User Privacy Policy of Topease

User Privacy Policy of Topease

Updated Date：December 2022

Effective Date：December 2022

Important Tips:

Please read and understand thoroughly this policy before using Topease's products or services, and use them only after confirming that you fully understand and agree to it. Once you start using Topease's products or services, it means that you have fully understood and agreed to this policy.

Introduction

To protect the privacy of our users, Topease has established the "Topease User Personal Information Protection Policy" (hereinafter referred to as "this Policy") in accordance with national laws and regulations. This Policy will provide you with detailed information on how Topease collects, uses and manages your personal information. This Policy applies to the Topease data products (or services) that Topease provides to you through computer devices, mobile terminals or other devices and programs, including sub-products like Topease Global Trade Pal 5.0, D&B Hoovers, Tesour, Melark, and Yixueke.

Topease understands the importance of personal information to you and will make every effort to protect the security and reliability of your personal information. Topease is committed to processing personal information in accordance with the principles of lawfulness, legitimacy, necessity and good faith, and will take appropriate security measures to protect your personal information in accordance with the mature security standards of the industry. Topease’s processing of personal information has a clear and reasonable purpose and is directly related to this purpose. The approach that Topease takes has the least impact on the rights of individuals.

If you have any questions, comments or suggestions regarding the contents of this Policy, please contact Topease by using the following contact information:

Email：advise@topease.net

Phone Number：021-64860066

Part 1: Definitions

Topease：It refers to Shanghai Topease Info-Tech Co., Ltd and includes:

1. Qingdao Branch of Shanghai Topease Info-Tech Co., Ltd

2. Xiamen Branch of Shanghai Topease Info-Tech Co., Ltd

3. Jinhua Branch of Shanghai Topease Info-Tech Co., Ltd

4. Shenzhen Branch of Shanghai Topease Info-Tech Co., Ltd

5. Hangzhou Branch of Shanghai Topease Info-Tech Co., Ltd

6. Wenzhou Branch of Shanghai Topease Info-Tech Co., Ltd

7. Ningbo Branch of Shanghai Topease Info-Tech Co., Ltd

8. Taizhou Branch of Shanghai Topease Info-Tech Co., Ltd

9. Jiangsu Topease Info-Tech Co., Ltd

10. Shanghai Topease Business Consulting Co.

Other possible new entities owned by Topease.

Personal Information: It refers to all kinds of information recorded electronically or in other ways that can identify a specific natural person or reflect the activities of a specific natural person alone or in combination with other information, such as name, date of birth, identity document number, address, communication contact method, communication record and content, credit information, transaction information, etc.

Sensitive Personal Information: It refers to personal information that may endanger personal and property safety if leaked, illegally provided or misused, and may easily lead to damage to personal reputation, physical and mental health or discriminatory treatment. Generally speaking, it includes biometric information, religious beliefs, specific identities, medical health, financial accounts, whereabouts and other information, as well as personal information of minors under 14.

Part 2: Privacy Policy

This policy will help you understand the following information:

1. How Topease collects and uses your personal information within reasonable limits.

2. How Topease uses cookies and similar technologies.

3. How Topease shares, transfers, and publicly discloses your personal information within reasonable limits

4. How Topease protects your personal information.

5. Your rights.

6. How Topease processes personal information of minors.

7. How Topease transfers your personal information worldwide in accordance with the law and regulations.

8. How this policy is updated.

9. How to contact Topease.

1. How Topease Collects and Uses Your Personal Information within Reasonable Limits

(a) The Purpose and Scope of Collection and Use of Your Personal Information.

Topease will follow the principles of legality, justification and necessity in collecting and using your personal information for the following purposes as described in this policy.

(i) When you register and login to the product before using Topease data, Topease will collect your cell phone number or email account, and will use this information for opening and verifying permissions, sending official account opening SMS notification, identifying the user's company and sending regular product update dynamic SMS.

(ii) When you fill out the product application trial form, Topease will collect your name, region, industry, company, position, email and cell phone number. Topease will use this information to arrange sales staff to contact you to confirm the opening of the trial account or the purchase of the official account.

In the course of your use of Topease's products (or services) described above, it will help Topease provide you with a better service and experience if you provide the following additional information. However, if you do not provide this information, the use of basic functions of this service will not be affected.

The information you provide above will be used by Topease for the duration of your use of the products (or services) mentioned above. If you cancel your account and request Topease to delete your personal information, Topease will stop using and delete the above information.

The above information will be stored in the People's Republic of China. For cross-border transmission, Topease will obtain your authorization separately.

When Topease wants to use information for purposes other than those set forth in this policy, we will ask for your prior consent.

When Topease wants to use information collected for a specific purpose for other purposes, we will ask for your consent in advance.

2. How Topease Uses Cookies and Similar Technologies

(a) Cookies

Cookies are small data files that are stored on your computer or mobile device to ensure that the site works properly and efficiently, to make your visit easier, and to suggest content that may be of interest to you. Cookies usually contain an identifier, the site name, and some numbers and characters. With the help of cookies, websites can store data such as your cell phone number or email address.

Topease will not use cookies for any purpose other than those described in this policy. You can manage or delete cookies according to your preferences, and you can clear all cookies stored on your computer. Most browsers automatically accept cookies, but you can usually modify your browser settings to refuse cookies if you wish. Please note that due to technical limitations, if you deactivate cookies, you may not be able to enjoy the best service experience, and some services may not work properly.

(b) Web Beacons and Pixel Tags

In addition to cookies, Topease uses other similar technologies such as web beacons and pixel tags on its website. For example, an email sent to you by Topease may contain a link to an address that links to content on the Topease website. If you click on that link, Topease tracks that click, which is helpful for Topease to understand your product or service preferences and improve its customer service. A web beacon is typically a transparent image that is embedded in a website or email. With the help of pixel tags in the email, Topease is able to know if the email has been opened. If you do not want your activity to be tracked in this way, you can unsubscribe from Topease's mailing list at any time.

(3) Do Not Track

Many web browsers have a “Do Not track” feature, which issues “Do Not Track” requests to websites. At this time, the major Internet standards organizations have not established policies that govern how websites should respond to such requests. However, if your browser has enabled “Do Not Track”, then all of Topease's websites will respect your choice.

3. How Topease Shares, Transfers, and Publicly Discloses Your Personal Information within Reasonable Limits

(a) Sharing

Topease will not share your personal information with any other third party, except for the following.

(i) Sharing with explicit consent: Topease will share your personal information with other parties after obtaining your explicit consent.

(ii) Topease may share your personal information with the public in accordance with laws and regulations, or as mandated by government authorities.

(iii) Sharing with Topease's Affiliates: Your personal information may be shared with Topease's affiliates or branches. Topease will only share personal information that is necessary for the performance of the contract and is subject to the purposes stated in this Privacy Policy. If an affiliate or a branch wants to change the purpose or scope of processing personal information, it will seek your authorized consent again.

(iv) Sharing with Authorized Partners: Some of Topease's services will be provided by authorized partners only for the purposes stated in this policy, and Topease may share some of your personal information with partners to provide better customer service and user experience. For example, your email, region, industry, company and position. Topease will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and only as much personal information as is necessary to provide the service. Topease's partners do not have the right to use the shared personal information for any other purpose.

For companies, organizations and individuals with whom Topease shares personal information, Topease will sign strict confidentiality agreements or terms with them, requiring them to keep and use the shared personal information for the purposes and scope agreed with Topease, and to take other relevant confidentiality and security measures to keep and process the shared personal information received.

(b) Transfer

Topease will not, in principle, transfer your personal information to any company, organization or individual, except in the following cases.

(i) Transfer with your explicit consent: After informing you of the purpose of the transfer, the type of data recipient, the type of data to be transferred and other conditions required by law, and obtaining your explicit consent, Topease will transfer your personal information to other parties.

(ii) In case of merger, acquisition or reorganization, bankruptcy and liquidation, if personal information is transferred, Topease will ask the new company or organization holding your personal information to be bound by this privacy policy, and will inform you of the name and contact information of the recipient, otherwise Topease will ask this company or organization to seek your authorized consent again. If the purpose of using personal information changes, Topease will obtain your express consent again.

Topease will only publicly disclose your personal information other than sensitive personal information under the following circumstances.

(i) After informing you of the purpose and type of public disclosure of personal information (and the content of the sensitive personal information involved if there is a disclosure of sensitive personal information) and obtaining your separate and explicit consent.

(ii) Disclosure based on law: Topease may disclose your personal information publicly if compelled to do so by law, legal process, judicial or governmental authorities.

(d) Exceptions to Prior Authorized Consent for Sharing, Transfer, and Public Disclosure of Personal Information

Your prior authorized consent is not required for the sharing, transfer, or public disclosure of your personal information in the following cases.

(i) Your personal information is directly related to national security and national defense security.

(ii) Your personal information is directly related to public safety, public health, significant public interest.

(iii) When an emergency occurs, we need to safeguard your or other individuals ‘life, property and other legitimate rights and interests but it is difficult to obtain the consent(you or other individuals will be informed in time after the emergency is eliminated).

(iv) The Personal information that you disclose to the public on your own and within a reasonable range (except for those that the individual explicitly rejects and have a significant impact on the rights and interests of the individual).

(v) The collection of personal information from legitimate public disclosure of information, such as legitimate news reports, government information disclosure and other channels (except for those that the individual explicitly refuses and have a significant impact on personal rights and interests).

(vi) Your information is necessary for the conclusion or performance of the contract to which the individual is a party, or for the implementation of human resources management in accordance with the labor rules and regulations established by law and the collective contract signed by law.

(vii) It is necessary to share, transfer and publicly disclose your personal information so as to fulfill legal duties or legal obligations.

(viii) The Processing of personal information within a reasonable range for the implementation of news reporting and public opinion monitoring in the public interest.

According to the law, the sharing or transfer of anonymized personal information, and at the same time ensuring that the recipient of the data cannot recover and re-identify the subject of the personal information, is not an act of sharing, transferring or publicly disclosing the personal information to the public. Therefore the storage and processing of such data will not require separate notification to you and your consent.

4. How Topease Protects Your Personal Information

(a) Topease has implemented industry-standard security measures to protect the personal information you provide to us from unauthorized access, public disclosure, use, modification, damage or loss. Topease takes all reasonably practicable steps to protect your personal information. For example, the exchange of data (such as credit card information) between your browser and the Service is protected by SSL encryption; Topease provides https secure browsing of the Topease website; Topease uses encryption technology to ensure the confidentiality of data; Topease uses trusted protection mechanisms to prevent malicious attacks on data; Topease deploys access control mechanisms to ensure that only authorized personnel have access to personal information; in addition, Topease has signed confidentiality agreements with its employees or included confidentiality obligations in employment contracts with employees; Topease holds security and privacy training courses to enhance employees' awareness of the importance of protecting personal information.

(b) Topease will take all reasonably practicable steps to ensure that no unrelated personal information is collected. Topease will only retain your personal information for the shortest period of time necessary to achieve the purposes described in this policy, unless an extended retention period is required or permitted by law.

(c) Please know and understand that the Internet is not an absolutely secure environment and that e-mail, instant messaging, and communication with other Topease users are not encrypted, and Topease strongly recommends that you do not send personal information through such means. In addition, Topease strongly recommends that you help us keep your account secure by using a secure method and a complex password. If you find that your personal information has been leaked, especially your account or password, please contact Topease immediately using the contact information provided in this Privacy Policy so that Topease can take appropriate action.

(d) Topease will regularly update and disclose the relevant contents of the reports on security risks and personal information security impact assessment. You can get it by way of announcement on Topease's official website.

(e) The Internet environment is not 100% secure and Topease will endeavor to ensure or warrant the security of any information you send to us. If Topease's physical, technical or managerial safeguards are compromised, resulting in unauthorized access, public disclosure, alteration or destruction of information, resulting in damage to your legal rights and interests, Topease will bear the corresponding legal responsibility.

(f) After the unfortunate occurrence of personal information security incidents, Topease will inform you in a timely manner in accordance with the requirements of laws and regulations: the basic situation of the security incident and the possible impact, the disposal measures that Topease has taken or will take, the suggestions for you to prevent independently and reduce the risk, the remedial measures for you, etc. Topease will inform you in a timely manner of the incident-related situation by mail, letter, and telephone. If it is difficult to inform the subject of personal information one by one, Topease will take reasonable and effective ways to publish the announcement.

At the same time, Topease will also take the initiative to report the disposal of personal information security incidents in accordance with the requirements of the regulatory authorities.

5. Your Rights

In accordance with the relevant Chinese laws, regulations and standards, as well as the common practices of other countries and regions, Topease protects your right to exercise the following rights with respect to your personal information.

(a)Access Your Personal Information

You have the right to access your personal information, with the exceptions provided by law and regulations. If you wish to exercise your right of access to data, you may do so by:

Account Information - If you wish to access or edit your profile information and payment information in your account, change your password, add security information, or close your account, etc., you may do so by visiting Personal Center.

If you are unable to access this personal information through the above paths, you may contact Topease at any time using Topease's web form or send an email to advise@topease.net. Topease will respond to your request for access within fifteen days.

For any other personal information generated in the course of your use of Topease's products or services, Topease will provide it to you as long as it does not require excessive investment costs for Topease. If you wish to exercise your right of data access, please send an email to advise@topease.net.

(b)Correction of Your Personal Information

When you discover an error in your personal information processed by Topease, you have the right to request a correction by using the methods listed in "(a) Access Your Personal Information".

If you are unable to correct such personal information in the manner described above, you may do so at any time by contacting Topease using its web form or sending an email to advise@topease.net. Topease will respond to your request for correction as soon as possible, and at the latest within fifteen days.

(c)Delete Your Personal Information

You may make a request to Topease to delete personal information in the following cases:

(i) Topease's processing of personal information violates laws and regulations.

(ii) Topease collects and uses your personal information without your consent.

(iii) Topease's processing of personal information is in breach of the agreement with you

(iv) You will no longer use Topease's products or services, or you have canceled your account.

(v) Topease will no longer provide you with products or services.

If Topease decides to respond to your request for deletion, it will also notify the entities that have received your personal information from Topease and request that they delete it promptly, unless otherwise required by law or regulation, or unless those entities have your independent authorization directly (in which case you should notify those entities directly to delete your personal information).

When you delete information from Topease's service, Topease may not immediately delete the corresponding information from the backup system, but will delete it when the backup is updated.

（d）Change the Scope of Your Authorized Consent

Each business function requires some basic personal information in order to be completed (see Part II, Section 1 of this policy for details). You may give or withdraw your authorized consent for the collection and use of additional personal information collected at any time.

When you withdraw your consent, Topease will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization.

(E) Subjects of Personal Information Cancel the Account

You can cancel your registered account at any time in the following way: Personal Center - Cancel Account. After you cancel your account, Topease will stop providing products or services to you and delete your personal information upon your request, except as required by law or regulation or as otherwise provided or agreed between Topease and you.

(F) Constraint Information System Automatic Decision Making

In some business functions, Topease may make decisions based solely on non-manual automated decision making mechanisms including information systems, algorithms, etc. If these decisions significantly affect your legal rights, you have the right to seek an explanation from Topease, and Topease will provide appropriate remedies.

(G) Withdrawal of Consent

If personal information is processed based on your personal consent, you have the right to withdraw your consent and Topease will not refuse to provide products or services on the grounds that you do not consent to the processing of your personal information or withdraw your consent, except where the processing of personal information is necessary for the provision of the products or services.

(H) Respond to Your Request Above

For security purposes, Topease may require you to provide a written request or prove your identity in other ways. Topease reserves the right to ask you to verify your identity before processing your request.

Topease will respond within fifteen days. If you are not satisfied, you can send an email to advise@topease.net to file a complaint.

In principle, we do not charge a fee for your reasonable requests, but we will charge a cost fee for repeated requests that exceed reasonable limits, as appropriate. Requests that are unnecessarily repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical (for example, involving the backup of information stored on tape) may be denied.

In the following cases, Topease will not be able to respond to your request, as required by law or regulation.

(i) Directly related to national security, state secrets, and national defense security.

(ii) Directly related to public safety, public health, significant public interest.

(iii) There is sufficient evidence that you have subjective malice or abuse of rights.

(iv) Responding to your request will lead to serious damage to the legitimate rights and interests of you or other individuals or organizations.

(v) Involving trade secrets.

6. How Topease Processes Personal Information of minors.

Topease's products, website and services are intended primarily for adults. Minors may not create their own user accounts without the consent of a parent or guardian. If you are a minor, you must ask your parent or guardian to read this policy carefully and use our products or services or provide information to us with the consent of your parent or guardian.

In the case where personal information is collected from a minor with the consent of a parent or guardian, Topease will only use or publicly disclose this information when it is permitted by law, with the express consent of the parent or guardian, or when it is necessary to protect the minor.

If Topease finds that it has collected personal information from a minor without prior verifiable parental or guardian consent, it will seek to delete the relevant data as soon as possible.

For processing personal information of minors under the age of fourteen, Topease will separately formulate special rules for the processing of personal information.

7. How Topease Transfers Your Personal Information Worldwide in Accordance with the Law and Regulations.

Personal information collected and generated by Topease during its operation in the People's Republic of China is stored in the territory of China, except for the following cases:

(a) It is clearly defined by laws and regulations.

(b) Topease has obtained your express authorization.

For the above situations, Topease will ensure that your personal information is adequately protected to the same extent as it would be in the People's Republic of China. For example, Topease may request your consent to transfer personal information across borders or implement security measures such as data de-identification prior to the transfer of data across borders.

8. How this Policy is Updated

Topease's privacy policy may change.

Topease will not reduce your rights under this Privacy Policy without your express consent, and Topease will post any changes to this Policy through reasonable means (such as on this page).

For material changes, Topease will also provide more prominent notice (including for some services, Topease will send a notice by email to explain the specific changes to the Privacy Policy).

Material changes within the meaning of this policy include, but are not limited to:

(a) Significant changes in Topease's service model, such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used.

(b) Major changes in Topease’s ownership structure, organizational structure, etc., such as changes in owners caused by business adjustments, bankruptcy mergers, etc.

(d) Significant changes in your right to participate in the processing of personal information and the way you exercise it.

(e) Changes in the department in charge of processing personal information security, the contact method and the complaint channel.

(f) When the personal information security impact assessment report indicates a high risk.

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

9. How to Contact Topease.

If you have any questions, comments or suggestions regarding this Privacy Policy, please contact Topease by using the following contact information:

Email：advise@topease.net

Phone Number：021-64860066

Topease has a dedicated personal information protection department (or personal information protection officer), and you can contact them in the same way.

In general, Topease will reply within fifteen days.

If you are not satisfied with Topease's response, especially if Topease's personal information processing practices have harmed your legal rights, you can also bring a lawsuit to the court with jurisdiction in the place where Topease is domiciled

If there are differences in translation between the English and Chinese versions, the Chinese version shall prevail.