Personal Information Protection and Privacy Policy

This policy applies only to Screen Direct products and services.

New date: October 2024

If you have any questions, comments or suggestions, please contact us using the contact information below:

E-mail: Support@zkdigimax.com

This policy will help you understand the following:

n Rules for the collection and use of personal information

n How we protect your personal information

n Your rights

n How we handle personal information of minors

n How this policy will be updated

n How to contact us

ZKDIGIMAX Co., Ltd. and its affiliates (hereinafter referred to as "ZKDIGIMAX", "the Company" or "we") recognizes the importance of your personal information and will do our best to protect the security and safety of your personal information. We recognize the importance of your personal information and will do our best to keep your personal information safe and secure. We are committed to maintaining your trust in us and abide by the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clarity of purpose, the principle of opt-in consent, the principle of minimum necessity, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. We also promise that we will not use your personal information for any purpose other than to protect your privacy. At the same time, ZKDIGIMAX promises that we will take appropriate security measures to protect your personal information in accordance with the industry's mature security standards.

Before using this product (or service), please be sure to read and thoroughly understand this policy and use the relevant product or service after confirming that you fully understand and agree to it. Once you start using the products or services, it means that you have fully understood and agreed to this policy.

I. Rules for the collection and use of personal information

(i) What personal information we collect about you

1. When you use Screen Direct (the name of the software product), we will collect the following information about you:

The business functions we provide rely on certain information to operate. If you choose to use this service, you will be required to provide us with, or allow us to collect, the necessary information, including: cell phone number, job title, name, email address, avatar, action, geographic location of login, IP address of the action, action, and type of device used to log in.

According to the software product you choose, you can selectively enter your cell phone number/name, in the account login need to use the mailbox as the account, you must provide the real mailbox in order to use the related business.

2、You can independently choose to provide us with or allow us to collect the following information: personal avatar, position, cell phone number.

This information is not necessary for the operation of the business function, but it is very important for improving the quality of service and developing new products or services. We will not compel you to provide this information, and your refusal will not adversely affect the use of this business function.

3. When you use this business function, our software will apply to you for the following system permissions related to personal information: obtaining location.

Failure to grant your authorization will result in our inability to provide the business functionality. In addition to the above permissions, you can choose whether to grant additional system permissions to the software.

When you contact us, we may keep information such as records and contents of your correspondence/calls or the contact information you have left in order to contact you or help you to solve the problem, or to record the solutions and results of the related problems.

(ii) How we use your personal information

1. For the necessary personal information, we will use it to provide this business function, and we will also use the following information to maintain and improve this business function, develop new business functions, etc.

2、We use personal information that is not necessary for the following purposes:

(iii) How we use cookies and similar technologies

1. Cookies

Cookies and similar technologies are commonly used on the Internet. To ensure the proper functioning of a website, we store a small data file called a cookie on your computer or mobile device, which usually contains an identifier, the name of the site, and some numbers and characters. Cookies enable websites to store data such as your preferences. We do not use cookies for any purpose other than those described in this policy. You can manage or delete cookies according to your preferences, you can clear all cookies stored on your computer and most web browsers have a function to block cookies. However, if you do so, you will need to personally change your user settings each time you visit our website.

2. Other similar technologies

In addition to cookies, we use web beacons, pixel tags, and other similar technologies on our website to help us understand your product or service preferences and improve customer service.

(iv) Cloud Platform Security Responsibility

1、ZKDIGIMAX is responsible for the security management and operation of services and data interaction on ZKDIGIMAX Cloud Platform, and is responsible for the security of the cloud service platform and infrastructure provided. Customers develop their own software or hardware embedded software by calling API interface, SDK, and accessing ZKDIGIMAX Cloud platform need to guarantee the security compliance of their applications and data, including hardware equipment and software by themselves. The main responsibility of ZKDIGIMAX Cloud is to develop, operate and maintain the basic services, platform services and application services, while the main responsibility of the customer is to customize the third-party client and build the third-party cloud services on top of using ZKDIGIMAX Cloud services. The following figure shows the shared responsibility model of the basic cloud service provider, ZKDIGIMAX and the customer's information security responsibility.

2、Security responsibility of ZKDIGIMAX cloud

a) ZKDIGIMAX Cloud ensures the security management and operation of infrastructure, physical equipment by selecting the world-renowned cloud hosting service providers Amazon, Tencent Cloud, Ali Cloud and other first-class cloud computing platforms.

b) ZKDIGIMAX Cloud security covers data security and cloud service security. ZKDIGIMAX commits to provide security operation and operation services of cloud platform by utilizing its security team and the professional attack protection technology experience of well-known security service vendors in the global scope to effectively protect the security operation of ZKDIGIMAX Cloud as well as safeguard the security of customers, users' privacy and data. Including but not limited to:

² Data Security: This refers to the security management of the customer's business data itself in the cloud business environment, including collection and identification, classification and hierarchy, permissions and encryption, and privacy compliance;

² Access control management: management of access rights to resources and data, including user management, rights management, authentication, etc;

² Cloud service security: refers to the security management of business-related applications in a cloud computing environment, including the design, development, release, configuration and use of applications and service interfaces.

3. Client's responsibility for security

a) Customers need to strictly follow the security configuration and access requirements of ZKDIGIMAX when using ZKDIGIMAX Cloud's solutions. At the same time, customers need to ensure the security of their own cloud, client or hardware products themselves.

b) For applications developed based on ZKDIGIMAX SDK/API, ZKDIGIMAX only provides technical support, but cannot provide security for the software as a whole.

c) For the data security compliance, privacy policy and other related information of the customized products based on ZKDIGIMAX solution, the privacy policy statement and legal compliance are the responsibility of the customer, and when necessary, ZKDIGIMAX security compliance team is willing to provide security solution help and consulting services.

(v) How we share, transfer and publicly disclose your personal information

1. Sharing

We will not share your personal information with any companies, organizations and individuals outside of our company unless we have your express consent.

We may share your personal information externally in accordance with laws and regulations, or in accordance with the mandatory requirements of governmental authorities.

2. Transfers

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

a) Transfer with explicit consent: We may transfer your personal information to other parties with your explicit consent;

b) In the event of a merger, acquisition, or bankruptcy or liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this Personal Information Protection Policy, or we will require that company or organization to seek your authorization and consent again.

3. Public disclosure

We will only publicly disclose your personal information in the following circumstances:

a) With your express consent;

b) Disclosure Based on Law: We may publicly disclose your personal information where required by law, legal process, litigation or mandatory requirements of governmental authorities, including:

c) Related to the fulfillment of the obligations of the controller of personal information under laws and regulations;

d) Directly related to national security and defense security;

e) Directly related to public safety, public health, and significant public interest;

f) Directly related to criminal investigations, prosecutions, trials and enforcement of sentences;

g) For the purpose of safeguarding the life, property and other significant legitimate rights and interests of the subject of the personal information or other individuals but it is difficult to obtain the authorized consent of the person himself/herself;

h) The personal information involved is disclosed to the public by the subject of the personal information himself/herself;

i) Necessary for the conclusion and performance of a contract in accordance with the requirements of the subject of the personal information;

j) Personal information is collected from lawful publicly disclosed information, such as lawful news reports, government information disclosure, and other channels;

k) Necessary to maintain the safe and stable operation of the products or services provided, such as detecting and disposing of malfunctions in the products or services;

l) The controller of the personal information is a news organization and it is necessary for it to carry out legitimate news reporting;

m) If the controller of personal information is an academic research organization, and if it is necessary to carry out statistical or academic research in the public interest, and if it provides the results of academic research or descriptions to the public, and if it de-identifies the personal information contained in the results.

Please note that, according to the law, the sharing or transfer of personal information that has been de-identified and processed in such a way as to ensure that the recipient of the data is unable to recover and re-identify the subject of the personal information does not constitute an act of sharing, transferring or publicly disclosing the personal information to the outside world, and that the preservation and processing of such data will be carried out without any separate notification to you and without obtaining your consent.

2. How we protect your personal information

(i) We value the security of personal data. We employ appropriate physical, managerial and technical safeguards to protect your personal data from unauthorized access, disclosure, use, modification, damage or loss. For example, we use encryption technology to ensure the confidentiality of data; we use protection mechanisms to prevent malicious attacks on data; we deploy access control mechanisms to ensure that only authorized personnel have access to personal data; and we conduct security and privacy protection training courses to enhance staff awareness of the importance of protecting personal data. We will do our best to protect your personal data, but please note that no security measure is foolproof.

(ii) We will retain your personal data for as long as is necessary to fulfill the purposes described in this policy, unless an extension of the retention period is required or permitted by law. Because the data storage period may vary based on different scenarios and different products and services, the criteria we use to determine the retention period include: the period of time for which the personal data is required to fulfill the business purpose, including the provision of products and services, maintenance of corresponding transaction and business records, control and improvement of the performance and quality of the products and services, guaranteeing the security of the system, products and services, responding to possible inquiries or complaints from users, locating problems, etc.; whether the user agrees to a longer retention period; the user's consent to a longer retention period; the user's consent to a longer retention period. complaints, problem localization, etc.; whether the user agrees to a longer retention period; whether there are special requirements for retaining data by law, contract, etc., etc. We will retain your registration information as long as your account is necessary to provide you with the service. You can also choose to cancel your account, after you cancel the account, we will stop providing products and services based on the account, and in the absence of special legal requirements, delete your corresponding personal data.

(iii) After the unfortunate occurrence of a personal information security incident, we will, in accordance with the requirements of laws and regulations (within 30 natural days at the latest), inform you of: the basic situation of the security incident and its possible impact, the measures we have taken or will take to deal with the incident, the suggestions you can independently take to prevent and minimize the risk, and the remedial measures to be taken against you. We will inform you of the situation related to the incident by email, letter, phone call, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to make a public announcement. At the same time, we will also report on the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

(iv) The Internet environment is not 100% secure, and although we have these security measures in place, please note that there is no such thing as "perfect security" on the Internet, and we will do our best to ensure the security of your information.

(v) To ensure a smooth browsing experience, you may receive content or web links from third parties external to us and our partners ("Third Parties"). We have no control over such Third Parties. It is your choice whether or not to access the links, content, products and services provided by Third Parties. We have no control over the privacy and data protection policies of Third Parties and such Third Parties are not bound by this Policy. Before submitting personal information to a third party, please see that third party's privacy policy.

3. Your rights

In accordance with the relevant laws, regulations and standards of China, as well as the common practice of other countries and regions, we guarantee that you will exercise the following rights with respect to your personal information:

(i) Access to your personal information

You have the right to access your personal information, with the exception of the exceptions provided for in laws and regulations. If you wish to exercise your right of access to data, you may do so yourself by logging into the software platform where you can view your personal information.

如If you are unable to access this personal information through the links above, you may at any time 发送电子邮件至Support@zkdigimax.com

For other personal information generated in the course of your use of our products or services, we will provide you with it as long as we don't need too much input. If you wish to exercise your right of data access, 请发送电子邮件至Support@zkdigimax.com

Correction of your personal information

You have the right to ask us to correct any personal information we process about you if you discover that it is incorrect. You can make a request for correction in the ways listed under "(i) Access to your personal information".

If you are unable to correct this personal information through the link above, 您可以随时发送电子邮件至Support@zkdigimax.com

(ii) Delete your personal information

In the following cases, you may make a written request to us to delete your personal information:

1. If our handling of personal information violates laws and regulations;

2. If we collect or use your personal information without your consent;

3. If you no longer use our products or services, or if you cancel your account;

4. If we no longer provide products or services to you.

You also have the right to withdraw your consent at any time when we process your personal data on the basis of your consent, where required by applicable law. However, revocation of consent will not affect the lawfulness and validity of our processing of your personal data based on your consent prior to the revocation, nor will it affect our processing of your personal data based on another appropriate basis of legitimacy.

(iii) Responding to your request above

For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

We will respond within 7 days. If you are not satisfied, you can also file a complaint at Support@zkdigimax.com

In principle, we do not charge fees for reasonable requests, but we will charge a fee for costs incurred for requests that are repeated more than reasonably possible. We may refuse requests that are unnecessarily repetitive, require excessive technical means (e.g., requiring the development of a new system or a fundamental change in existing practices), pose a risk to the legal rights of others, or are highly impractical (e.g., involving the backing up of information stored on magnetic tapes).

We will not be able to respond to your request in the following circumstances:

1. Related to the fulfillment of the obligations of the controller of personal information under laws and regulations;

2. Directly related to national security and defense security;

3. Directly related to public safety, public health, and significant public interest;

4. Directly related to criminal investigations, prosecutions, trials and enforcement of sentences;

5. Where the controller of personal information has sufficient evidence of subjective malice or abuse of rights by the subject of the personal information;

6. For the purpose of safeguarding the life, property and other important legal rights and interests of the subject of the personal information or other individuals, but it is difficult to obtain the consent of the individual;

7. If responding to a request from a subject of personal information will result in serious damage to the legitimate rights and interests of the subject of personal information or other individuals or organizations;

8. Those involving trade secrets.

4. How we handle minors’ personal information

Our products, websites and services are primarily intended for adults. Minors should not create their own personal information subject accounts without parental or guardian consent. If you are a minor, we recommend that you ask your parent or guardian to read this Policy carefully and to use our services or provide information to us with the consent of your parent or guardian.

In cases where personal information of minors is collected with parental consent, we will only use or publicly disclose this information as permitted by law, with the express consent of the parent or guardian, or as necessary to protect the minor.

If we become aware that we have collected personal information from minors without first obtaining verifiable parental consent, we will seek to delete the relevant data as soon as possible.

4. How this policy will be updated

Our personal information protection and privacy policy is subject to change.

We will not reduce your rights under this policy without your express consent. We will post any changes we make to this policy on this page.

For major changes, we will also provide more prominent notice (including, for certain services, email notification of specific changes to our personal information protection policy).

Significant changes referred to in this policy include, but are not limited to:

1. Significant changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, and how personal information is used;

2. Significant changes in our ownership structure, organizational structure, etc. such as changes in ownership due to business restructuring, bankruptcy and mergers and acquisitions;

3. Changes in the primary recipients of personal information to be shared, transferred or publicly disclosed;

4. Significant changes in your rights to participate in the processing of personal information and how you can exercise them;

5. In the event of a change in the department responsible for handling the security of personal information, our contact details and complaint channels;

We will also keep an older version of this policy on file for your review.

6. How to contact us

If you have any questions, comments or suggestions about this Personal Information Protection and Privacy Policy, Please send your questions to Support@zkdigimax.com by under normal circumstances will respond within 7 days. More contact information will be announced on our official website (http://www.ZKDIGIMAX.com).