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4PARADIGM PRIVACY POLICY


Revised on 12 Aug, 2021





4Paradigm (北京第四范式智能技术股份有限公司 in Chinese) and its affiliates (“4Paradigm” or “we”) value and respect your privacy. Please read carefully and make sure you understand this 4Paradigm Privacy Policy (this “Policy”) before submitting your personal information to us.


This Policy describes how 4Paradigm will process your data, including what personal information we will collect, how we will use that data, with whom we will share that data, and how we will keep your data safe.This Policy shall apply to the website (“4Paradigm Website”), the Mini-Program (“4Paradigm Mini-Program”), the App (“4Paradigm App”) and the WeChat Official Account that we operate.

This Policy is intended to help you understand:

◼ What personal information we will collect from you
◼ How we will use and share your personal information
◼ How we will keep your personal information safe
◼ How we will use cookies and similar technologies
◼ How you can control your data
◼ How we will store and transfer your personal information on a worldwide basis
◼ How we will process children’s personal information
◼ How this Policy will be updated
◼ How to contact us

1. What personal information we will collect from you


Personal information refers to various types of information recorded by electronic or other means that can be used individually or in combination with other information to identify a particular natural person or reflect the activities of a specific natural person.


◼Account Registration: If you wish to learn about our products or services, you can apply to create a user account on 4Paradigm Website. For this purpose, you may need to provide us with your name, mobile number, email address, name of company or organization, job title, industry, your demand, and the products you wish to enquire about.


◼Use of Products and Services: When you use our products and services, we need to collect your contact details (in case of our corporate customer) to ensure the successful delivery and operation of the products and services. When corporate customers use 4Paradigm’s products to collect and process their users’ personal information, such data processing shall be governed by the corporate customer’s privacy policy and 4Paradigm will not have access to or be privy to such data.


◼Following and Using WeChat Official Account and Mini-Program: When you follow our WeChat Official Account, we will collect your [WeChat nickname and avatar]; and when you use our WeChat Mini-Program, we will collect your [WeChat UnionID, OpenID, UserID, WeChat username, gender and location] upon your authorization. The foregoing data will be collected by us after obtaining your permission as prompted accordingly pursuant to the personal information collection rules of WeChat Official Account and WeChat Mini-Program. If you use any specific feature of WeChat Mini-Program, we may collect other personal information that is necessary to perform that feature.


◼Participation in Events: We may hold online or offline events from time to time, during which we may collect certain data about you, such as your name, company, job title and contact number, in order to enable your check-in for the event.


◼Communication and Feedback: We may receive feedback from you, communicate with you, and respond to your queries or requests, online through 4Paradigm Website, 4Paradigm App and 4Paradigm Mini-Program, whereby the information you provide will be recorded.


◼Cookies: Our web server logs will, through technologies such as cookies, automatically collect information such as a visitor’s IP address or device identifier, or the content of messages you send us, such as the information you enter for query or the questions or information you provide for customer support purpose. These information will not be used in a manner that can directly identify any visitor. For a description of technologies such as cookies, please refer to “How we will use cookies and similar technologies”.


◼Job Application: We offer the opportunity to apply for jobs online on 4Paradigm Website. After you select a specific job, you will need to provide your name, mobile number, email address and your CV. You may also choose to manually fill in your age, education, work experience, internship experience, project experience, awards, language skills, location, job search intentions and self description.


◼Third Party Sources: To the extent permitted by law, we will also obtain relevant data from public and commercial third party sources, for example, by purchasing statistics from other companies to support our services. This information will support us to collect more accurate information and provide better services.
You may choose not to provide us with personal information in some circumstances. But if you choose not to provide the necessary information, we may not be able to provide you with the relevant services or to respond to or resolve the problem you are experiencing.

2. How we will use and share your personal information


We may use your personal information in the following circumstances or for the following purposes.


◼Creating User Account or Registering: If you wish to learn about our products and services, receive information, enroll for live or virtual events or request a trial version, we may ask you to register for a user account. You may register for such user account on 4Paradigm Website, which will give you access to specific features or services offered by us. In this case, the specific registration information you provide to access those features or services will be used only for the specific purpose of providing those features or services to you.


◼Responding to Your Request for Information, Support or Transaction: If you make a request for information, support or transaction, such as a call back, technical support, or specific marketing materials, we will use the information you provide to fulfil your request.


◼Ensuring Secure Operation of Platform: We will collect necessary device information and browsing log information to enable us to operate website or to comply with the security or legal requirements on the operation of website.


◼Marketing: We may use your contact details, or information provided when you participate in certain marketing event, each for marketing purposes such as sending you information about products and services that may be of interest to you; inviting you to participate in market research or satisfaction surveys; or sending you marketing messages. If you do not wish to receive such information, you may opt out to receive such marketing messages at any time by using the contact details provided in Section 9 - How to Contact Us.


◼Notice: We will use your personal information to send you important notices, such as notices of changes to the terms of use or the privacy policy of website.


◼Personalizing Your User Experience and Content: We will collect information about your activities during your visit, such as recording your preferences and settings, so as to personalize your website experience. We will also collect statistics to support us further improve our website and services.


◼Contacting Employees of Our Customers, Potential Customers, Suppliers and Business Partners: If you are an employee of one of our customers, potential customers, suppliers and business partners, we may use the personal information you provide to manage and develop our business relationship with you or the company you represent. For example, we may use your contact details to send you the details of business partnership program or to contact you for the purpose of customer satisfaction surveys or market research.


◼Recruitment: If you submit an application for a job opportunity with 4Paradigm through 4Paradigm Website, we will ask you to provide us with your personal information and use this information to process your application, assess your candidacy, or contact you for recruitment purposes.


◼Mandatory Requirements under Laws, in Proceedings or of Government Authorities: In some cases, a government authority or court may require us to provide or disclose your personal information, whereupon we may as required by law disclose your personal information or other information to the government authority or court to protect our rights, your safety or the safety of others, or to respond to a government request.


◼Mergers, Acquisitions or Bankruptcy Liquidations: We will not transfer your personal information to any company, organization or individual unless with your express consent; in the event of any merger, acquisition or bankruptcy liquidation that involves the transfer of your personal information, we will require the company or organization who is the transferee of your personal information to continuously be bound by this Policy or we will require that company or organization to otherwise ask for your permission.


◼Some functions of 4Paradigm’s products and services may be provided by third party suppliers, or 4Paradigm may need to perform certain specific services through its affiliates, or 4Paradigm may need to engage third parties to support us achieve the foregoing purposes or to provide products or services to you or your company or process your requests. For example, we may engage service providers to assist us in providing supports to our customers, in which case we may need to share your personal information with 4Paradigm’s affiliates, suppliers and business partners who provide services to 4Paradigm. We will enter into strict confidentiality agreements with these third parties, under which these third parties will be required to process your personal information in compliance with our requirements, this Policy and other relevant confidentiality and security requirements.

3. How we will keep your personal information safe


4Paradigm is committed to protecting the security of your personal information. We have adopted industry-standard security measures to protect the personal information you provide against unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonably practicable steps to protect your personal information. For example, we use encryption technology to ensure the confidentiality of data; we use protection mechanisms to prevent malicious tampering or attacks on data; we ensure that only authorized personnel have access to personal data by deploying access control mechanisms; and we conduct security and privacy training to enhance our staff’s awareness of the significance of personal data protection.


Please note, however, that the Internet environment is not totally secure; therefore, although we will take measures to protect your personal information, we cannot be certain about or guarantee the security of the information you provide to us or obtain from our website. In the unfortunate event of a personal information security incident, we will promptly inform you by email, letter, telephone, push notification, announcement, etc. as required by laws and regulations of the relevant details of such incident, including basic information of the security incident and its possible impacts, the measures we have taken or will take to respond to it, the suggestions for you to prevent and mitigate the risks on your own, and the remedial measures that are available to you, etc.


We will also proactively report on the handling of the personal information security incidents as required by the regulators.

4. How we will use cookies and similar technologies


As what most websites or internet service providers do, we use cookies to support us improve the user’s experience. Cookies are small pieces of data sent from a website to your browser and stored on your computer's hard drive to identify your computer or mobile device. Cookies can help websites remember one or more visits by users and save their settings such as language, font, size and other browsing preferences of your computer or mobile device so that you do not have to re-configure your user preferences each time you visit. Cookies support us know how our websites are used and whether the user’s visits are effective, such as the number of visitors, the duration of visits, as well as the topics and advertisements that are of most interest to visitors. We can use such information to support us better design our website so as to offer you a more efficient and pleasant user experience, and to enable us to better serve our users. 4Paradigm will not use cookies for any purpose other than those described in this Policy. Most web browsers have the ability to block cookies and you may manage or delete cookies according to your preferences; but if you do so, you will need to manually change your user settings each time you visit our website, and some features of 4Paradigm Website may not function properly.


In addition to cookies, we will use other similar technologies such as Web Beacons and electronic tags on 4Paradigm Website to better customize the website so that we may provide better customer service. When you visit a page that uses these technologies, a non-personally identifiable notification of your visit will be generated to help us know your preferences and improve customer service. These technologies often work in conjunction with cookies. If you disable cookies, web beacons and other technologies will still detect your visits to these pages, but they will not in conjunction with the information stored in the cookies.

5. How you can control your data


In accordance with the relevant Chinese laws, regulations and standards, as well as the prevailing practices in other countries and regions, we protect your right to exercise the following rights in relation to your personal information: (a) to access your personal information possessed by us; (b) to request for correction or update of your personal information possessed by us if any error is identified therein; (c) to request our deletion of your personal information; (d) to change the scope of or revoke your authorization or permission (without prejudice to the legality and validity of our previous processing of your personal information based on your authorization); and (e) to cancel your previously registered account; and (vi) to obtain a copy of your personal information possessed by us.


If you wish to exercise any of these rights, you may do so by yourself in connection with the services we provide, or you may instruct us to do so by sending us feedback through the contact details set forth in Section 9 (How to Contact Us). In order to protect the security of your personal information, you may be required to provide a written request or otherwise to prove your identity. We may ask you to have your own identity verified before we process your request, and we will respond to your request within fifteen days after your identity has been verified.


We will not charge for your reasonable requests in principle, but we will charge a cost-based fee for repeated requests that exceed a reasonable extent, as appropriate. We may refuse the requests that are unnecessarily repetitive or require excessive technical means (e.g. requiring development of new systems or fundamental changes to current practice), or pose a risk to the legal rights of any other person, or are highly impractical (e.g. involving the backup of the information stored on tape).


We will not be able to respond to your request:


a. related to the fulfilment of obligations by the personal data controllers under the laws and regulations;


b. directly related to national security or national defense security;


c. directly related to public safety, public health, or significant public interest;


d. directly related to criminal investigation, prosecution, trial and enforcement of judgments;


e. where the personal data controller has sufficient evidence to prove the subjective malice of, or the abuse of right by, the subject of the personal information;


f. for the purpose of the protection of the life, property and other significant legitimate rights or interests of the subject of personal information or other individuals, where responding to the request from the subject of personal information would cause that purpose fails to achieve.


g. where responding to the request from the subject of personal information would result in serious damage to the legitimate rights or interests of the subject of personal information or of other individuals or organizations; or


h. involving trade secrets.


If you believe that our processing of your personal information does not comply with the applicable data protection laws, you may contact the statutory data protection authority.

6. How we will store and transfer your personal information on a worldwide basis


We will only retain your personal information for a period that is necessary to achieve the purposes described in this Policy, unless for a longer period with your consent or as otherwise required by laws or regulations. Upon the expiry of such retention period, we will delete or anonymize your personal information.


In principle, personal information that we collect and generate in the People’s Republic of China will be stored in the People’s Republic of China.


We may, to the extent permitted by law, share your personal information internally among 4Paradigm and its affiliates or with our suppliers and business partners; therefore, your information may be transferred to, or accessed from, other countries or regions where we conduct business. You understand and agree that we may transfer or share your personal information outside of China for these purposes. In such cases, we will ensure that your personal information is protected adequately to the same extent as it would be in the People’s Republic of China and that we comply with the regulatory requirements on the export of personal information, such as by requesting your consent to the cross-border transfer of you personal information or by taking security measures such as data de-identification prior to the cross-border data transfers.

7. How we will process children’s personal information


Our website, products and services are intended to be used primarily by adults. Children should not register their own accounts without the consent of their parents or guardians. Where any children’s personal information are collected with the consent of their parents, we will only use or publicly disclose this information to the extent permitted by law and with the express consent of their parent or guardian or as necessary to protect the children. If we become aware that we have collected any children’s personal information without prior verifiable consent of their parent, we will manage to delete the relevant data as soon as possible.
A person under the age of 14 is a “child” in accordance with this Policy.

8. How this Policy will be updated


This Policy may be changed from time to time.


We will post any changes made to this Policy on this page. For any material changes, we will also provide more prominent notice (including, in case of certain services, email notification of specific changes to this Policy). We suggest that you check this page regularly for the latest information about our privacy policy.


The “material changes” referred to in this Policy include, but are not limited to


a. Significant changes in our service model, such as the purposes for which personal information is processed, the types of personal information processed, and how personal information is used, etc.


b. Changes in the primary recipients to or with whom your personal information is shared, transferred or publicly disclosed;


c. Significant changes in your rights to participate in the processing of personal information, or the manners in which such rights are exercised;


d. Changes in our department responsible for managing the security of personal information, or its contact details or channels for complaint; and


e. High risks indicated in a personal information security impact assessment report.


We will keep an older version of this Policy on file for your review.

9. How to contact us


If you have any questions, comments or suggestions about this Policy, you may contact us by sending an email to 4pdlegal@4paradigm.com or a physical mail to 4Paradigm, Building 1, No. 66 Qinghezhong Street, Haidian District, Beijing.


Generally, we will reply within fifteen days. We may verify your identity before replying to you.