Sinnet Privacy Policy for Amazon Web Services (Beijing Region)

Last Updated: February 28, 2024

The Amazon Web Services China (Beijing) Region is operated by Beijing Sinnet Technology Co., Ltd. (“Sinnet”, “we” or “us”). We operate and provide cloud services from data centers located in the People’s Republic of China (for the purpose of this Privacy Policy, excluding Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan, referred to below as “China”), and based on Amazon Web Services technologies of Amazon Connect Technology Services (Beijing) Co., Ltd., or its affiliates (collectively, “Technical Providers”). This Sinnet Privacy Policy for Amazon Web Services (Beijing Region) is referred to in the Sinnet Customer Agreement for Amazon Web Services (Beijing Region) (“Sinnet Customer Agreement”) available at www.amazonaws.cn (the “Amazon Web Services China Site”, previously called “AWS China Site”). All capitalized terms used in this Privacy Policy will have the meaning ascribed to them in the Sinnet Customer Agreement, unless otherwise defined in this Privacy Policy.

This Privacy Policy applies to the Amazon Web Services China Site, as well as applications, products, services, events, and experiences that we provide to you and reference this Privacy Policy (together, the “Offerings”).

This Privacy Policy does not apply to the “content” processed, stored, or hosted by our customers using the Offerings in connection with an account of Amazon Web Services China (Beijing) Region, including any personal information of their end users. This Privacy Policy also does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy policies.

BEFORE USING THE OFFERINGS, PLEASE ENSURE THAT YOU READ, THOROUGHLY UNDERSTAND, AND AGREE TO THIS PRIVACY POLICY. PLEASE PAY SPECIAL ATTENTION TO THE CLAUSES THAT USE CAPITLIZED LETTERS. PLEASE ALSO FOCUS YOUR ATTENTION TO CLAUSES PERTAINING TO SENSITIVE PERSONAL INFORMATION, WHICH ARE UNDERLINED.

1. How We Collect and Use Personal Information

1.1. How We Collect Personal Information

In the course of providing the Offerings to you, we may collect your personal information in the following ways.

  • INFORMATION YOU GIVE US: WE COLLECT ANY INFORMATION YOU PROVIDE IN RELATION TO THE OFFERINGS. IF THE INFORMATION YOU PROVIDE INCLUDES PERSONAL INFORMATION OF THIRD PARTIES, BEFORE PROVIDING SUCH INFORMATION TO US, YOU REPRESENT AND WARRANT THAT THE INFORMATION YOU PROVIDE TO US IS LEGITIMATELY AND COMPLIANTLY SOURCED, INCLUDING BUT NOT LIMITED TO OBTAINING NECESSARY CONSENT TO PROCESS SUCH PERSONAL INFORMATION, (a) to share the personal information of third parties with us and our entrusted processors, and (b) in accordance with our Privacy Policy, we and our entrusted processors can process and use the personal information of these third parties. Upon reasonable request, you will provide evidence of such consent or other compliance documentation and assist us in responding to any inquiries regarding third-party personal information.         
  • AUTOMATIC INFORMATION: WE AUTOMATICALLY COLLECT CERTAIN TYPES OF INFORMATION WHEN YOU INTERACT WITH THE OFFERINGS.
  • INFORMATION FROM OTHER SOURCES: WE MIGHT COLLECT INFORMATION ABOUT YOU FROM OTHER SOURCES, INCLUDING SERVICE PROVIDERS, PARTNERS, AND PUBLICLY AVAILABLE SOURCES.

1.2. How We Use Personal Information

In the course of providing the Offerings to you, we may use your personal information in the following ways:

  • To provide you with the essential functions of the Offerings, you are required to authorize us to collect and use necessary information.
  • To provide you with supplementary functions of the Offerings, you can choose to authorize us to collect and use certain information. If you choose not to provide such information, you may not be able to use certain supplementary functions or achieve the intended full functionality of the Offerings, but it will not affect your use of the essential functions of the Offerings.

Please refer to the specific sections below for details of the personal information processed for each function.

1.2.1. To Provide You with the Essential Functions of the Offerings

1.2.1.1. To Help You Become a User of the Offerings

We use your personal information to provide and deliver the Offerings and process transactions related to the Offerings, including registrations, subscriptions, purchases and payments.

To help you register an account of the Offerings, we need to process the following information you have provided:

  • your name, email address, physical address, phone number, and other similar contact information;
  • usernames, aliases, roles, and other authentication and security credential information (passwords);
  • information about your organization and your contacts, such as colleagues or people within your organization, including the name, email address, phone number, ID type, and ID number of the company's network security personnel.

If you refuse to provide the above information, you will not be able to register an account of the Offerings and you can only use browsing and searching services. YOU UNDERSTAND AND ACKNOWLEDGE THAT THE ID INFORMATION MENTIONED ABOVE IS SENSITIVE PERSONAL INFORMATION. WE COLLECT AND USE SUCH INFORMATION TO ASSIST YOU IN COMPLETING THE REGISTRATION PROCESS AND TO FULFILL THE NECESSARY REQUIREMENTS FOR NETWORK SECURITY PROTECTION AS STIPULATED BY THE LAWS AND REGULATIONS OF CHINA.

When you subscribe to or purchase the Offerings, we need to process the following information to assist you in completing the order payment: your organization's payment information (including credit card or bank account information), payment settings (such as payment instrument information and billing preferences), subscription, purchase, usage, billing, and payment history.

1.2.1.2. To Provide You with Secure and Reliable Offerings

To enhance the security of your use of the Offerings, perform identity verification, and prevent fraud or security incidents, we may collect and use your account information, computer and device information (such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting), the location of your device or computer, network and connection information (such as the Internet protocol (IP) address used to connect your computer or other device to the Internet and information about your Internet service provider), authentication and security credential information, content interaction information (such as content downloads, streams, and playback details, including duration and number of simultaneous streams and downloads), the offerings metrics (such as offering usage, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs), log information (such as the full uniform resource locators (URL) clickstream to, through, and from our website (including date and time) and the offerings, content you viewed or searched for, page response times, download errors, and page interaction information (such as scrolling, clicks, and mouse-overs)), email addresses and phone numbers used to contact us; and identifiers and information contained in cookies (see our Cookie Notice).

YOU UNDERSTAND AND ACKNOWLEDGE THAT THE ABOVE INFORMATION CONTAINS YOUR SENSITIVE PERSONAL INFORMATION. WE MAY COLLECT AND USE SUCH SENSITIVE INFORMATION TO ASSESS YOUR ACCOUNT AND TRANSACTION RISKS, PERFORM IDENTITY VERIFICATION, DETECT AND PREVENT SECURITY INCIDENTS, AND TAKE NECESSARY RECORDING, AUDITING, ANALYZING, AND HANDLING MEASURES IN ACCORDANCE WITH THE LAW. IF YOU REFUSE TO PROVIDE US WITH SUCH INFORMATION, WE WILL NOT BE ABLE TO PROVIDE YOU WITH THE OFFERINGS.

1.2.2. To Provide You with Supplementary Functions of the Offerings

1.2.2.1. To Provide ICP Recordal Services

In order to ensure that you comply with the relevant provisions of Chinese laws and regulations, we use your personal information to provide you with ICP recordal services based on your registration and application. To help you complete your ICP recordal, you need to provide us with your email address, phone number, authentication and security credential information (passwords), and information about your organization and your contacts, such as colleagues or person in charge within your organization, including the name, job title, email address, phone number, IDs (e.g., ID card, passport) and photo of the company's person in charge.

YOU UNDERSTAND AND ACKNOWLEDGE THAT THE ABOVE INFORMATION CONTAINS YOUR SENSITIVE PERSONAL INFORMATION. WE COLLECT AND USE SUCH SENSITIVE INFORMATION AS IS NECESSARY TO PROVIDE WITH YOU THE ICP RECORDAL SERVICE. IF YOU REFUSE TO PROVIDE US WITH SUCH INFORMATION, WE WILL NOT BE ABLE TO PROVIDE YOU WITH THE OFFERINGS, AND YOU CAN ONLY USE BROWSING AND SEARCHING SERVICES.

1.2.2.2. To Provide Customer Service Consultation

We use your personal information to communicate with you in relation to the Offerings via different channels (e.g., by phone, email, chat) and to respond to your requests. For example, you may communicate with us by phone, email, or otherwise; you may also interact or communicate with us to request customer support. To this end, we will collect and process personal information associated with your inquiry, depending on your specific question, relevant personal information may include: your account information; contact information; information about your location; content of feedback, testimonials, inquiries, support tickets, and any phone conversations, chat sessions and emails with or to us; activity-related information; and other necessary personal information provided with your consent or proactively provided by you.

YOU UNDERSTAND AND ACKNOWLEDGE THAT THE ABOVE INFORMATION CONTAINS YOUR SENSITIVE PERSONAL INFORMATION. WE COLLECT AND USE SUCH SENSITIVE INFORMATION TO RECORD OUR COMMUNICATIONS WITH YOU, SO AS TO PROVIDE YOU WITH MORE TIMELY AND ACCURATE CONSULTING SERVICES. IF YOU REFUSE TO PROVIDE US WITH THIS INFORMATION, WE WILL NOT BE ABLE TO PROVIDE YOU WITH CORRESPONDING CUSTOMER SERVICE CONSULTATION, BUT IT WILL NOT AFFECT THE ESSENTIAL FUNCTIONS OF THE OFFERINGS.

1.2.2.3. To Provide Recommendations for the Offerings

We use your name, username, email address, phone number and billing information to recommend the Offerings that might be of interest to you, or improve your user experience with the Offerings.

1.2.2.4. To Market and Promote the Offerings

We may use your name, image, voice, and other identifiers that are personal to you when you attend an event organized by us and/or our partners, or use certain Offerings, in order to market and promote our Offerings.

1.2.2.5. To Measure, Fix, and Support the Offerings

We use your following personal information to measure use of, analyze performance of, fix errors in, provide support for the Offerings.

In order to achieve such purposes, we will collect and process:

  • your account information;
  • a questionnaire, a support ticket, or other information request forms submitted by you;
  • content of feedback, testimonials, inquiries, support tickets, and any phone conversations, chat sessions and emails with or to us;
  • user information statistics; and
  • other necessary personal information with your consent or voluntarily provided by you.

YOU UNDERSTAND AND ACKNOWLEDGE THAT THE ABOVE INFORMATION CONTAINS YOUR SENSITIVE PERSONAL INFORMATION. IF YOU FAIL TO PROVIDE THIS INFORMATION, IT MAY AFFECT OUR ABILITY TO PROVIDE YOU WITH MORE CONVENIENT AND ACCURATE OFFERINGS AND TO FIX ERRORS IN THE OFFERINGS, BUT IT WILL NOT AFFECT THE ESSENTIAL FUNCTIONS OF THE OFFERINGS.

1.3. Other Uses

We will collect and use your personal information based on the purposes stated in the How We Collect and Use Personal Information section of this Privacy Policy, and we may also use data to improve and develop the Offerings to the extent permitted by laws and regulations. We will ask for your consent to use your personal information for a specific purpose that we communicate to you. When we intend to use the information collected for a specific purpose for other purposes, unless there are exceptions stated in this Privacy Policy, we will obtain your consent in advance.

1.4. Exceptions to Prior Authorization and Consent

You are fully aware that we do not need your authorization or consent to collect and use your relevant personal information in the following situations:

  • directly related to national security or national defense;
  • in connection with the fulfilment of our obligations under laws and regulations;
  • necessary to enter into and perform an agreement or other written document to which you are a party;
  • directly related to public security, public health or material public interests, for example: when it is necessary to respond to public health emergencies, or to protect the life, health and property safety of you and others in an emergency;
  • directly related to criminal investigations, prosecutions, trials or execution of court decisions;
  • for the purpose of safeguarding the life, property or other significant lawful rights and interests of you or other individuals, and it is difficult to obtain consent from you;
  • processing to a reasonable extent the personal information that you elect to disclose to the public in accordance with the provisions of laws and regulations;
  • processing to a reasonable extent your personal information collected from legally and publicly disclosed information (such as lawful news reports and government information disclosure), in accordance with the provisions of laws and regulations;
  • necessary for maintaining the safety and stable operation of software and related services, such as detecting and addressing malfunctions in software and related service;
  • other situations stipulated by laws and regulations.

PLEASE BE FULLY AWARE THAT IF WE USE TECHNICAL MEANS TO PROCESS PERSONAL INFORMATION SO THAT THE SUBJECT OF PERSONAL INFORMATION CANNOT BE IDENTIFIED, AND THE INFORMATION CANNOT BE RESTORED AFTER PROCESSING, THEN THE USE OF SUCH PROCESSED DATA DOES NOT NEED TO NOTIFY YOU AND OBTAIN YOUR CONSENT.

2. Cookies

To enable our systems to recognize your browser or device and to provide the Offerings, we use Cookies and other identifiers. You can manage browser Cookies through your browser settings (e.g., accept and install Cookies, or remove Cookies). The Help section on most browsers and devices will provide you with instructions on how to prevent your browser or device from accepting new Cookies, how to have your browser notify you when you receive new Cookies, or how to completely disable Cookies. However, if you block or reject some of our Cookies through your browser’s settings, you might not be able to use certain Offerings that require you to sign in to an account and some features and services may not work. For more information about cookies and how we use them, please read our Cookie Notice.

3. How We Entrust Processing, and Share, Transfer, and Publicly Disclose Your Personal Information

Information about our customers is an important part of our business and we are not in the business of selling our customers’ personal information to others. We share the personal information as described below, or pursuant to applicable laws and regulations and with affiliates we control that either are subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy. The specific rules we entrust to process, share, transfer, and publicly disclose your personal information are as follows.

3.1. Entrusted Processing to Third Parties

Certain functions of the Offerings may be provided by the following types of third-party service providers:

  • Technical Providers and Business Partners: To optimize performance of the Offerings, we work closely with the Technical Providers and business partners to operate and provide the Offerings based on Amazon Web Services technologies, and we may share the personal information with the Technical Providers and business partners for technical and customer support purposes. The Technical Providers and business partners only have access to personal information needed to perform their functions and may not use it for other purposes.
  • Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf, which include: delivering Amazon Web Services hardware, sending communications, processing payments, assessing credit and compliance risks, analyzing data, providing marketing and sales assistance (including advertising and event management), conducting customer relationship management, providing training, and other professional services. These third-party service providers only have access to personal information needed to perform their functions, and may not use it for other purposes.

In the event that we entrust any companies, organizations, or individuals to process your personal information, we will enter into agreements with them to specify the purpose, duration, method of processing, types of personal information, protective measures as well as the rights and obligations of the parties, and will supervise their personal information processing activities to the extent permitted by law and consistent with this Privacy Policy. Furthermore, they must process that information in accordance with this Privacy Policy and as permitted by applicable laws of China.

3.2. Sharing Your Personal Information

We will not share your personal information with other organizations and individuals, except in the following circumstances:

  • Sharing with Your Explicit Consent: We may share your personal information with other parties after obtaining your explicit consent.
  • Sharing Required for the Fulfilment of Our Legal Obligations: We may share your personal information with other parties as required by laws and regulations, litigation, or requests of governmental or regulatory authorities.
  • Sharing When It Is Necessary to Conclude and Perform a Contract with You as a Party: We may share your personal information with other parties when it is necessary to conclude and perform a contract with you as a Party (e.g., you can order services, software, and content provided by third parties for use on or through the Offerings, and we will provide those third parties information to facilitate your subscription, purchases, or support). You can tell when a third party is involved in your transactions, and we share your contact person’s name, physical address, and phone number with that third party. 
  • Sharing with Our Affiliates: We may share your personal information with our affiliates. We will only share necessary personal information, and such sharing is subject to this Privacy Policy. 
  • Sharing to Protect Us and Others: We may share your account and other personal information when we believe release is appropriate to (i) comply with the law, (ii) enforce or apply our terms and other agreements, or (iii) protect the rights, property, or security, of us, the Technology Providers, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.

3.3. Transferring Your Personal Information

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

  • after obtaining your consent of transfer, we may transfer your personal information to the relevant party to the extent that you have consented; or
  • transfer of personal information is due to merger, division, dissolution and declaration of bankruptcy. We will fulfill corresponding duties and obligations in accordance with applicable laws and regulations.

3.4. Public Disclosure

We will not publicly disclose your personal information without your consent unless required by applicable laws.

4. Storage Location of Personal Information

Your personal information will be stored in in China. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by applicable laws of China.

5. How We Protect Your Personal Information

Security is our highest priority. We design our systems with your security and privacy in mind.

  • We maintain a wide variety of compliance programs that validate our security controls. Click here to learn more about our compliance programs.
  • We protect the security of your information during transmission to or from Amazon Web Services China Site, applications, products, or services by using encryption protocols and software.
  • We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal information. Our security procedures mean that we may request proof of identity before we disclose personal information to you.

 6. Third Parties Sites and Services

The Offerings may include third-party advertising or content, or links to other websites and applications. These third parties may collect information about you when you interact with their advertising, content, or services. The processing and protection of your personal information by those third parties shall be subject to the privacy policies or similar documents of such parties. We are not responsible for the practices of these companies.

7. Your Rights

According to the laws and regulations of the People's Republic of China, you are entitled to the following rights in relation to your personal information:

7.1. Accessing, Correcting, and Supplementing Your Personal Information

You can view, update, and delete relevant information about your account and your interactions with the Offerings (such as the Amazon Web Services Management Console (including the My Account, Billing Dashboard, Bills, Payment Methods, Payment History, Preferences and Fapiao Management pages)). If you cannot access or update your information yourself, you can always contact us for assistance.

You have choices about the collection and use of your personal information. Many of the Offerings include settings that provide you with options as to how your information is being used. You can choose not to provide certain information, but then you might not be able to take advantage of certain Offerings.

  • Account Information: If you want to add, update, or delete information related to your account, please go to the Management Console. When you update or delete any information, we usually keep a copy of the prior version for our records.
  • Communications: If you do not want to receive promotional messages from us, please unsubscribe by following unsubscribe guidance in the communications we have sent you. If you do not want to receive in-app notifications from us, please adjust your notification settings in the app or your device.
  • Browser and Devices: The Help feature on most browsers and devices will provide you with instructions on how to prevent your browser or device from accepting new Cookies, how to have your browser notify you when you receive new Cookies, or how to completely disable Cookies.

7.2. Deleting Your Personal Information

You can request the deletion of the personal information that is no longer necessary for the processing purposes, processed based on withdrawn consent, associated with discontinued Offerings or has expired retention periods, or where processing activities do not comply with applicable legal requirements, through the methods provided in this Privacy Policy.

7.3. Responding to Your Requests

  • Subject to applicable laws, you can access and manage your personal information in the above-mentioned ways. Please note that if you interact with the Offerings on behalf of or through your organization or your organization has shared your personal information with us, you need to contact us through your organization about your rights relating to your personal information.
  • We usually charge no fees with respect to your reasonable requests. However, we may charge a certain amount of fees with respect to repeated, voluminous or unreasonable requests. We may decline a request that is gratuitously repetitive or technically demanding (for example, if the development of a new system or a fundamental change in existing practice is required), may put others' lawful interests at risk, or is highly impractical.

7.4. Exceptions to Responding to Your Requests

We may not be able to respond to your requests if:

  • The request is related to our performance of any statutory obligations;
  • The request is directly related to national security or the security of national defense;
  • The request is directly related to public security, public health or material public interest;
  • The request is directly related to criminal investigation, prosecution, trial and enforcement of judgment;
  • There is reasonable evidence showing that you have demonstrated subjective malice or abused your rights;
  • The request is related to the protection of your or other individuals' life, property and other significant lawful rights and interests, and it is difficult to obtain the consent of the individual whose life, property and other significant lawful rights and interests are at risk;
  • Responding to your request will cause serious damages to the lawful rights and interests of you or other individuals or organization; or
  • The request involves trade secrets.

7.5. Exercising Your Rights

You may exercise any of your rights set forth in this section by contacting us in accordance with the section below titled "Contact, Notices, and Revisions."

8. Special Agreements on Children’s Personal Information

IF YOU ARE UNDER 18, YOU MAY ONLY USE THE OFFERINGS WITH THE INVOLVEMENT OF A PARENT OR OTHER LEGAL GUARDIAN. IF YOU’RE UNDER 14, THE APPLICABLE LAWS OF CHINA CONSIDER YOU AS A CHILD, AND YOU MAY ONLY PROVIDE YOUR PERSONAL INFORMATION WITH THE CONSENT OF YOUR PARENT OR OTHER LEGAL GUARDIAN. WE WILL NOT KNOWINGLY COLLECT AND USE A CHILD'S PERSONAL INFORMATION EXCEPT TO THE EXTENT PERMITTED BY LAW, WITH THE CONSENT OF A CHILD’S PARENT OR OTHER LEGAL GUARDIAN, OR AS NECESSARY FOR THE PROTECTION OF THE CHILD.

9. Retention of Personal Information

WE WILL RETAIN YOUR PERSONAL INFORMATION FOR AS LONG AS IT IS REQUIRED IN ORDER TO FULFILL THE RELEVANT PURPOSES DESCRIBED IN THIS PRIVACY POLICY, AS MAY BE REQUIRED BY LAW, OR AS OTHERWISE COMMUNICATED TO YOU. WE WILL DELETE YOUR PERSONAL INFORMATION IN ACCORDANCE WITH APPLICABLE LAWS.

10. Contacts, Notices, and Revisions

If you have any concern about privacy at Sinnet, please contact us with a thorough description, and we will try to deliver our response and/or reasonable clarification to you within 15 working days, or other period as required by applicable laws and regulations, following receipt of your inquiry. You may also contact us at the addresses below:

Beijing Sinnet Technology Co., Ltd.2/F, Tower A, East Gate Plaza, No.9 Dongzhongjie Street, Dongcheng District, Beijing P.R. China, 100027

If you interact with the Offerings on behalf of or through your organization, then your personal information may also be subject to your organization’s privacy practices, and you should direct privacy inquiries to your organization.

Our business changes constantly, and our Privacy Policy may also change. You should check our website frequently to see recent changes. You can see the date on which the latest version of this Privacy Policy was posted. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of personal information collected in the past without informing affected customers and giving them a choice.