Privacy Policy

Last modified: 01 JUL 2022

Introduction

ZHEJIANG HUACHUANG VISION TECHNOLOGY CO.，LTD. and our associated companies (“we” or “us” or “our” or “Huachuang”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (the “Privacy Policy”). For more information on Huachuang associated companies and their contact details see https://www.hitrolink.com/ 

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our websitehttps://www.hitrolink.com/, including any subdomains and any content, functionality and services offered on, by or through it or them, or any other websites, e-mails, applications that link to this Privacy Policy (collectively referred to as “Services”). This Privacy Policy also describes how we collect, use, maintain, share, protect and disclose that information. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

This Privacy Policy includes the following contents:

1.Information We Collect About You and How We Collect It

2.Children under the Age of 16

3.How We Use Your Information

4.Information Sharing

5.Data Security Measures

6.International Transfers

7.Your Rights

8.Changes to our Privacy Policy

9.Contact

1.Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services, including information that identifies you personally, such as name, postal address, e-mail address and telephone number (“personal data”). We also collect information that is about you, but individually does not identify you, such as demographic data, and information about your Internet connection, the equipment you use to access our Services and usage details.

We collect this information directly from you when you provide it to us. We may also automatically collect certain information as you navigate through the website or use our Services, such as usage details, equipment profiles and IP addresses, by means of cookies, web beacons and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Services may include:

•Name, address and other identifying information

We collect contact details such as your address, telephone number and e-mail address when you register for an event or exhibition via our website, apply for a newsletter, or when you leave your business card at an event or exhibition.

•Information that you provide at the time of registering for use of or access to our Services

For example, subscribing to our posting material, requesting further services, registering for newsletters or other communications, entering a contest or promotion sponsored by us, reserving place for participation in our training or marketing activities, or reporting a problem with our Services.

•Information you provide when you use certain features of our Services

For example, records and copies of your correspondence (including e-mail addresses) if you contact us; requests for repair services of products bought from us, product model and S/N, and contacts for their delivery after repair; your responses to surveys that we might ask you to complete for research or other purposes; your search queries on the use of our Services.

•Information you provide when you apply for a job

When you decide to apply for a job, we may collect information about you via the forms you fill in on the ‘Career’ section of our website, including any files you choose to attach. Moreover, we may also collect information about you via other channels such as social media or recruitment agencies (if you got into contact with us via them) when you apply for a position.

•Information we collect during an event/exhibition

When we organize events and exhibitions we may collect personal data during these events. During these live events we also demonstrate our devices and may record live images that include data. During these exhibitions we may also collect data from you directly, like for example, when you fill in an enquiry during an event or exhibition.

•Personal information required for the performance of a contract

Details of transactions you carry out through the use of our Services and of the fulfillment of your orders (note that you may be required to provide financial information before placing an order through our Services).

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of our website, or transmitted to other users of our websites or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the websites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

Our Site and apps use cookies and similar technologies. We use functional cookies to ensure that our Site and Services operate properly and analytical cookies to make your user experience optimal. Third-party cookies may collect data outside our websites as well. As you navigate through and interact with the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, traffic data, logs and other communication data. You can find more information on our Cookie Statement.

Our Privacy Policy does not cover the use of cookies by others, including, without limitation, our partners, affiliates, tracking utility company and service providers. We do not have access or control over these cookies.

2.Children under the Age of 16

Our websites are not generally targeted at children under 16 years of age. No one under age 16 should provide any personal data to or on our Services. We do not knowingly collect personal data from children under 16.

Huachuang strongly recommends that parents take an active role in supervising the online activities of their children. If you believe we might have any information from or about a child under 16, please contact us at

3.How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data for the following main purposes:

•To carry out our agreement with you, including billing and collection

When you enter into an agreement with us, we process your personal data for the purpose of delivering you the products and services. This includes the processing of personal data relevant for concluding the agreement and the performance of obligations of both parties.

•To provide our online services to you

We process a username and password when you register at our website to have access to a range of services such as training courses, access to marketing materials and software and or repair support for products you have purchased from us and their delivery after repair. In addition, this also includes that we process contact details to contact you in case of technical issues with your account. In addition to the account details, we also use this data for the purpose of recording the progress of your training, or the complete history of support we provided to you with regard to our products and services, or to send you invitations to our marketing activities for which you have registered your interest via our Website.

•To communicate with you

We use your contact details to communicate with you, provide you with information you request about us, answer your questions or when we handle your complaints.

•For statistical research

- General. We use automatic tools to perform statistical research into general trends regarding the use of our services, websites, apps and social media and the behavior and preferences of our customers and users. We also send periodically enquiries to our customers and prospects to gain insight in their opinions and preferences.

- Data. To perform our research, we may merge and analyze the different types of data as described above. We may also combine such aggregated data with information we receive from our group companies or from market research. Without your consent we will not use sensitive data for this statistical research.

- Interests and benefits. Statistical research helps us to develop better services and offerings, to provide more responsive customer support and to improve the design and content of our websites, products and mobile apps.

•For direct marketing

- General. We may use your personal information to send you newsletters, promotions or other marketing communications, including invitations to our exhibitions.

- Categories of data. To understand what is relevant for you we may use automatic tools to analyze your personal information. For this purpose, we may use and combine the information described above. We may also combine such data with information we receive from our group companies or from other sources, such as market research or public information. Without your consent we will not use sensitive data for statistical research.

- Interest and benefits. We use the results of our analysis to tailor our marketing communications to your (and the company you represent), specific interests and preferences. For example, if we notice that you work in a specific sector, such as banking, we may customize our offers, invitations to exhibitions and newsletters to this sector.

- Channels. We use different channels for our marketing communications, such as e-mail, apps, social media and your personal online account.

- Object or revoke. You may object or revoke your consent for receiving marketing communications at any time by following the instructions in the relevant marketing communication or by contacting us 

•To comply with statutory obligations

We may be required by law to collect and share your identifying information and personal data with public or governmental organizations for the purpose of compliance with the law, a court order, or to respond to any government or regulatory request.

We only use "Aggregated" or “De-identified” information to: (a) understand users’ preferences; (b) enhance and optimize users’ experience; (c) improve the functional design to better support the users; (d) provide better customer care and customer service; and (e) gather analytical data.

We process your personal data on the basis of the following legal grounds: on the basis of your consent, for the performance of a contract with you, to comply with legal obligations we are subject to and on the basis of our legitimate interests or the interests of a third party as described in this policy. When we process your personal data for our legitimate interests or the interests of a third party, we will take reasonable measures to prevent unwarranted harm to you. Our legitimate interests may for example be improving our newsletters and website by analysing which parts of our communications are most relevant for persons interested in our activities, or securing our website and facilities. For more information on these interests, please contact us to understand the purposes for which we process your personal data (see below).

4.Information Sharing

We may disclose your personal data with certain trusted third parties that perform business functions for us or provide services to us, being our subsidiaries and affiliates; or contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.

The main purposes of sharing are:

•To deliver your orders and provide you the services requested from us

To deliver you the products you order and the services you request such as training, repair of products, participation in roadshows and other marketing activities, we may share your personal data with our group companies, and other companies involved in facilitating you with services such as distributors or dealers. For more information about our group companies, please visit our website under About Us or feel free to contact us.

•To keep in touch with our prospects, customers, and former customer

We may share your personal data with subsidiaries and partners for the purpose of being able to contact you in the future and provide you with services. This includes sharing personal data within the group for the purposes of customer relation management.

•For statistical research and direct marketing

We may share your personal data within our group for the purpose of statistical research and direct marketing.

•To let you benefit special offers of partners of Huachuang

We may share your information with our partners to let you benefit from the services of these partners that we integrate or offer in our own services and apps. For example, when we cooperate with resellers or when we organize or participate in exhibitions and other marketing events organized by third parties, either in their entirety or in cooperation with us.

All such third parties will be required to adequately safeguard your personal data, subject to agreements that correspond to the requirements of applicable laws.

We may also disclose your personal data:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request or for investigations (e.g. disclosure to prevent crime or fraud, or to comply with a court order or legislation).

• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the legitimate rights, property or safety of Huachuang, our customers or others.

5.Data Security Measures

We have implemented appropriate technical and organizational measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a user name and password for access to certain parts of the Site, you are responsible for keeping these credentials confidential. We ask you not to share your credentials with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site. We periodically review the technologies used and policies implemented for securing the collected information.

Your personal data will be retained for as long as required for the purposes described in this Privacy Policy or in so far as such is necessary for compliance with statutory obligations and for solving any disputes.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

7.Your Rights

You can review and change your personal data by logging into your account on our website and visiting your account profile page. If you are not able to find your personal data you may also send us an e-mail atto request access to, or require us to correct or delete any personal data that you have provided to us. You may also object to or request us to restrict your processing. If we process your personal data based on consent, you may withdraw your consent at any time by contacting us (see below). A summary of your legal rights is set out below:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

For security reasons, we will take steps to authenticate your identity before providing access to your personal data. You also have the right to lodge a complaint with the relevant Data Protection Authority.

8.Changes to Our Privacy Policy

We keep this Privacy Policy under review and modify this Privacy Policy from time to time. We will inform you for any modifications on the Privacy Policy. We will also provide a notice of the modifications on the homepage for a short period. The date the Privacy Policy was last revised is identified at the top of the page.

9.Contact Information

To ask questions or comment on this Privacy Policy or our privacy practices, please contact our Data Protection Officer via phone atthrough email ator by mail at:

ZHEJIANG HUACHUANG VISION TECHNOLOGY CO.，LTD

 Zhejiang Province, 310053 China 

16F, Building 1, Strong Square, No. 1168 Bin'an Road, Binjiang District, Hangzhou City, Hangzhou, P.R.China

COOKIE STATEMENT

We, ZHEJIANG HUACHUANG VISION TECHNOLOGY CO.，LTD. make use of cookies, JavaScript and other technologies (“cookies”) when you visit our website  https://www.hitrolink.com/ The next time you visit our website, some of these cookies ensure that your device is recognized.

1. What are cookies?

A cookie is a small text file that a website saves your computer or mobile device when you visit the site.

2. Which cookies we store and why

Our website uses functional cookies to ensure that it operates properly and analytical cookies to make your user experience optimal.

Functional cookies

These cookies are necessary for basic site functionalities and are therefore set when you visit our websites. These cookies remember your preferences as you use our websites. For example, if any of our websites requires you to register so that you can receive the relevant services, after registration, first-party cookies are used which keep your email stored for a certain period of time, so that you can save time from setting or entering them whenever you come back to the site or move from one page to another. More specifically we use these functional cookies in specific:

Functional Cookies
Name	Domain	Purpose	Expiration period
training_user_id	.hitrolink.com	Store email after registration (login status)	21 days
USER_ID	.hitrolink.com	Store email after registration (login userid)	21 days
training_user_email		Store email after registration (login user email)	30 days
LOGONI		Session I	7 days
username	www.hitrolink.com	Stores email after registration	7, 14, 21 days

Analytical cookies

The cookies are used to collect information about the way in which visitors use Huachuang websites, including information about the pages most visited and the number of error messages displayed, which helps us to create reports on the visibility of our webpages so that we can constantly improve our website. These cookies help Huachuang to improve its websites and to make your browsing experience more friendly and pleasant.

Here are the specifics on the analytical cookies:

Analytical Cookies
Name	Domain	Purpose	Expiration period
Google Analytics  (_ga and _gid)	.hitrolink.com	Clicking behavior, time spent on website, distinguishes each visitor	2 years
USER_ID	.hitrolink.com	Track visitor’s movement across various domains	18 years

3. Control the cookies we store and access

If you would like to revoke consent, you can adjust your browser settings to delete our or third-party cookies. You can also adjust your browser settings to prevent websites from setting cookies or third-party cookies altogether. If you prevent us from setting specific cookies, you may find that some functions are not available or that certain parts of the website will not load. 

4. Questions?

If you have any questions regarding the use of your information, please contact us atat any time.

This statement was last updated on 01/07/2022