No products in the cart.
**Update Date: November 03, 2024**
**Effective Date: November 03, 2024**
Dear Users,
Our website address is: https://newgan.com
We have updated the “NewGaN Mall Privacy Policy” to include details on how the NewGaN Mall client application uses clipboard functionality and to provide additional information on system permissions and authorization management.
The “NewGaN Mall Privacy Policy” (hereinafter referred to as “this Privacy Policy”) applies to all products and/or services provided by Shenzhen NaBaiYe Technology Co., Ltd. (hereinafter referred to as “we”, “NewGaN Mall”) to users (hereinafter referred to as “you”), including but not limited to the NewGaN Mall portal website (https://newgan.com), the NewGaN Mall App, and any existing or future internet products or services operated by NewGaN Mall.
Given the wide range of products and services offered by NewGaN Mall, this Privacy Policy may not cover all possible scenarios involving the collection and processing of personal information for each product and service. Specific content regarding the collection of personal information for particular products or services may be described in separate privacy policies or statements published with those specific products or services. In case of inconsistencies between this Privacy Policy and the specific privacy policies or statements of individual products or services, the latter shall prevail. Please read and fully understand this Privacy Policy and the privacy policies (if any) of specific products or services before using them to make appropriate choices. If you have any questions about this Privacy Policy, you can contact us through the methods provided under “How to Contact Us.” Please use the following contact information:
**Introduction**
This Privacy Policy highlights clauses that significantly affect your rights, sensitive personal information we may collect, and clauses that may exempt or limit our liability using bold text, underlining, or other noticeable means. Please pay special attention to these.
Our products and/or services are only available to individuals who are 18 years of age or older. If you are under 18 years old, especially if you are under 14 years old, please do not use our products and/or services without the consent and guidance of your guardian. If we inadvertently collect the personal information of a child upon receiving your notice, we will promptly delete such information.
This Privacy Policy will help you understand the following:
1. Definition
2. How do we collect and use your personal information?
3. How we use cookies and similar technologies
4. How do we share, transfer, and publicly disclose your personal information
5. How do we protect your personal information?
6. How do we store your personal information?
7. Your rights
8. Other third parties and their services
9. Protection of minors
10 Changes to this Privacy Policy
11. How to contact us
I. Definition
NewGaN Mall: Refers to the operating affiliates that may exist in Shenzhen Nabaiye Technology Co., Ltd. and its related services.
Third party: refers to the suppliers we cooperate with for the collection of personal information, storage of data, system maintenance, business support and other needs, or individuals, companies or other organizations that establish cooperation or investment relations with us for other matters.
Personal information refers to all kinds of information recorded electronically or otherwise that can identify a natural person individually or in combination with other information, but does not include information that has been anonymized.
Personal sensitive information: refers to personal information that may endanger personal and property safety once leaked, illegally provided or misused, and can easily lead to personal reputation, physical and mental health damage or discriminatory treatment. For the relevant personal sensitive information listed in this Privacy Policy, in order to make it easier for you to be alert when reading, we will remind you in this Privacy Policy by means of prominent marks or direct instructions.
Children: Refers to minors under the age of fourteen (inclusive).
Deletion of personal information: refers to the act of removing personal information from the systems involved in the implementation of products and/or services, so that it remains unretrievable and inaccessible.
Anonymization refers to the processing of personal information so that it cannot identify a specific individual and cannot be recovered.
II. How we collect and use your personal information
When you use our products or services, we need to collect and use your personal information to enter into, perform contracts or implement human resource planning. In addition, in some scenarios, in order to provide you with our products or services, you need to authorize and can choose to authorize us to collect and use personal information.
1. Register as our user
When you register and log in to your account, you need to provide us with your mobile number information, and we will send a SMS verification code to your mobile number to verify that your registered mobile number is valid. Please understand that this is necessary to meet the requirements of the network real-name system. In addition, you also need to provide us with your username and registration password information so that we can help you create your username and password, complete account registration and login. If you refuse to provide the above information, you may not be able to register and log in, nor use our products and/or services. During the registration process or after completing account creation, if you provide additional information such as nickname, name, email address, etc., it will help us to provide you with better service and experience. If you do not provide this information, it will not affect the basic functionality of the products and services we provide.
You acknowledge and agree that we are committed to providing you with the entire electronic industry chain and one-stop service, and to facilitate your use of other products and/or services we provide to you. When you register as our user, your registered account will be applicable to a variety of products and/or services under NewGaN Mall and its affiliates.
2. Provide you with WeChat scan code login service
You can bind your account to your WeChat account. In order to provide you with account binding WeChat and WeChat scan code login services, we will collect your WeChat OpenID information.
3. Provide you with viewing and browsing product services
In order to provide you with browsing history, search history, shopping cart or order product display services, we will collect your browsing information, search history, shopping cart purchase products, and order information, and use this information to conduct data analytics, predict your preferences, and push you commercial advertisements, commercial text messages, and other marketing information that may be of interest to you.
4. Provide you with procurement services
When you are ready to settle the goods in your shopping cart, we will automatically generate an order for the goods you purchased for you. You need to fill in at least your order contact person and contact number, technical contact person and contact number, delivery address and mobile phone number in the order, and the order will indicate the customer number, order number, goods or services information you purchased, order time, payment amount you should pay and payment method. We will use the above information to achieve identity verification, transaction confirmation, payment settlement, commodity delivery, order inquiry, customer service consultation and after-sales services functions. We will also use the above information to determine whether there is any abnormality in your transaction to protect your transaction security.
Please note that if you order goods or services for others through our products and/or services, you need to provide the aforementioned information of the actual orderer. Before providing us with the aforementioned information of the actual orderer, you need to ensure that you have obtained their authorization.
5. Provide you with payment services
If you have a payment settlement during our service, you can choose the payment service provided by the third-party payment institution we cooperate with. The payment service itself does not collect your personal information, but we may need to share your order number and transaction amount information with these payment institutions during the payment service process for the payment institution to confirm your payment instruction and complete the payment.
6. Provide you with prepayment services
You can make a prepayment in the prepayment system. In order to facilitate your normal use of the prepayment and refund functions, we need to collect your transfer information, including: your bank card account name, account opening bank account number, and account opening bank name information.
7. Provide you with invoicing services
In order to help you issue an invoice, we need to collect the VAT/general invoice invoicing information you voluntarily provide to us, including: invoicing company name/personal name, invoicing subject, address, phone number, tax number, account opening bank account number, and account opening bank name information. In addition, in order to serve your invoice to you, we need to collect your invoice delivery address information, including: invoice recipient, invoice recipient phone number, and invoice delivery address information.
8. Provide you with product delivery services
After you place an order and complete the payment or redeem the goods with points online, we will collect your order information and receipt information in order to complete the delivery of the goods for you. At the same time, we will share your above information with relevant service providers.
9. Provide you with points redemption function
When you redeem points, we need to collect your receipt information. In addition, if you need to redeem a JD.com card, we also need to collect the information of the mobile phone number bound to your JD.com account in order to complete the delivery of your redeemed items.
10. Feedback, complaints, and dispute resolution
In order to provide you with assistance and receive your feedback, complaints and reports, when you contact us or make a feedback, complaint and dispute resolution application, in order to verify your identity and provide you with feedback, we need you to provide necessary personal information, including the feedback you submitted and your contact information (mobile phone number, email address) and other documents you submitted (if any), and the service records, correspondence and call records formed accordingly. When it comes to feedback, complaints and reports related to your order information, we may also inquire about your order information.
We will send you our important notices through the contact information you provide, including information about the use of the service and changes to the terms, conditions and policies. Because this information is essential to communication between you and us and to safeguard your legitimate interests, you may receive such information unless you stop using the product and/or service.
11. Questionnaire
We may conduct online surveys from time to time to better understand your comments and suggestions on the products and/or services we provide. When conducting a survey, we need to collect the information you submit during the process of answering the questionnaire.
12. Marketing Information
We will use your mobile number to send you information such as our service updates and event announcements (“Marketing Information”). We will fill in the unsubscribe option in the marketing information. If you do not want to receive our marketing information, you can unsubscribe at any time by following the prompts in the marketing information, or contact us through the contact information provided in this Privacy Policy.
13. Safe operation
In order to meet the requirements of laws and regulations such as cyber security and the need for cyber security protection, and to improve the security of your use of products and/or services, protect your personal and property safety and that of third parties or the public from infringement, better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, and network intrusions, and more accurately identify violations of laws and regulations, we may use or integrate your device information, service log information, and information we obtain from third parties through legal authorization to comprehensively judge your operational risks and prevent security incidents in a timely manner.
(1) Equipment information
In order to ensure the security of products and/or services and to investigate possible risks, when you use NewGaN Mall, we will collect the device information you use, including unique device identifiers (IDFA, IMEI, Android ID, IMSI), device type, device manufacturer, device model, screen size, system version, browser, MAC address, device location (IP address, GPS location, WiFi information (SSID, BSSID)), mobile phone operator, network type, and associate these device information.
(2) Log information
In order to count the user usage of products and/or services and provide you with secure services, when you use NewGaN Mall, we will automatically collect detailed information about your use of products and/or services and save it as a network log according to relevant legal requirements, including your Internet Protocol Address, browser type, telecom operator, network environment, language used, date and time of visit, total page browsing records you visited, notification opening records, and length of stay.
Please note that individual device information, log information, etc. are information that cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or combine it with personal information, such non-personal information will be regarded as personal information during the combined use period. Unless authorized by you or otherwise provided by laws and regulations, we will use “desensitization, de-identification, anonymization” and other methods to process such personal information.
14. Legal exemption from collection and use of personal information with consent
You acknowledge and agree that, in accordance with relevant laws and regulations, we do not need your authorization or consent to collect and use personal information in the following circumstances:
(1) It is necessary for the conclusion and performance of the contract you are a party to, or for the implementation of human resource planning in accordance with the labor rules and regulations formulated by law and the collective contract signed by law;
(2) Necessary for the performance of statutory duties or obligations;
(3) It is necessary to respond to public health emergencies or to protect the lives, health and property of natural persons in emergency situations.
(4) Carrying out acts such as coverage and public opinion supervision for the public interest, and processing personal information within a reasonable range;
(5) Handle your self-disclosed or other legally disclosed personal information within a reasonable range in accordance with relevant laws and regulations, unless it has a significant impact on your personal rights and interests or you expressly refuse;
(6) Other circumstances stipulated by laws and administrative regulations.
15. Copy and paste information in client side software
When you copy and paste information in the NewGaN Marketplace client side application, and share or receive shared product/event information, etc., we will request to use your clipboard. We only recognize the clipboard content locally and will not upload your clipboard information to our servers.
16. Sensor information
In order to provide you with some functions of the NewGaN Mall App, we need to collect your sensor information. For example, in order to use the Chromium WebView component, we need to collect your acceleration sensor information and share it to the Chromium to identify whether the user’s screen rotates and realize the display of the App page; in order to realize the camera function, we need to collect your acceleration sensor information to determine whether the device is in motion to achieve re-focusing; in order to realize the positioning function, we will collect your acceleration sensor, magnetic field sensor, direction sensor and gyroscope sensor information; in order to achieve security purposes, we need to collect your acceleration sensor information to assist in identifying whether it is normal user behavior.
17. Application permission application and usage rules
When you upload your business license to verify your enterprise account, or upload related attachments to apply for after-sales services, we will ask you to authorize the camera and storage permissions required for the corresponding function according to the function you want to use. If you do not agree or cancel the authorization, you will not be able to use the corresponding function, but it will not affect your use of other functions of NewGaN Mall. You can also manage the permissions through “My-Settings-System Permissions”.
When we want to use the information for other purposes not stated in this Privacy Policy, we will ask for your consent in advance. At the same time, when we want to use the information collected for a specific purpose for other purposes, we will ask for your consent in advance.
III. How we use cookies and similar technologies
NewGaN Mall and its third-party partners automatically collect certain types of usage information when you use our services, read our emails, or otherwise contact us. We typically collect such information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location recognition technologies, file information, and similar technologies (collectively, “tracking technologies”).
We send you cookies to determine the identity and login status of registered users, simplify your repeated login steps, and ensure account or data security. At the same time, we may collect data obtained by cookies and similar technologies to analyze users’ use of services, improve service quality and optimize user experience.
We do not use cookies and similar technologies for any purpose other than those described in this Privacy Policy. You can manage or delete cookies according to your preferences. Most web browsers automatically accept cookies, but you can usually clear all cookies saved on your computer or manage site-specific cookies in the settings bar of your browser as needed. However, if you do this, you may need to change the user settings yourself every time you visit the NewGaN Mall website, and your previously recorded information will also be deleted, which may have an impact on the security of the services you use.
NewGaN Mall may collect information about your device and its software, such as your Internet Protocol Address, browser type, internet service provider, platform type, device type, operating system, date and timestamp (a unique ID that allows us to recognize your browser, mobile device or account). We also collect information about how you use our website. When you visit our website from a mobile device, we may collect a unique identification number associated with your device or our mobile application.
We may collect analytics data or use third-party analytics tools to help us measure website traffic and usage trends to understand the demographics of our users. We may also employ technologies such as application statistical modeling tools that allow us to identify and contact you across multiple devices.
IV. How do we share, transfer, and publicly disclose your personal information?
(1) Sharing
We will not share your personal information with any company, organization, or individual outside of the NewGaN marketplace, except in the following cases:
1. Sharing with affirmative consent: After obtaining your affirmative consent, we will share your personal information with other parties.
2. We may share your personal information externally in accordance with laws and regulations, or as required by government authorities.
3. Sharing with our affiliates: Your personal information may be shared with affiliates of NewGaN Mall. We will only share the necessary personal information and are bound by the purposes stated in this Privacy Policy. If the affiliate wants to change the purpose of processing personal information, it will ask for your authorization again.
4. Sharing with partners: We may share with our business partners the order information, account info, payment information, etc. necessary to provide you with services. Our business partners include the following types:
(1) Suppliers/service providers. Only for the purpose stated in this Privacy Policy, some of our services will be provided by business partners. To ensure the smooth completion of the services provided to you, we may share your personal information with the above partners, including package payment services, logistics services, after-sales services, etc. This may include your contact information, order information, payment information, address information, etc., to ensure the smooth completion of the services provided to you.
(2) Other business partners. We may also share information with partners who entrust us with promotion and advertising, but we will only provide these partners with information such as the coverage, effectiveness, and statistics of the promotion, and will not provide personal information that can identify you.
(3) Vendors, service providers, and other partners. We may share minimal information with vendors, service providers, and other partners who support our business, including providing technical infrastructure services entrusted to us, analyzing how our services are used, measuring the effectiveness of our services, and providing Client Servers. We conduct rigorous security monitoring of Application Programming Interfaces (APIs), software tool development kits (SDKs), and information systems that authorize our partners to obtain relevant information.
(4) Based on your individual consent. Sharing with other third parties where we have your individual consent (including but not limited to signing other agreements);
(5) Based on social and public interests that comply with laws and regulations.
We will only share your personal information for legitimate, legitimate, necessary, specific and explicit purposes, and only share personal information necessary to provide services. Our partners have no right to use the shared personal information for any other purpose.
All companies, organizations, and individuals with whom we share personal information will have strict confidentiality agreements requiring them to handle personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.
In order to provide you with our products or services, we may need to entrust the above-mentioned affiliates or partners to process and share your personal information. Regarding the handling and sharing of your personal information between NewGaN Mall and third parties, please refer to the “List of Sharing Personal Information with Third Parties by NewGaN Mall”.
(2) Transfer
We will not transfer your personal information to any company, organization or individual, except in the following cases:
1. Transfer with affirmative consent: After obtaining your affirmative consent, we will transfer your personal information to other parties;
In the event of a merger, acquisition 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 to be bound by this Privacy Policy, otherwise we will require the company or organization to seek your authorization again.
(III) Public disclosure
We will only publicly disclose your personal information in the following circumstances:
1. After obtaining your affirmative consent;
2. Disclosure based on law: In the case of mandatory requirements by law, legal process, litigation or government authorities, we may disclose your personal information to the aforementioned regulatory authorities.
According to the law, the sharing, transfer, and disclosure of personal information that has been de-identified, and ensuring that the recipient of the data cannot recover and re-identify the subject of personal information, is not an act of external sharing, transfer, and public disclosure of personal information. The storage and processing of such data will not require further notice to you and your consent.
Please note that the information you voluntarily post or even share publicly when using the products and/or services may involve your or others’ personal information or even sensitive personal information. Please be more cautious when using the products and/or services.
V. How do we protect your personal information?
1. Data security technical measures
In order to ensure the security of your information, we will take various reasonable physical, electronic and management security measures to protect your information, so that your information will not be leaked, damaged or lost, including but not limited to SSL, encrypted storage of information, access control of data centers, dedicated network channels and agents. We also take strict management of employees who may have access to your information, including but not limited to different authority controls according to different positions, signing non-disclosure agreements with them, monitoring relevant operations and other measures. We will provide corresponding security measures according to existing technology to protect your information and provide reasonable security guarantees. We will try our best to ensure that your information is not leaked, damaged or lost at any time.
2. Security certification
We are committed to providing all-round protection for your information security. At present, the NewGaN mall system has passed the three-level protection certification of the Ministry of Public Security Information System. We will also establish an information security system to resist and deal with various information security threats in a timely manner to provide all-round protection for your information security. However, please know and understand that the Internet is not an absolutely safe environment. We strongly recommend that you help us ensure the security of your account through secure means and the use of complex passwords. If you find that your personal information has been leaked, especially your account or password, please contact us immediately according to the contact information provided in this Privacy Policy, so that we can take corresponding measures.
3. Guarantee of cooperation agreements with third parties
Before we share your personal information with other third parties, we will strictly require the third party to assume information protection obligations and responsibilities. To this end, we will require the third party to sign a data processing agreement before cooperation or set out the relevant data protection terms in the cooperation agreement signed by both parties. The agreement strictly stipulates that the third party’s confidentiality obligations to user information, including the storage, use and transfer of information, should meet our control requirements and accept our review, supervision and audit. Once there is any violation, we will require the other party to bear the corresponding legal responsibility.
4. Personal information security incidents
In the unfortunate event of a personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the handling measures we have taken or will take, suggestions for you to prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant situation of the incident by email, letter, phone, push notification, etc. When it is difficult to inform the personal information subject one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.
How do we store your personal information?
1. Storage location. In principle, the personal information we collect and generate within the territory of the People’s Republic of China will be stored within the territory of the People’s Republic of China, except in the following cases: as expressly stipulated by laws and regulations; with your authorization and consent separately. In the above cases, we will and require the data recipient to process personal information in accordance with this Privacy Policy and other relevant security and confidentiality measures.
2. Storage period. We promise to retain your personal information only for the minimum period necessary to achieve the purposes stated in this Privacy Policy, unless there are mandatory retention requirements by law (for example, the “E-Commerce Law of the People’s Republic of China” requires that the retention period of goods and service information and transaction information be not less than three years from the date of completion of the transaction; and other circumstances that require a reasonable extension of the period for financial, audit, dispute resolution, etc.). After your personal information exceeds the retention period, we will delete your personal information or make it anonymous as required by applicable laws.
3. Suspension of the operation of products and/or services. In the event of the suspension of the operation of products and/or services, unless otherwise provided by laws, regulations or regulatory documents, we will inform you of such situation, stop collecting your personal information in a timely manner, and delete or anonymize the personal information that has been collected. If anonymization or deletion is not possible (for example, your personal information has been stored in a backup), we will securely store your personal information and separate it from other data processing, thereby restricting any further processing of it.
VII. Your rights
We take your concerns about personal information very seriously and do our best to protect your rights to access, correct, copy, delete, and withdraw consent to your personal information, so that you have the full ability to protect your privacy and security. Your rights include:
1. Access and correct your personal information.
Except as required by laws and regulations, you have the right to access and correct your personal information at any time. We provide you with access to and correction of your information in the specific interface of our products and/or services. You can also request access to your personal information by sending an email to the person in charge of personal information protection as set out in the “How to contact us” section of this Privacy Policy. If you find that your personal information collected, stored, used, or disclosed by us is wrong or incomplete, or if you encounter difficulties in exercising the above rights, you can contact us through the means described in this Privacy Policy “How to contact us”. Unless otherwise provided by laws and regulations or otherwise agreed in this Privacy Policy, we will respond to your request in a timely manner after verifying your identity.
2. Delete your personal information
In the following circumstances, you may request that we delete your personal information:
(1) If our handling of personal information violates laws and regulations;
(2) If we collect and use your personal information without your consent;
(3) If our handling of personal information violates our agreement with you;
(4) If you stop using our products or services, or you cancel your account.
(5) If we stop providing you with products or services.
If you intentionally delete it, you have the right to request or consult us about deleting your personal information through the contact information set out in Article 11 of this Privacy Policy (except where data anonymization has been done or as otherwise provided by laws and regulations). Unless otherwise agreed by laws and regulations or this Privacy Policy, we will respond promptly after verifying your identity.
Please note that when you successfully cancel your NewGaN Mall account, we will delete or anonymize your personal information. When you delete relevant information independently or with our assistance, we may not be able to delete the corresponding information from the system immediately due to applicable laws or security technology restrictions. We will securely store your personal information and guarantee that it will not be processed any further until it can be deleted or anonymized.
3. Withdrawal of agreed authorization
The functions in some of our products and/or services may require your authorization to be realized. Please understand that each service and function requires you to provide some necessary personal information to be completed. After you withdraw your consent or authorization, we will not be able to continue to provide you with the services and functions corresponding to the withdrawal of consent or authorization, and will no longer process your corresponding personal information.
You can change the scope of your authorization or withdraw your authorization by contacting us in the manner set out in Article 11 of this Privacy Policy. After that, we will no longer collect information related to these authorizations. However, after you change the scope of your authorization or withdraw your authorization, we may not be able to continue to provide you with the corresponding services. At the same time, you are aware and understand that we will continue to save or disclose the personal information provided before you change the scope of your authorization or withdraw your authorization in accordance with applicable laws and regulations and the provisions of this Privacy Policy.
4. Cancellation of account
You can apply to cancel your registered NewGaN Mall account in the NewGaN Mall. The route to cancel your account is: My – Settings – Cancel Account. Cancellation of your account may result in the erasure and irrecoverability of all your data and information; however, in certain circumstances (such as reasonably necessary to fulfill our legal obligations, resolve disputes, prevent fraud and abuse), we will retain anonymized information of non-identifiable individuals after cancellation.
Please note that your cancellation is irreversible. Once cancelled, we will no longer provide you with corresponding products and/or services. Your account information, order records, property rights and interests, etc. will be emptied together. Please be sure to operate cautiously and do a good job of data backup and rights liquidation before canceling your account to avoid unnecessary losses.
5. Obtain a copy of your personal information
You have the right to obtain a copy of your personal information, which you can provide by contacting us in the manner set out in Article 11 of this Privacy Policy. Subject to technical feasibility, such as data interface matching, we may also directly transfer a copy of your personal information to a third party designated by you upon your request.
6. Respond to your request for the above rights
In order to ensure security, we may require you to provide a written request when you exercise the above rights. After verifying your identity, we will process your request. In principle, we do not charge a fee for your reasonable request, but we will charge a certain cost for repeated requests that exceed reasonable limits, depending on the situation. We may reject requests that are unwarranted and repetitive, require excessive technical means (for example, need to develop new systems or fundamentally change current practices), pose a risk to the legitimate rights and interests of others, or are very impractical (for example, involve backing up information stored on magnetic tapes).
7. Exceptions to respond to your request for rights
Despite the above agreement, according to laws and regulations, we may not be able to respond to your request under the following circumstances:
(1) related to our fulfillment of our obligations under laws and regulations;
(2) directly related to national security and national defense;
(3) Those directly related to public safety, public health, or major public interests.
(4) directly related to criminal investigation, prosecution, trial, and execution of judgments.
(5) We have sufficient evidence to demonstrate that you have subjective malice or abuse of rights.
(6) To safeguard your or other individuals’ life, property, and other major legitimate rights and interests, but it is difficult to obtain my consent.
(7) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations.
(8) Involving trade secrets.
Other third parties and their services
Our Services may contain links to and from third parties that are directly related to our business partners, advertisers and social media sites. In addition, our users may post links to third-party websites. If you follow a link to any website, please note that these third parties and their services have their own Privacy Policies and we are not responsible for or liable for their policies or websites. We strongly recommend that you read their Privacy Policies, Terms and Conditions of Use to understand how they collect, use and share personal information.
IX. Protection of minors
Our services are for adults only. Any minors participating in online activities should obtain the prior consent of their parents or guardians. We will protect the relevant information of minors in accordance with relevant national laws and regulations.
If we find that we have collected personal information from minors, we will try to delete the relevant data as soon as possible. In the case of collecting personal information from minors with the consent of parents or guardians to use our services, we will only use, share, transfer or disclose this information as permitted by laws and regulations, with the affirmative consent of parents or guardians or as necessary to protect minors.
If we find that we have collected personal information from minors without the prior consent of a verifiable parent or legal guardian, we will try to handle the relevant personal information appropriately as soon as possible.
Changes to this Privacy Policy
We may revise or update this Privacy Policy from time to time to reflect changes in our business, laws, regulations and regulatory compliance requirements. We will send an updated version through the website and remind you of the update of the relevant content through push messages, in-app letters, red dot prompts or other means before it takes effect. Please visit in time to understand the latest Privacy Policy.
For major changes, we will also provide more prominent notices (including for some services, we will send notifications via pop-up windows or emails explaining the specific changes to the Privacy Policy).
Material changes to this Privacy Policy include, but are not limited to:
1. Significant changes in the product and/or service model. Such as the purpose of processing personal information, the type of personal information processed, how personal information is used, etc.;
2. We have undergone major changes in ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.;
3. Changes in the main objects of personal information sharing, transfer, or public disclosure;
4. Significant changes in your rights to participate in the processing of personal information and in the way you exercise them.
5. When our responsible department, contact information, and complaint channels for handling personal information security change;
6. When the personal information security impact assessment report indicates that there is a high risk.
If you continue to use any of our services or visit relevant websites after the adjustment or change of the Privacy Policy, we consider that you have fully read, understood and accepted the revised Privacy Policy and are bound by it.
How to contact us
If you have any questions about this Privacy Policy, you can contact us at:
Email of the person in charge of personal information protection: privacy@newgan.com
Address: 1515K9, Building A, Xinghe Century, 3069 Caitian Road, Gangxia Community, Futian Street, Futian District, Shenzhen
We will review the issue as soon as possible and respond within 15 days. If we are unable to respond to your request, we will send you a notice within the time limit stipulated by law and explain the reason. If you are not satisfied with our response, especially if you believe that our personal information processing practices have damaged your legitimate rights and interests, you can also file a lawsuit with the People’s Court of Futian District, Shenzhen City, Guangdong Province.