to provide you with products and services based on MarketingDesk account, recommend information that may be of interest to you, identify abnormal member accounts, and protect the personal and property safety of MarketingDesk affiliates, other users or the public from infringement, your personal information may be shared with our affiliates and/or their designated service providers. We will only share necessary personal information and are bound by the purpose stated in this privacy policy. If we share your sensitive personal information or the affiliate company changes the purpose of using and processing your personal information, we will again ask for your authorization and consent.

6. Sharing with authorized partners: We may entrust authorized partners to provide you with certain services or perform functions on our behalf. We will only share with you for the legal, legitimate, necessary, specific and clear purposes stated in this privacy policy. The authorized partners can only have access to the information they need to perform their duties, and may not use this information for any other purpose. Currently, our authorized partners include the following types:

(1) Authorized partners for advertising, analysis services, and material production. Unless we have your permission, we will not share your personally identifiable information with partners that provide advertising and analysis services. We will entrust these partners to process information related to advertising coverage and effectiveness, but will not provide your personally identifiable information, or we will de-identify this information so that it will not identify you personally. Such partners may combine the above-mentioned information with other data they obtain legally to implement advertising services or decision-making suggestions entrusted by us.

(2) Suppliers, service providers and other partners. We send information to suppliers, service providers and other partners who support our business. These supports include technical infrastructure services commissioned by us, analysis of how our services is used, measuring the effectiveness of services, providing customer services, facilitate payment or conduct academic research and surveys. We will conduct strict security inspections on the application program interface (API) and software tool development kit (SDK) for authorized partners to obtain relevant information, and agree strict data protection measures with authorized partners, making them comply with our entrusted purpose, service description, this privacy policy and any other relevant confidentiality and security measures to handle personal information.

(3) In addition to the above-mentioned suppliers, service providers and other partners, for services provided by a third party relying on or through MarketingDesk, if you provide your personal information to it, you will be bound by its privacy agreement. And we will bear not responsibility for its privacy protection measures.

(2) Transfer

We will not transfer your personal information to any company, organization or individual, except in the following cases:

1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

2. In the event of a merger, acquisition, bankruptcy liquidation of MarketingDesk service providers, or other situations involving mergers, acquisitions or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue subjecting to this policy, otherwise we will require the company, organization and individual to seek authorization and consent from you again.

(3) Public disclosure

We will only publicly disclose your personal information under the following circumstances:

1. With your explicit consent or based on your active choice, we may publicly disclose your personal information;

2. If we determine that you have violated laws and regulations or seriously violated MarketingDesk’s related agreements and rules, or to protect the personal and property safety of MarketingDesk users or the public from infringement, we may disclose in accordance with laws and regulations or with your consent regarding your personal information, including relevant violations and the measures that the MarketingDesk platform has taken against you.

(4) Exceptions for obtaining prior authorization and consent when sharing, transferring, and publicly disclosing personal information

In the following situations, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent:

1. Related to national security and national defense security;

2. Related to public safety, public health, and major public interests;

3. Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and execution of judgments;

4. In order to protect your or other individuals' life, property, and other major legal rights and interests, but it is difficult to obtain the consent of the person;

5. Your personal information disclosed to the public on your own;

6. Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels. Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify specific individuals and cannot restore it, there is no need to notify you separately and get your consent for sharing, transferring, and publicly disclosing data after such processing.

4. How do we protect your information

(1) We have adopted reasonable and feasible safety protection measures that comply with industry standards to protect your information and prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information. For example, the data exchange between your browser and the server is protected by SSL protocol encryption; We also provide a secure browsing method of HTTPS protocol for MarketingDesk system website; We will use encryption technology to improve the security of personal information; We will use trusted protection mechanism to prevent personal information from being maliciously attacked; We will deploy an access control mechanism to try our best to ensure that only authorized personnel can access personal information.

(2) We have an advanced data security management system in the industry to improve the security of the entire system in multiple dimensions from organizational construction, system design, personnel management, and product technology.

(3) We will take reasonable and feasible measures and try our best to avoid collecting irrelevant personal information. We will only retain your personal information for the period required to achieve the purpose stated in the policy, unless there is a mandatory retention requirement by law. After your personal information exceeds the retention period, we will delete your personal information or make it anonymized in accordance with the requirements of applicable laws.

(4) Although we will try our best to take security measures, please note that the Internet is not an absolutely secure environment, and there is no "perfect security measure". We still strongly recommend you do not use non-MarketDesk-recommended communication methods to send your information when you use MarketingDesk services. Please properly protect your personal information and only provide it to others when necessary. If you find that your personal information, especially your account or password, has been leaked, please contact MarketingDesk customer service immediately so that we can take corresponding measures according to your application. Please note that the information you voluntarily share or even publicly share when using our services may involve your, others' personal information or even personal sensitive information. Please consider more carefully whether to share or even publicly share relevant information when using our services. Please use a complex password to help us ensure the security of your account. We will do our best to ensure the security of any information you send to us. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of information, resulting in damage to your legitimate rights and interests, we will bear the corresponding legal responsibility.

(5) In the unfortunate event of a personal information security incident, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and suggestions about how you can independently prevent and reduce risks, remedies for you, etc. We will inform you of the incident-related situation by email, letter, telephone, push notification, etc. If it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to publish an announcement. At the same time, we will also report the handling of security incidents on personal information in accordance with the requirements of the regulatory authorities.

5. How do you manage your information

You have the following rights with respect to your personal information:

(1) You have the right to access your personal information, except for exceptions provided by laws and regulations. If you want to exercise the right of data access, you can access it yourself through the following methods:

Personal Center-If you want to access or edit the personal information and payment information in your account, change your password, add security information, etc., you can perform such operations by visiting the MarketingDesk system page. If you are unable to access this personal information through the above link, you can contact our customer service at any time. We will respond to your request for access within 15 days.

(2) You have the right to correct your personal information;

(3) You have the right to cancel your personal information. You can apply for cancellation of your account through the online customer service, mini program for online customer service, and customer service email provided by MarketingDesk's official website. When you confirm the cancellation of your account information, we will delete your information. The resulting loss of your rights or assets disappearing at the same time shall be borne by you;

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us as much as possible at the same time, requiring them to delete them in a timely manner, unless laws and regulations provide otherwise, or these entities have obtained your independent authorization.

When you delete information from our service, we may not delete the corresponding information in the backup system immediately, but we will delete the information when the backup is updated.

(4) You have the right to change the scope of your authorization. If you believe that MarketingDesk has collected and used your personal information in violation of the law, you can contact us through MarketingDesk customer service and/or customer service email.

6. How do we deal with the information of minors

In using the MarketingDesk service, we presume that you have the corresponding capacity for civil conduct. If you are a minor, we ask you to ask your parents or guardians to read this privacy policy carefully and use our services or provide us with information with the consent of your parents or guardians.

In the case of collecting personal information of minors who are using our products or services with the consent of their parents or guardians, we will only use, share, or transfer or disclose this information when permitted by laws and regulations, with the explicit consent of the parents or guardians, or necessary to protect the minors.

If you are the guardian of a minor, if you have any questions about the personal information of the minor under your supervision, please contact us through the contact information in Section 9.

7. How to transfer your information globally

The personal information collected and generated during our operations within the territory of the People's Republic of China is stored in the territory of China, except in the following circumstances:

1. Applicable laws have clear regulations;

2. Obtain your explicit authorization;

3. You conduct personal active actions such as cross-border use of system functions through the Internet.

In response to the above circumstances, we will ensure that your personal information is adequately protected in accordance with this privacy policy.

8. How to update and notify this privacy policy

Our privacy policy may change.

We will not restrict your rights under this Privacy Policy without your explicit consent. We will post any changes to our privacy policy on a particular page.

For significant changes, we will also provide more significant notification (Including we will notify you through the official website of MarketingDesk and even provide you with pop-ups).

Significant changes referred to in this policy include but are not limited to:

1. Significant changes have taken place in our service model. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;

2, We have a major change in control and so on. Like changes in information controllers caused by mergers and acquisitions;

3. Changes in the main objects of personal information sharing, transfer or public disclosure;

4. Your right to participate in personal information processing and the way you exercise it have changed significantly;

5. The departments responsible for handling personal information security, contact methods and complaint channels have changed;

6. The security impact assessment report on personal information indicates that there is a high risk.

If you believe that a change in your Privacy Policy affects your right to use our products or services, you can terminate using our products or services by contacting us within 30 days of receiving the change notice.

9. How to contact us

If you have complaints or reports about online information security, if you have any questions, comments or suggestions related to the Privacy Policy and your information, or questions about this statement or MarketingDesk's privacy measures, please contact MarketingDesk. You can provide feedback through the official online customer service of MarketingDesk or the customer service email: 1745542711@qq.com. We will respond to your email request within 15 days.

If you are not satisfied with our response, especially if you believe that our handling of personal information has harmed your legitimate rights and interests, you can also seek a solution by filing a lawsuit with a competent court where we are registered.