Sinnet Privacy Policy for Amazon Web Services (Beijing Region)

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 describes how we collect and use your personal information in relation to Amazon Web Services China Site, applications, products, services, events, and experiences that 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.

• Personal Information We Collect
• How We Use Personal Information
• Cookies
• How We Share Personal Information
• Location of Personal Information
• How We Secure Information
• Internet Advertising and Third Parties
• Access and Choice
• Children’s Personal Information
• Retention of Personal Information
• Contacts, Notices, and Revisions
• Examples of Information Collected
  

• INFORMATION YOU GIVE US: WE COLLECT ANY INFORMATION YOU PROVIDE IN RELATION TO THE OFFERINGS. SEE EXAMPLES OF INFORMATION YOU GIVE US BELOW.

• AUTOMATIC INFORMATION: WE AUTOMATICALLY COLLECT CERTAIN TYPES OF INFORMATION WHEN YOU INTERACT WITH THE OFFERINGS. SEE EXAMPLES OF INFORMATION WE COLLECT AUTOMATICALLY BELOW.

• INFORMATION FROM OTHER SOURCES: WE MIGHT COLLECT INFORMATION ABOUT YOU FROM OTHER SOURCES, INCLUDING SERVICE PROVIDERS, PARTNERS, AND PUBLICLY AVAILABLE SOURCES. SEE EXAMPLES OF INFORMATION WE COLLECT FROM OTHER SOURCES BELOW.
  

We use your personal information to operate, provide, and improve the Offerings. Our purposes for using personal information include:

• Provide 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.
• Measure, Support, and Improve the Offerings: We use your personal information to measure use of, analyze performance of, fix errors in, provide support for, improve, and develop the Offerings.
• Recommendations and Personalization: We use your personal information to recommend the Offerings that might be of interest to you, identify your preferences, and personalize your experience with the Offerings.
• Comply with Legal Obligations: In certain cases, we have a legal obligation to collect, use, or retain your personal information. 
• Communicate with You: 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.
• Marketing: We use your personal information to market and promote the Offerings. We might display interest-based ads for the Offerings. 
• Fraud and Abuse Prevention and Credit Risks: We use your personal information to prevent and detect fraud and abuse in order to protect the security of our customers, us, the Technical Providers, and others. We may also use scoring methods to assess and manage credit risks.
• Purposes for Which We Seek Your Consent: We may also ask for your consent to use your personal information for a specific purpose that we communicate to you.
  

To enable our systems to recognize your browser or device and to provide the Offerings, we use Cookies. You can manage browser Cookies through your browser settings (e.g., accept and install Cookies, or remove 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.

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.

• Technical Providers and business partners: To ensure the smooth 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. Furthermore, they must process that information in accordance with this Privacy Policy and as permitted by applicable laws of China.

• Transactions Involving Third Parties: We make available to you services, software, and content provided by third parties for use on or through the Offerings. You can tell when a third party is involved in your transactions, and we share information related to those transactions with that third party. 

• Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf. Examples 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, and providing training. These third-party service providers only have access to personal information needed to perform their functions, and may not use it for other purposes. Further, they must process that information in accordance with this Privacy Policy and as permitted by applicable laws of China.

• Business Transfers: As we continue to develop our business, we might sell or buy businesses or services. In such transactions, personal information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless the individual consents otherwise). Also, in the unlikely event that we or substantially all of our assets are acquired, your information will be one of the transferred assets.

• Protection of Us and Others: We release 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.

• At Your Option:  Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you can decide whether to share the 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.

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.
  

The Offerings may include third-party advertising and links to other websites and applications. Third party advertising partners may collect information about you when you interact with their content, advertising, or services. 

You can view, update, and delete certain information about your account and your interactions with the Offerings. See list of examples of information that you can access below. 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 tell you how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

WE DON’T PROVIDE THE OFFERINGS FOR PURCHASE BY CHILDREN. IF YOU’RE UNDER 18, YOU MAY USE THE OFFERINGS ONLY WITH THE INVOLVEMENT OF A PARENT OR GUARDIAN.

WE KEEP YOUR PERSONAL INFORMATION TO ENABLE YOUR CONTINUED USE OF THE OFFERINGS, FOR AS LONG AS IT IS REQUIRED IN ORDER TO FULFILL THE RELEVANT PURPOSES DESCRIBED IN THIS PRIVACY POLICY, OR, AS MAY BE REQUIRED BY LAW, OR AS OTHERWISE COMMUNICATED TO YOU. HOW LONG WE RETAIN SPECIFIC PERSONAL INFORMATION VARIES DEPENDING ON THE PURPOSE FOR ITS USE, AND WE WILL DELETE YOUR PERSONAL INFORMATION IN ACCORDANCE WITH APPLICABLE LAW.

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 30 days, or other period as required by applicable laws and regulations, upon receipt of your enquiry. 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. Unless stated otherwise, our current Privacy Policy applies to all personal information we have about you and your account. 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.

Information You Give Us

You provide information to us when you:

• search for, subscribe to, or purchase the Offerings;
• create or administer your account (and you might have more than one account if you have used more than one email address when using the Offerings);
• configure your settings for, provide data access permissions for, or otherwise interact with the Offerings; 
• register for or attend an event organized by us and/or our partners;
• offer your content, products, or services on or through the Offerings;
  
• communicate with us by phone, email, or otherwise; 
• complete a questionnaire, a support ticket, or other information request forms; 
• post on Amazon Web Services China Site or participate in community features; and
• employ notification services.

Depending on your use of the Offerings, you might supply us with such information as:

• your name, email address, PHYSICAL ADDRESS, phone number, and other similar contact information;
• PAYMENT INFORMATION, INCLUDING CREDIT CARD AND BANK ACCOUNT INFORMATION;
• INFORMATION ABOUT YOUR LOCATION;
• information about your organization and your contacts, such as colleagues or people within your organization;
• usernames, aliases, roles, and other authentication and security credential information;
• content of feedback, testimonials, inquiries, support tickets, and any phone conversations, chat sessions and emails with or to us; 
• YOUR IMAGE (still, video, and in some cases 3-D), 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;
• INFORMATION REGARDING IDENTITY, INCLUDING GOVERNMENT-ISSUED IDENTIFICATION INFORMATION; 
• corporate and FINANCIAL INFORMATION; and
• VAT numbers and other tax identifiers.

Automatic Information

We collect information automatically when you:

• visit, interact with, or use the Offerings (including when you use your computer or other device to interact with the Offerings); 
• download content from us;
• open emails or click on links in emails from us; and
• interact or communicate with us (such as when you attend an event organized by us and/or our partners or when you request customer support).

Examples of the information we automatically collect include:

• 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; 
• 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;
• 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; 
• 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).

Information from Other Sources

Examples of information we receive from other sources include:

• marketing, sales generation, and recruitment information, including your name, email address, PHYSICAL ADDRESS, phone number, and other similar contact information; 
• subscription, purchase, support, or other information about your interactions with products and services offered by us, our affiliates, or third parties in relation to the Offerings; 
• search results and links, including paid listings (such as Sponsored Links); and 
• fraud history information or identity information from credit authorities or qualified institutions.

Information You Can Access

Examples of information you can access through the Offerings include:

• your name, email address, physical address, phone number, and other similar contact information; 
• usernames, aliases, roles, and other authentication and security credential information;
• your subscription, purchase, usage, billing, and payment history; 
• payment settings, such as payment instrument information and billing preferences;
• fapiao (or tax) information; and
• email communication and notification settings.

Customers can access the information above through 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)