Privacy Policy
Date of publication:2024.3.7
Date of effect:2024.3.7
Shenzhen Jingtai Technology Co., Ltd. (hereinafter called "We" or "XtalPi") is the operator and personal information processor of XtalPi website (https://xtalpi.com/). We are fully aware of the importance of personal information to the user (hereinafter called "you") and as such we respect and utilize all efforts to protect it. We have prepared this Privacy Policy (hereinafter called “Policy”), which covers how we collect, use, disclose, protect, transfer and store your personal information when you visit and use XtalPi website or otherwise interact with us.
Your understanding of the content of the Policy is extremely important for you to exercise your rights and protect your personal information. We hope that before your use of our services or provision of your personal information to us, you thoroughly read and confirm that you fully understand details of the Policy and make the choice that you deem appropriate based on the guidelines in the Policy.
You warrant that at the time you begin to use our services you have attained 18 years of age. You will need your guardian's consent with respect to the use of our services if you are under the age of 18, and you will use our services with the guidance of the guardian.
The Policy will help you to understand the following:
I. Definitions and scope of application
II. How we collect, use and store your personal information
III. How we use cookies and similar technologies
IV. How we handle outsourced processing, sharing and disclosure of your personal information
V. How we transfer your personal information overseas
VI. How we protect your personal information
VII. Your rights
VIII. How we process personal information of minors
IX. Updating of privacy policy
X. How to contact us
I.Definitions and scope of application
(1)Basic definitions
1.Personal information: Personal information refers to all types of information pertaining to an identified or identifiable natural person whether recorded electronically or in other modes. It does not include information of individuals processed anonymously.
2.Sensitive personal information: Sensitive personal information refers to information that, if leaked or illegally used, can easily lead to infringement on an individual's dignity or harm to the individual's personal or property safety. We will indicate sensitive personal information prominently in the Policy, and separately draw your attention to such information before collecting it.
3.Services: Services insofar as the Policy is concerned include relevant services provided to you through XtalPi website and other interactive channels, and other third parties (e.g., third-party recruitment platform). They do not include products and/or services for which we already have personal information processing rules in place.
(2)Exceptions
1.Our services may contain links to third-party websites, products and services. All links to such third-party websites, products and services are provided solely for your convenience. We have no control over such third parties and their contents, and are unable to provide any express or implied warranty with respect to them. Neither can such links be construed as recommendation or authorization by us with respect to their contents. Such third parties are subject to their personal information protection rules. For the above reasons you would need to separately read the personal information processing rules of such third parties before providing your personal information to them.
2.The Policy does not apply to products and/or services for which we already have personal information processing rules in place. With respect to personal information collected by us pursuant to the aforesaid products and/or services, you would need to read the personal information processing rules for such products and/or services.
II.How we collect, use and store your personal information
(1)Overview
1.We will collect and use, personal information that you have provided or generated during your use of services or personal information obtained from third parties in accordance with laws and regulations, properly, lawfully, where it is necessary and with integrity, for unequivocal and reasonable objectives described in the Policy and in such a way that has minimal impact on your rights. Insofar as we need to use your personal information for purposes or objectives not specified in the Policy or there are changes to its processing method and type, we will inform you in reasonable manner and obtain fresh consent from you with respect to our handling of such information.
2.XtalPi website is a platform used by us for publication of information and product details to members of the public, including corporate news, promotion of XtalPi products and/or services, collection of loopholes, display of recruitment information and corporate contact, etc. In order for us to provide browsing services to you, we will collect and use necessary information according to laws and regulations. If you refuse to provide such information you may not be able to use our services normally.
3.With respect to personal information provided by users in different territories, we will comply with local laws and regulations pertaining to the protection of such personal information and undertake collection, use, storage and protection accordingly.
4.In order for us to provide services other than browsing, you can elect to consent or not consent to our collection and use of your personal information. If you do not grant your consent, you will only be unable to use the services corresponding to such personal information normally; browsing or use by you of other services of ours will not be affected.
(2)We will collect and use the following types of personal information for the following objectives and in the following ways:
1.Browsing of XtalPi website
When you browse XtalPi website, we will, in order to display our products and/or services, use Google Analytics to collect information on your device's service log, including time of access, territory of access, access device, access browser, access system, behavior flow and staying time, etc.
2.Contacting us
If you are interested in our products/services, or want to submit to us information on product loopholes, complaint/suggestion or business inquiry and need to contact us, we may collect your name, the business of your interest, type of your current business, your company/unit, your department/position, the province or city in which you are working, your mobile phone number, your work e-mail address, the type of personnel you would expect to contact, your desired communication means, and your specific needs/remarks. Of these, your name, the business of your interest, type of your current business, your company/unit, your department/position, the province or city in which you are working, your mobile phone number, your work e-mail address, the type of personnel you would expect to contact and your desired communication means are compulsory information, and your specific needs/remarks are optional information. Our collection of compulsory information is in order for us to understand your needs and get in touch with you. Optional information enables us to provide you with the results of our action, proposal and response in a better and faster way. If you do not consent to providing us with the aforesaid information, it may result in us being unable to communicate with you and respond to your needs.
3.Business partnership management
If you or an organization that you belong to are our business partners, we may collect your name, contact information, and delivery address to establish and conduct a business cooperation with you or your organization when you or your organization interact with us.
4.Recruitment
You can view details of the job positions involved in our recruitment under "Community Recruitment" and "Campus Recruitment" in the "Contact Us" page on our website. The page is actually linked to third-party recruitment platforms. If you wish to join us, you can send in your resume through an account registered with the third-party recruitment platform. We will obtain your resume which contains your personal information from such third-party recruitment platform in order to understand your personal background, contact you and complete the processes relating to our recruitment. Your resume may contain sensitive personal information, but if you do not offer a resume which contains your personal information you may not be able to participate in our recruitment activities. In these circumstances, please read thoroughly the personal information processing rules and/or service agreement of such third parties before using their services and providing your personal information to them.
(3)How we use your personal information
You agree and authorize us to retain information collected by us and use it for the following purposes:
1.Provision of services pursuant to the Policy;
2.For purposes required under legal, regulatory, order of the court or other legal proceedings, or by order of government authorities;
3.Other situations pursuant to your authorization or applicable law.
If we intend to use your personal information for any purpose other than that stated in the Policy or collect other personal information from you, we will seek your prior consent, and insofar as we have not obtained your consent, we will not use your personal information for such purpose or collect any additional personal information from you.
(4)How we store your personal information
We will store your personal information collected in China in accordance with applicable Chinese laws and regulations, and some of your personal information may also be stored outside of China or transferred outside of China to fulfill the purposes set forth in this Policy. (Please see the section below entitled "How we transfer your personal information overseas" for more information)
With respect to your personal information collected or processed by us, we will retain such information for a duration such as to meet the purpose of collection in accordance with any legal, accounting or reporting requirement. Save in the following circumstances we will delete or render anonymous your personal information, if you withdraw your consent, or request that your personal information be deleted, or the duration for retention of our personal information has expired:
• Compliance with laws and regulations relating to retention of information;
• Pursuant to financial, audit or dispute resolution requirements for reasonable extension of duration of retention;
• Insofar as it is allowed within the law, to achieve the purpose described in the Policy.
(5)Lawful reasons other than your consent
Pursuant to relevant laws and regulations we can, under the following circumstances, collect and use certain necessary personal information without first obtaining your authorization or consent with respect thereto:
1.As required for the purpose of formation or fulfillment of contact as a contractual party;
2.As required for the fulfillment of our statutory responsibility or obligation;
3.As required for the protection of life, health and property safety in response to sudden public health events or emergencies;
4.Processing personal information published by an individual on its own accord or already lawfully published as provided in the "Personal Information Protection Law of the People's Republic of China" insofar as such processing is within a reasonable scope;
5.Other circumstances prescribed by laws or administrative regulations.
III.How we use cookies and similar technologies
In order to ensure normal operation of our website, an improved viewing experience for you, recommendation of contents that may be of interest to you as well as those that you may wish to store and contents in forms that you may be required to fill in more than once, we will use cookies on your desktop or mobile devices. Furthermore, we will use programs from third-party service providers including Google Analytics and cookies from Baidu Statistics in order to conduct essential statistical analysis. Cookies are small text files saved in your desktop or mobile devices when you browse websites. They usually contain symbols, website name and certain numerals and alphabets so as to distinguish your desktop or mobile devices from other devices.
IV.How we handle outsourced processing, sharing and disclosure of your personal information
(1)Outsourced processing
In order for us to provide our services or achieve the purposes with respect to the use of the aforesaid information, we may need to outsource to third-party service providers for them to process your personal information. For example, with regard to recruitment, we will outsource to third-party service providers with respect to the collection and processing of your personal information including application and resume.
With regard to companies, organizations or individuals to which we have outsourced processing of personal information, we will take reasonable steps to review their ability to protect personal information, sign strict confidentiality agreements or legal documents with them, state clearly the objectives, term, processing means, types of personal information, protection measures and each party's rights and obligations, and require them to strictly abide by the Policy as well as take adequate organizational or technical measures to protect your privacy and personal information. When the outsourced parties no longer provide any service to you, we will delete or notify such parties to delete your personal information.
(2)Sharing
Sharing refers to us providing personal information to other personal information controlling parties, with each of us having independent controlling right over such personal information. In general we will not share your personal information with outside parties, except under the following circumstances:
1.Sharing upon obtaining individual consent: Once we have obtained your individual consent or upon your initiation, we will share information with third party appointed by you within the scope of your authorization;
2.Sharing in statutorily-provided situations: We may, as required by laws and regulations or pursuant to litigation or dispute resolution, or upon administrative or judicial orders, share your personal information.
(3)Assignment
We will not assign your personal information to any company, organization or individual, except under the following circumstances:
1.Assignment upon obtaining express consent: We will assign your personal information to other parties after obtaining your express consent;
2.Insofar as assignment of personal information is involved during merger, acquisition or liquidation of company, we will require the company or organization which acquires your personal information to continue to be bound by the terms of the Policy, failing which we will require such company or organization to obtain your authorization or consent with respect to your personal information.
(4)Public disclosure
We will publicly disclose your personal information only under the following circumstances:
1.After we have obtained your express consent;
2.Disclosure as required by law: We may publicly disclose your personal information pursuant to the law, legal proceedings, litigation or compulsory order of government authorities.
V.How we transfer your personal information overseas
As a company that operates in multiple locations around the world, our daily business and cooperation with you or your organization may involve working with colleagues and service providers in different countries. In order to fulfill the purposes described in this Policy, we may transfer your personal information outside of China in the following circumstances, after we have fulfilled the requirements of applicable Chinese laws and regulations. We will require the overseas recipient to protect your personal information with appropriate protective measures (which shall be at least equivalent to the level of protection of personal information required by Chinese laws) and to process and safeguard it in accordance with this Policy.
In the business partnership management scenario, in order to realize the unified management and maintenance of XtalPi's global customers and their contacts, we need to transfer the basic personal information (such as name, contact information, and delivery address) of our business partner contacts to XtalPi Inc. located in the United States (the contact information and the exercising channel is ITSecurity@Xtalpi.com), and the overseas recipient will collect, use and store your personal information.
VI.How we protect your personal information
XtalPi has obtained ISO27001 Information Security Management certification in 2019. In order to ensure security of your information, we will adopt reasonable and necessary measures insofar as they are permitted under current technological standards, to protect your information. Measures such as physical protection, security technology and management regulations are employed to reduce the risk of misplacement, erroneous use, unauthorized perusal, disclosure and change of information. They include without limitation SSL encrypted transmission, firewall and encrypted storage, control of physical viewing and control of information-viewing authorization. Notwithstanding that we have prudently adopted reasonable measures, we cannot guarantee complete security of your personal information, given the complexities of existing Internet environment.
We are equipped with network security emergency response plans to enable us to promptly deal with security risks such as system loopholes, computer virus, online attack and network intrusion. Once an event poses a threat to our network security we will immediately activate our emergency response plan, adopt relevant remedial measures and notify relevant authorities or individuals in accordance with laws and regulations.
VII.Your rights
Under the law you enjoy the following rights with respect to your personal information. We will fully protect your ability to exercise your rights. Based on our current service capability, you can follow the guidelines below:
1.Checkingand duplicating your personal information, or transfer your personal information to designated third parties: If you need to check or obtain a copy of your personal information collected by us, you can contact us by sending an e-mail to this address: contact@xtalpi.com. After we have verified your identity, we will, subject to the relevant laws and regulations and insofar as existing technology allows, provide you with a duplicate copy of your personal information. If you wish to transfer your personal information to a designated individual, we will, subject to qualification requirements stipulated by state network communication authority, provide you with the transfer path.
2.Correcting and supplementing your personal information: If you discover errors in your personal information, you can contact us by e-mail (contact@xtalpi.com) to request for correction or supplemental information.
3.Deleting your personal information: When you no longer need to use our services and want to delete your personal information, or you have found that we have collected, used or shared your personal information with others in violation of laws, regulations or agreement with you, you can demand that we delete such information by way of e-mail to contact@xtalpi.com, informing us of your need and scope of information to be deleted. We will carry out corresponding action. Insofar as the retention period stipulated by the law or administrative regulations has not expired, or deletion of your personal information is technically unachievable, we will stop processing such information save with storage or other necessary security protection measures.
4.Withdrawal of your consent: You can grant or withdraw your authorization or consent at any time. In the case of withdrawal of consent, you can send an e-mail to contact@xtalpi.com, informing us of your decision to withdraw your consent and scope of such withdrawal. Please understand however, that certain service functions need some basic personal information in order for them to be completed. Once you have withdrawn your consent or authorization, we will no longer be able to continue providing you such services. Neither can we process your personal information. In any case withdrawal by you of your consent will not affect previous processing of your personal information pursuant to your consent.
5.Obtaining our explanations with respect to the Policy or to exercise other rights under applicable data protection laws: You can send an e-mail to contact@xtalpi.com to request that we explain the Policy to you or to request the exercise of other rights under applicable data protection laws.
6.Responding to your request: We will put in place convenient channels and response mechanism to accept and process your request. In order to ensure security, we will need to verify your identity before we can process your request. We will complete verification of identity and respond within 15 working days of receipt of your application. If your request is relatively complex or requires numerous technical means we will complete our response within the time period stipulated by laws and regulations. In principle we will not levy any charge for processing reasonable requests. However, if your requests exceed reasonable limit or require numerous technical means, we will levy charges as the situation merits.
VIII.How we process personal information of minors
1.Our services are mainly targeted at adults with certain degree of professional knowledge and background. As such we will not take active steps to collect personal information of minors. For minors whose guardians have consented to our collection of personal information, we will use, share, assign or disclose such information only insofar as they are allowed by the law, with the consent of the guardians or it is necessary to protect minors.
2.If there are factual evidence of minors registering with us and use our services without obtaining the consent of their guardians, we will delete their personal information as soon as we are informed by such guardians with requests to delete such information.
IX.Updating of privacy policy
Our Privacy Policy may be updated according to changes in laws and regulations and our business situation.
1.We will not without your express consent restrict your rights enjoyed under the Policy. We will announce any change to the Policy in the relevant webpage ("XtalPi Home Page-Bottom-Privacy Policy").
2.We will also notify you any change to individual processing personal information, processing objective, processing means, type of personal information processed, retention period and rights of data entity.
X.How to contact us
If you have any question with respect to the Policy or our collection, use, disclosure, sharing or storage of your personal information, you can contact us using the information below:
Shenzhen Jingtai Technology Co., Ltd.
E-mail: contact@xtalpi.com
Address: 3rd Floor, 2nd phase of the International Biomedical Industrial Park, No. 2, Hongliu Road, Futian District, Shenzhen
If you are not satisfied with our reply, and in particular you are of the view that the manner in which we process your personal information is detrimental to your lawful interest, you can also seek solutions through the following external means, i.e., by seeking resolution through litigation at a court having jurisdiction over Shenzhen Jingtai Technology Co., Ltd.