Privacy Policy
Release date: November 17, 2024
Effective Date: November 17, 2024
introduction
Zhongbei International "refers to the PC or mobile application provided by Shenzhen Zhongbei International Enterprise Management Services Co., Ltd. and its affiliates (hereinafter referred to as" us "or" Zhongbei "). We attach great importance to the security of users' personal information and make reasonable commercial efforts to protect their personal information. We are committed to adopting consistent and strict policies in all operations. We hope to explain to you through the Privacy Policy (hereinafter referred to as "this Policy") our processing rules and related matters when collecting and using personal information, in order to better protect your and related individuals' rights.
This policy applies to the websites, PC platforms, Zhongbei ticket management apps, mini programs, and various products and services provided to you in new forms that arise with technological development (hereinafter collectively referred to as "mobile applications" or "products/services") that we operate, develop, and manage. If other products or services of our affiliated companies use products or services from mobile applications (such as logging in with a Zhongbei account) but do not have a separate privacy policy, this policy also applies to that part of the products or services. If other products or services provided to you by our affiliated companies have separate privacy policies, the corresponding products or services shall be subject to the corresponding privacy policies.
Please read this policy carefully and have a detailed understanding of how we collect and use information, so that you can better understand our services and make appropriate choices. Please confirm that you fully understand and agree to this policy before starting to use the mobile application. If you click on "Agree to this Policy" or check an option with a similar meaning, or actively log in, confirm, agree, accept, and use the mobile application and related services we provide, it means that you agree to our collection, use, storage, sharing, transfer, and disclosure of personal information in accordance with this Policy (including updated versions). The relevant special tips are as follows:
In order to provide you with the basic functions of our products and services, you need to authorize us to collect and use necessary information; If you refuse to provide such necessary information, you will not be able to use our products and services normally.
If you refuse us to collect any of your personal information, we will not be able to provide you with the complete basic service functions of this platform.
In order to provide you with the expanded functions of our services and products, you may choose to authorize us to further collect and use information other than that required to achieve basic functions; If you refuse to provide such information, you will not be able to use the relevant additional functions or achieve the intended functional effects, but it will not affect the basic functions of your use of our products and services.
If a certain information cannot identify your personal identity alone or in combination with other information, then that information does not belong to your personal information in the legal sense. When the information we have objectively identifies your personal identity by combining it with other information, even if we unintentionally or cannot ultimately identify your personal identity by obtaining or combining any other information, this information will still be treated and protected as personal information in accordance with this policy during its use.
The functions and services we provide to you are constantly updated and developed. If a certain function or service is not described below and collects your information, we will separately explain the content, scope, and purpose of the information collection to you through instant notification (including pop ups, page prompts, website announcements, interaction processes, etc.), function update instructions, etc., and obtain your separate consent for a certain function or service. These instant notifications and feature update instructions constitute a part of this privacy policy and have the same legal effect as this privacy policy.
If you have any questions about this policy or related matters, please contact us via email zbpgadmin@zbpg.top Contact us via email or through the contact information provided in the "How to Contact Us" section of this policy.
catalogue
1、 How do we collect and use personal information
2、 How do we use cookies and similar technologies
3、 Personal information that we may share, transfer or disclose
4、 How do we store and protect personal information
5、 How to exercise your rights
6、 Third party websites and services
7、 Cross border transmission of personal information
8、 Special protection for minors
9、 Notice and Revision
10、 How to contact us
1、 How do we collect and use personal information
（1） The personal information we collect and use
Personal information refers to various information related to identified or identifiable natural persons recorded electronically or in other ways, excluding anonymized information. Sensitive personal information refers to personal information that, once leaked or illegally used, can easily lead to the infringement of a natural person's personal dignity or endanger their personal and property safety, including biometric, religious beliefs, specific identities, medical and health information, financial accounts, whereabouts, and personal information of minors under the age of fourteen. We will prominently highlight sensitive personal information in bold and underlined in this policy.
In the process of using our products/services, we will collect information that you voluntarily provide, authorize to provide, or provide based on your requirements, as well as information generated when you use mobile applications, in the following ways, in order to provide you with services, optimize services, and ensure the security of your account. If you refuse to provide or agree to our collection of this information, you will not be able to access the corresponding services.
1. Registration and Login
(1) When you register and log in to our products and services, you can create or log in to an account using your phone number, email, password, or verification code; At the same time, you can improve the relevant network identification information to enhance your personal information. Without logging in, we may collect your unique device identifier (such as IMEI, IDFA, IDFV, Android ID) for statistical purposes.
(2) When you register/log in, in order to ensure the security of your account, we will use human-machine authentication function to collect your browser type and settings, device type and settings, operating system, mobile network information (including carrier and phone number), and application version number through SDK.
2. Account management
When you add, cancel, unlock accounts, retrieve and modify passwords, in order to ensure the security of your account, we need to verify your information, mainly including your phone number, email, and password.
3. Services provided by Zhongbei International
If you wish to use the relevant services provided by Zhongbei International, you can access Zhongbei International's service platform and pages through our mobile application. Account opening and related functions are provided to you by Zhongbei International. You need to first visit the service platforms and pages operated by Zhongbei International in the relevant countries and regions. Afterwards, according to local regulations, laws and regulations, and account opening rules, you may need to provide your identity information, identification information, contact information, biometric information, and address information directly to Zhongbei International; When evaluating the suitability of your investment, you may need to provide your professional status, asset information, and income situation directly to Zhongbei International on your own; During the account opening process, you may need to enable the camera and microphone permissions on your device. The above information is collected by Zhongbei International and is subject to the personal information processing rules of Zhongbei International. You can further refer to the Zhongbei International Privacy Policy. After understanding the Privacy Policy of Zhongbei International, you can choose whether to provide the above information or enable the above permissions. If you do not wish to provide the above information or refuse to enable the above permissions, you may not be able to complete the registration process normally and will not be able to use the corresponding services and functions provided by Zhongbei International, but it does not affect your use of our mobile applications and the products/services we provide under this policy.
4. Storage function
By default, mobile applications only access storage space within the application sandbox/directory allocated by the Android system. After you authorize read/write access to your device storage, we will read or write necessary information such as images, files, crash logs, etc. from your device storage space to provide you with information publishing or local crash log recording functions, ensuring the stable operation of mobile applications.
5. Safe operation
To meet the basic requirements of laws and regulations and provide services, and to ensure the security of your account and system operation, we analyze the collected information to facilitate the troubleshooting of system failures, in order to achieve product development and upgrading, and optimize service quality. We will collect your device information and operation log information, which includes:
(1) Device Information: We will receive and record device related information based on the specific permissions you grant during the installation and use of mobile applications, including device name, device model, unique device identifier (such as IMEI, IDFA, IDFV, Android ID), operating system, IP address, device MAC address, software installation list, resolution, mobile application download channel, current mobile application version number, mobile application language setting information, and device sensor information (such as gravity sensor, gyroscope sensor, electromagnetic field sensor, acceleration sensor).
(2) Operation log information: When you use our mobile application, we will automatically collect detailed usage information of our mobile application as relevant network logs for storage. We need to collect your log information, including account status, login time, browsing history, which also includes your IP address, browser type, language used, operating system version, access date and time, network requests, etc. We will obtain storage permissions for your device to save the aforementioned log information.
6. Customer service
When you contact us for dispute resolution or apply for account related business operations, in order to ensure the security of your account and system, we need you to provide necessary personal information to verify your identity. In order to facilitate contact with you, help you solve the problem as soon as possible, or record the solution and results of related issues, we may save your communication/call records and related content with us (including account information, other information you provide to prove relevant facts, or contact information you leave). In order to provide services and improve service quality, we may also use your other information, including the relevant information you provide when contacting customer service, and the questionnaire response information you send us when participating in surveys.
（2） Our rules for the use of personal information
1. We will use the personal information authorized by you for the purposes and purposes specified in this policy to achieve the functionality of the mobile application. Please understand that the products and/or services we provide to you will be constantly updated and changed. Please note that if we intend to use personal information for purposes not specified in this policy or collect additional personal information not mentioned, we will provide you with detailed information on the purpose, method, and type of information collection through page prompts, interactive processes, website announcements, or other means, and obtain your consent separately. Once you agree, such additional information or use will be considered part of this policy and will also be subject to this policy.
When we collect various sensitive personal information from you, we will obtain your consent again through page prompts, interactive processes, website announcements, or other means in accordance with applicable laws, and minimize the impact on your personal rights. If we want to collect sensitive personal information that is not specified in this policy, or use the already specified sensitive personal information for other purposes that are not specified, we will also explain in detail to you the necessity, method, type, and impact on your personal rights of information collection through the above methods.
3. Please note that if the information you provide contains personal information of others, you must ensure that you have obtained legal authorization from others before providing this personal information to us.
（3） Exceptions with your authorized consent
In the following situations, we may also collect and use your personal information, but please be fully aware that collecting your information in the following situations does not require your authorization or consent:
(1) Related to the implementation of laws, regulations, and regulatory provisions;
(2) Directly related to national security and defense security;
(3) Directly related to public safety, public health, and major public interests;
(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments;
(5) For the purpose of safeguarding your own or other individuals' significant legitimate rights and interests such as life and property, but it is difficult to obtain your consent;
(6) The information collected is self disclosed by you to the public;
(7) Collecting information from legally disclosed sources, such as legitimate news reports, government information disclosure, and other channels;
(8) Necessary to sign or fulfill the contract according to your requirements;
(9) Necessary for maintaining mobile applications or other network platforms;
(10) Other circumstances stipulated by laws and regulations.
2. You acknowledge and agree that after collecting personal information, we may use technical means to de identify the information. The de identified information will not be able to identify your identity without the use of additional information. In this case, we may use the de identified information to analyze the database and commercialize it without obtaining your consent separately. All personal information you provide when using mobile applications will continue to authorize us to use it unless you delete it or refuse us to continue collecting it through device system settings.
2、 How do we use cookies and similar technologies
（1） Cookie
A cookie is a small text file created by a website server and stored on the user's browser. When the user accesses the website server, the website can access the cookie information. Cookies can be used not only to confirm user identity, but also to store user information and track user access behavior.
We do not collect or track any information or behavior from users through cookies, except for confirming their identity and login status.
If you use our web version product, you can manage and delete cookies according to your preferences. Most browsers allow you to disable or delete cookies in the system. It should be noted that blocking cookies may result in the functionality or services provided by us on our website or system that rely on cookies not working effectively or being unusable, which may affect your user experience.
（2） Cookie like technology
In addition to cookies, we will also use Authorization or "Web Beacon" and other similar technologies on the website. Authorization is the HTTP protocol header transmitted behind the Internet browser and the Internet server, which can replace cookies. Web Beacon can be used to calculate users browsing the web page or accessing some cookies. We will use Authorization to record your identity and collect information about your web browsing activity through network beacons, such as Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), visited pages, operating system, date/timestamp, and click data stream, so that we can have a deeper understanding and improve our products or services.
Many web browsers have a Do Not Track function, which can issue Do Not Track requests to websites. At present, the major Internet standards organizations have not established relevant policies to specify how websites should respond to such requests. But if your browser has enabled Do Not Track, we will respect your choice.
3、 Personal information that we may share, transfer or disclose
（1） Sharing
1. Without your consent, we will not share personal information with any third party, except in the following circumstances:
(1) Sharing with your consent: After obtaining your explicit consent, we share your personal information with other parties.
(2) Sharing under legal circumstances: We may share your personal information with external parties in accordance with laws and regulations, litigation dispute resolution needs, or as required by administrative or judicial authorities in accordance with the law.
(3) Shared with authorized partners: Some of our services will be provided by our partners solely for the purposes stated in this policy. Therefore, in order to ensure the provision of relevant services to you and improve your user experience, we may share the personal information you provide with our partners. For example, when you participate in the reward activities we provide, we must share your personal information with our partners in order to arrange the distribution of rewards or arrange for our partners to provide services. For example, in order to contact users to handle disputes, handle personal account related business operations, or in case of special business situations that require urgent bulk notifications to users, we need to cooperate with outbound platforms, share your contact information and notification content, and provide you with customer service.
(4) Necessary sharing with related parties: In order for us to provide you with consistent services and personalized recommendations, we will share personal information between companies or related parties that we directly or indirectly control. But these shares will be subject to the purposes stated in this policy. We will only share your personal information with our affiliates when necessary and subject to the purposes stated in this policy. If our affiliates want to change the purpose and method of processing personal information, they will seek your authorization and consent again.
(5) When you have questions that need to be answered, complain about us, complain about others, or are complained about by others, in order to protect your and others' legitimate rights and interests, we may save your name and contact information, the relevant content of the complaint and communication in the customer service system provided by third-party suppliers, and may provide it to the consumer rights protection department and other regulatory authorities for timely resolution of complaints and disputes, except for those explicitly prohibited by laws and regulations.
(6) When we need professional advice, we may share your personal information with our accountants, auditors, lawyers, or similar consultants.
(7) We may share reports on trends and their advertising effectiveness with advertising partners to help them better understand their audience. We will not share any of your personally identifiable information unless you allow us to do so.
(8) Other agreements between you and us regarding information sharing.
2. Your personal information may be shared with affiliated companies of Zhongbei in accordance with the provisions of Article (1) of this section. Such affiliated companies may only use your personal information in accordance with this privacy policy. If we need to change the purpose and method of processing your personal information, we will seek your authorization and consent separately. Our affiliated companies include but are not limited to Beijing Zhijianfengyi Information Technology Co., Ltd.
3. In order to achieve the purposes stated in this policy, we may integrate third-party software tools into the application and share some of your personal information with such third parties in order to provide better customer service and experience. Regarding the directory of partners we access and the sharing of personal information, please refer to the 'List of Third Party Shared Personal Information'.
4. We will only share personal information for lawful, legitimate, necessary, specific, and clear purposes. We will require companies, organizations, and individuals with whom we share personal information to process the information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures. At the same time, we will fulfill corresponding legal obligations in accordance with applicable laws and regulations, such as informing you of the recipient's name and contact information, sharing purposes and methods, the types of personal information shared, and obtaining your explicit consent through page prompts, interactive processes, website announcements, or other means; If there are any changes to the aforementioned content, we will seek your consent again.
（2） Transfer
We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:
1. Obtain your explicit consent in advance;
2. According to laws and regulations or mandatory administrative or judicial requirements;
When it comes to asset transfer, acquisition, merger, restructuring or bankruptcy liquidation, if it involves the transfer of personal information, we will inform you of the relevant situation and require new companies or organizations holding your personal information to continue to be bound by this policy. If the purpose or method of using personal information is changed, we will require the company or organization to obtain your explicit consent again.
（3） Disclosure
We will only disclose personal information under the following circumstances and with industry standard security measures in place:
1. According to your needs, disclose the information you have specified in the disclosure method that you have explicitly agreed to;
2. When announcing the list of certain winning activities, the winners' phone numbers or user nicknames will be desensitized and displayed;
3. In cases where laws, regulations, judiciary, legal procedures, or mandatory administrative enforcement requirements from government authorities require the provision of your personal information, we may publicly disclose your personal information in accordance with the scope and manner of the required personal information;
When we receive a request to disclose your personal information based on legal, regulatory, judicial, legal procedures, or mandatory administrative enforcement requirements from government authorities, we will request the relevant department making the request to provide reasonable documents to ensure that the request has a legal basis and that the relevant enforcement department has the legal right and reasonable purpose to obtain your personal information.
（4） Exceptions to obtaining prior authorization and consent for sharing, transferring, or disclosing information
If it meets the exceptions of "1. (3) Obtaining Your Authorization and Consent" in this policy, we do not need to obtain your prior authorization and consent for sharing, transferring, or disclosing personal information.
According to relevant laws, regulations, regulatory requirements, and our business needs, we may share, transfer, or disclose personal information that has been de identified or anonymized. Please be informed that sharing, transferring, or disclosing personal information that has been anonymized or de identified, and ensuring that the information recipient cannot recover and re identify the information subject, does not constitute external sharing, transfer, or public disclosure of personal information. The storage and processing of such information will not require further notice to you and your consent will be obtained.
4、 How do we store and protect personal information
（1） Storage
1. Storage location: Personal information collected and generated by us operating mobile applications and products/services in accordance with this policy within the territory of the People's Republic of China will be stored within China. If we need to store and process your personal information collected and processed under this policy overseas, we will strictly comply with applicable laws and regulations and ensure the security of your personal information. Please refer to "7. Cross border Transmission of Personal Information" in this policy for details.
2. Storage period: We will retain your personal information for the period necessary to achieve the purposes described in this policy, unless required or permitted by laws, regulations, rules, or normative documents to store such information for a longer period of time, such as in the following situations:
(1) To comply with applicable laws, regulations, and other relevant provisions;
(2) To comply with the provisions of court judgments, rulings or other legal procedures;
(3) To comply with the requirements of relevant government agencies or legally authorized organizations;
(4) Reasonable extension of the deadline is required for financial, auditing, dispute resolution, and other purposes;
After exceeding the retention period, we will delete your personal information or anonymize it in accordance with applicable laws.
3. Termination of operation: If we terminate the service or operation, we will notify you at least thirty days in advance and delete or anonymize your personal information after the termination of the service or operation.
（2） Protection
We attach great importance to information security and take reasonable preventive measures to protect personal information
1. We have taken security measures that comply with industry standards and are reasonable and feasible to protect your information, preventing unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable and feasible measures to protect your personal information. We take physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration, including but not limited to transport layer data encryption, firewalls and encrypted storage, physical access control, and information access authorization control. We have set up security programs to protect your information from unauthorized access. For example, we ensure that all of your network communications are protected using encryption technology (SSL). We use high-strength encryption measures to encrypt and store your personal information on our servers. We will use trusted protection mechanisms to prevent personal information from being maliciously attacked; We deploy strict data access control and multi factor authentication technology to protect personal information and prevent unauthorized access and use of data. When using personal information, such as displaying personal information and calculating personal information associations, we will use various data anonymization techniques including content replacement and SHA256 to enhance the security of personal information during use. We adopt techniques such as code security automatic checks and data access log analysis to strengthen personal information security audits.
2. We have an industry-leading data security management system centered around data lifecycle, which enhances the security of the entire system from multiple dimensions such as organizational construction, system design, personnel management, and product technology, ensuring the protection of your personal information. For example, we establish a data classification and grading system, data security management standards, security development standards, etc. to regulate the storage and use of personal information, and fulfill obligations such as security impact assessment and risk assessment in accordance with applicable laws. We require all employees to sign a confidentiality agreement. We will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information and strictly follow protection requirements through assessment, review, and incorporating data protection into their daily assessments.
3. In addition to providing systematic personal data protection measures, our Security Department - Personal Information Protection Specialist will serve as the Data Protection Officer (DPO) responsible for your data protection work.
4. We will take all reasonable and feasible measures to avoid collecting irrelevant personal information. We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless an extension of the retention period is required or permitted by law. After the necessary period, we will delete or anonymize your personal information, except as otherwise provided by laws and regulations. When our products or services cease operation, we will notify you in the form of push notifications, announcements, etc.
5. Please know and understand that the Internet is not an absolutely secure environment. We strongly recommend that you use our products and services in a secure way and with complex and reliable passwords to help us ensure the security of your account. If you discover that your personal information has been leaked, especially your account or password, please contact us immediately using the contact information provided in this policy so that we can take appropriate measures.
6. In the event of an unfortunate personal information security incident, we will inform you in accordance with legal and regulatory requirements of the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will inform you of the relevant situation of the event through email, letter, phone, push notifications, etc. If it is difficult to inform each user one by one, we will adopt a reasonable and effective way to publish an announcement. At the same time, we will also report the handling of information security incidents in accordance with regulatory requirements.
（3） Security incident handling
If there is a personal information leakage or other security incident, we will promptly handle it in accordance with regulations to prevent the security incident from escalating.
Please understand that due to technological limitations and risk prevention limitations, even if we have tried our best to strengthen security measures, we cannot always guarantee 100% information security. You need to understand that the system and communication network you are using may experience issues due to situations beyond our control, and communication methods with other customers such as email, instant messaging, social media, or other service software cannot be fully encrypted. We recommend that you use complex passwords when using such tools and take care to protect your information security.
Please make sure to properly safeguard your account, password, and other identity elements. When you use mobile applications, we will identify your identity through your account, password, and other identity elements. Once you disclose the aforementioned information, you and related parties may suffer losses and may have adverse effects on you. If you find that your account, password, and/or other identity elements may or have been leaked, please contact us immediately so that we can take appropriate measures in a timely manner to avoid or reduce related losses.
5、 How to exercise your rights
According to relevant laws, regulations, standards in China, as well as common practices in other countries and regions, we guarantee that you exercise the following rights over your personal information.
（1） Accessing, correcting, and deleting your personal information
1. Accessing and correcting your personal information
(1) You have the right to access and correct your personal information, except for exceptions provided by laws and regulations.
(2) You can log in to our app to enter the "My" page, click on the "Settings" in the upper right corner to enter the "Edit Information" section to access and change bound phone and email information; Modify personal information in "My" - "Edit Information"; Change login password, etc. under "My" - "Settings".
(3) You can log in to our app to enter the "My" page, click on "Settings" in the upper right corner to enter "Privacy Management".
(4) You have the right to obtain a copy of your personal information retained by our company. You can apply for a copy by calling customer service, and we will send the copy file to the email linked to your account within the legal time limit. Please note that in certain circumstances, we have the right to refuse requests to access copies of personal information (especially information protected by laws and regulations).
(5) If you are unable to access or correct the above information, you can contact customer service and we will respond to your access request within 15 working days.
(6) When you change your personal information or discover errors in your personal information that may affect our provision of services, or affect the normal transactions of the relevant parties represented by you, or in accordance with relevant laws and regulations that should be corrected in a timely manner, you should correct it yourself or contact us to request correction. Otherwise, all adverse consequences caused by this shall be borne by you.
2. Delete your personal information
(1) In the following situations, you can request the deletion of personal information from us. The deletion request method can be found in the contact information in this policy. We will promptly process the deletion after receiving your request:
·If our handling of your personal information violates legal regulations;
·If we collect and use your personal information without your explicit consent;
·If our handling of personal information seriously violates the terms of our agreement with you;
·If you no longer use our products or services, or if you have voluntarily cancelled your account;
·If we no longer provide you with products or services.
(2) If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us to delete it in a timely manner, unless otherwise provided by laws and regulations, or if these entities have obtained your independent authorization. When you delete information from our service, we may not immediately delete the corresponding information in the backup system, but will delete it when the backup is updated.
（2） Change the scope of your authorization or revoke your authorization
1. You can change the scope of your authorization for us to continue collecting personal information or revoke your authorization by deleting information, disabling device functions, or other means. You can also revoke all authorization for us to continue collecting your personal information by canceling your account.
2. Please understand that each business function requires some basic personal information to be completed. When you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawal of consent or authorization, nor will we process your corresponding personal information. But your decision to withdraw consent or authorization will not affect the personal information processing previously carried out based on your authorization. Moreover, due to technological limitations, legal regulations, or regulatory requirements, we may not be able to immediately meet all of your requirements. We will securely store your personal information and restrict any further processing of it until the backup can be cleared or anonymized.
（3） In response to your above request
To ensure safety, we may require you to provide a written request or other proof of your identity. We will respond to your request within fifteen working days after receiving your feedback on identity verification and completing the verification. If you are not satisfied with our response, you can also seek external resolution mechanisms through the methods provided in Section 10 below.
For your reasonable requests, we generally do not charge any fees, but for requests that are repeated multiple times or exceed reasonable limits, we will charge a certain cost fee depending on the situation. We may refuse requests that are unnecessarily repetitive, require excessive technical means (such as developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are highly impractical (such as involving information stored on backup tapes).
In the following situations, as required by laws and regulations, we will not be able to respond to your request:
1. Relevant to our obligations under laws and regulations;
2. Directly related to national security and defense security;
3. Directly related to public safety, public health, and major public interests;
4. Directly related to criminal investigation, prosecution, and trial;
5. There is sufficient evidence to indicate that you have subjective malice or abuse of power;
6. For the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property, but it is difficult to obtain my consent;
7. Responding to your request will result in serious harm to your or other individuals' or organizations' legitimate rights and interests;
8. Involving trade secrets.
6、 Third party websites and services
Our mobile applications may link to links or other services provided by third parties (including websites, WeChat, or other forms of services).
You can also use your Zhongbei account to log in to third-party platforms. With your consent, third parties may collect your personal information (including profile picture, nickname, and your log information) and may install automatic data collection tools on your computer to operate the above functions normally.
The above-mentioned third-party services are operated by the relevant third parties. This policy only applies to the personal information we collect and does not apply to any third-party services or information usage rules provided by third parties. Your use of such third-party services and any information you provide to such third parties will be subject to their terms of service and personal information protection rules (rather than this policy). You should carefully read their terms and rules, carefully assess the risks, and decide whether to accept, use third-party services or provide relevant information to third parties on your own. If you find that these third-party services pose risks, we recommend that you terminate the relevant operations to protect your legitimate rights and interests.
7、 Cross border transmission of personal information
1. The personal information collected and generated by our operation of mobile applications and products/services within the territory of the People's Republic of China in accordance with this policy will be stored within the territory of the People's Republic of China. If necessary for business or management purposes, we need to transmit your personal information collected and processed under this policy to overseas parties (including making your personal information accessible to other jurisdictions). Before transmission, we will strictly comply with the provisions of laws and regulations and the requirements of regulatory authorities to meet the necessary prerequisites and fulfill corresponding legal obligations, including informing you of the name and contact information of the overseas recipient, the purpose and method of transmission, the type of personal information transmitted, the way and procedure for you to exercise your rights to the overseas recipient, and obtaining your separate explicit consent. Although other countries have different data protection laws, we will ensure that your personal information is protected equally in other countries as it is within the territory of the People's Republic of China.
2. If you visit the service platforms and pages of international securities firms or third parties to obtain their products or services, international securities firms or third parties may provide products or services through global resources and servers. If you wish to obtain such products or services, you may need to provide relevant information directly to international securities firms or third parties located overseas according to the needs of the relevant products or services. Please refer to the relevant content of this policy to carefully assess risks and make your own decision on whether to accept, use related products or services, or provide relevant information to international securities firms or third parties.
8、 Special protection for minors
Minors should not access our services, and we will not collect personal information from minors; If you believe that we may have collected information from your children or guardians under the age of 18 without your knowledge, please contact us in accordance with Section 10 of this policy, and we will delete such information.
9、 Notice and Revision
We may modify this policy in a timely manner based on the development of our products or services and relevant legal requirements.
After the revision of this policy, you have the right to choose to accept the updated personal information protection policy or stop using mobile applications. If you continue to use it, it will be deemed that you have fully read, understood, and accepted the revised personal information protection policy.
In order to fully protect your legitimate rights and interests and keep you informed of the latest information on personal information protection, we will publish an updated version of this policy on the mobile application ("My → Settings → Privacy Policy") page. For significant changes, we will also provide more prominent notifications (including notification through public announcement or providing you with pop-up prompts). Please also visit our privacy policy page frequently to stay up-to-date with the latest privacy policies.
The significant changes referred to in this policy include but are not limited to:
（1） Our service model has undergone significant changes. Such as the purpose of processing personal information, the types of personal information processed, and the ways in which personal information is used;
（2） We have undergone significant changes in control rights, such as changes in information controllers caused by mergers and acquisitions;
（3） The main objects of personal information sharing, transfer or public disclosure have changed;
（4） There has been a significant change in your right to participate in personal information processing and the way you exercise it;
（5） Our responsible department, contact information, and complaint channels for handling personal information security have changed;
（6） When the personal information security impact assessment report indicates the presence of high risks.
This agreement is written in both Chinese and English. If there is any inconsistency between the Chinese and English versions, please refer to the English version.
10、 How to contact us
（1） The operating unit is Shenzhen Zhongbei International Enterprise Management Service Co., Ltd. If you have any questions, opinions or suggestions regarding this policy or your personal information, please send an email to zbpgadmin@zbpg.top Or call our customer service hotline at 852-56216885 and other ways to contact us.
（2） We have established a Security Department - Personal Information Protection Specialist. You can send an email to zbpgadmin@zbpg.top The way to connect with it.
（3） Normally, we will reply within 15 working days after receiving your feedback. If you are not satisfied with our response, especially if you believe that our personal information processing has harmed your legitimate rights and interests, you can also file a complaint or report to regulatory authorities such as cyberspace, telecommunications, public security, and industry and commerce.