Privacy Agreement
Latest
version release date: May 25, 2023
Welcome
to "XCEED" (referring to XCEED's products and mobile applications
(APP), hereinafter referred to as "XCEED")! XCEED APP (hereinafter
referred to as "APP" or "Application") is an APP product
provided by Shenzhen Meijie Import and Export Co.,
Ltd. (hereinafter referred to as "we" or "our company").
We
attach great importance to your privacy. In order to better protect your
personal information, we recommend that you carefully read the updated "XCEED
Privacy Policy" ("this Policy"), especially the terms in bold
black, to understand that what information about you is collected and how we
will use it, please ensure your full understanding and consent before starting
to use it. When you agree to this policy, you have agreed that we will process
your relevant information in accordance with this policy. You should not use XCEED
unless you have read and accepted all the terms of this policy. This policy
applies to, including but not limited to, personal information that you
actively provide during the use of XCEED services or that are generated due to
product/service needs. However, this policy does not apply to the use of
your personal information by third parties, and we encourage you to familiarize
yourself with the corresponding privacy policy before providing information to
the third party. If you have any objections or questions about the terms of
this policy, you can communicate with us through the contact information
published in Article 10 of this policy "How to Contact Us".
This policy will help you understand
the following:
一、related definition
二、How we collect and use
personal information
三、How we use SDK technology
四、How we process your personal information
五、How we store personal information
六、How we protect your personal information
七、How we manage your personal information
八、protection of minors
九、Revisions and Updates to this Policy
十、How to Contact Us
一、Related definition
Personal
information
Personal
information：Personal information refers to various information related
to identified or identifiable natural persons recorded electronically or
otherwise, excluding anonymized information.
Sensitive
personal information：Refers to personal information that, once leaked or
illegally used, may easily cause the personal dignity of a natural person to be
violated or the personal and property safety to be jeopardized. This policy
includes: personal biometric information (such as voiceprint, static or
dynamic facial features, etc.), precise positioning information, personal
information of children under the age of 14 (including), etc.
Anonymization
Through
the technical processing of personal information, the subject of personal
information cannot be identified and cannot be recovered after processing.
De-identification
processing
refers
to the process of technically processing personal information to make it
impossible to identify or associate the subject of personal information without
additional information.
二、How we collect and use personal
information
We
process the personal information that you actively provide in the process of
using the service or generated due to the needs of products/services in
accordance with laws and regulations and the principles of fairness, legality,
necessity, openness, transparency, and "minimization", and inform you
of the relevant personal information. Purpose and scope of use. If we intend
to use your personal information for other purposes not specified in this
policy, or use the collected information for other purposes based on a specific
purpose, we will notify you in a timely and reasonable manner, and we will
inform you again before using it and with your consent.
There
are two types of your personal information that we collect and use:
Information
necessary for basic business functions: This type of information is necessary
for the normal operation of the product/service, and you must authorize us to
collect it. If you refuse to provide it, you will not be able to use our
products/services normally.
Information
that may be required to expand business functions: This information is not
required for basic business functions, and you can choose whether to authorize
us to collect it. If you refuse to provide it, it will result in the failure of
additional functions or the effect we intend to achieve, but it will not affect
your normal use of basic business functions.
In
addition, you understand and agree that we hope to provide you with perfect
products and services, so we will continue to improve our products and
services, including technology, which means that we may often launch new
business functions, It may be necessary to collect new
personal information or to change the purpose or method of using personal
information. If a function or product/service that needs to collect your
personal information is not described in this policy, we will update this
policy, email, mobile phone text message, APP pop-up window, APP notification
bar message push…ETC, and explain to you the purpose, content, use method and
scope of the information collection, and provide you with a way to choose your
consent, and collect it after obtaining your express consent. During this
process, if you have any questions about related matters, you can communicate
with us through the contact information published in Article 10 "How to
Contact Us" of this policy, and we will answer you as soon as possible.
We
process the following types of personal information about you for the following
purposes：
User
registration and login
When
you create an account at XCEED, in order to become our member so that we can
provide you with member services, you need to provide (1) mobile phone number,
email address; and create (2) username and (3) password.
When
you use XCEED, in order to maintain your basic information and improve your
service experience, you need to choose to fill in and/or complete the necessary
information for the service, which may include your email address, mobile phone
number, nickname, etc. If you do not provide this information, it will not
affect your use of the basic business functions of XCEED. In order to better
provide you with after-sales service and firmware upgrade service, we need to
collect your XCEED device serial number and XCEED device MAC address. At the
same time, we also need to collect your Android ID, because the virtual UUID
needs to be used as the unique identification of the mobile phone in both the
buried point and the background interface request. When you use XCEED, in order
to maintain your basic information and improve your service experience, you
need to choose to fill in and/or complete the necessary information for the
service, which may include your email address, mobile phone number, nickname,
etc. If you do not provide this information, it will not affect your use of the
basic business functions of XCEED.
Audio
playback function
When
you use XCEED for audio playback, we may need to collect browsing and playback
history, favorites, etc. generated during your use.
Provide
information display and push of goods or services
In
the process of using our products/services, in order to provide you with a page
display that better suits your needs, we may automatically collect your usage
information and store it as web log information, and collect your page clicks
and browsing through buried points Wait for the specific number of operations
and the length of the buried point information.
We
will provide you with advertising push services by pushing banners on the
screen opening and discovery pages, and will clearly mark the word
"advertisement" on the screen opening and discovery page banners, and
place a skip or close button in the upper right corner of the screen opening
Provide users with the option to decline or turn off push or ad marketing.
If
you have any questions about our service of recommending advertisements to you
according to the aforementioned content, you can communicate with us through
the contact information published in Article 10 "How to Contact Us"
of this policy.
Notification
During
our operations, we may send various types of notifications through your email,
SMS, APP pop-up window, APP notification bar message push, etc., for user
message notification, identity verification, security verification, user
experience research and other purposes; , we may also
send you commercial information such as product-related services, functions or
activities. If you do not want to accept such information, you can communicate
with us through the contact information published in Article 10 of this Policy
"How to Contact Us".
Improve
our services
In
order to better understand your opinions and suggestions on XCEED
products/services and improve the quality of our products/services, we may,
with your consent, send emails, text messages, APP pop-up windows, APP
notification bar message push, etc. Ways to use third-party tools (Survey
Monkey) to send/provide questionnaires to you, conduct interviews with you,
etc. During the process of filling out the questionnaire/interview, you need to
provide different categories of personal information depending on the type of
the questionnaire/interview. If you do not wish to provide the above personal
information, you may refuse to complete the questionnaire/interview.
During
your use of our services, we may directly or indirectly collect and store
information about your use in order to identify abnormal account status,
understand product suitability, provide you with basic services such as
browsing, ensure the normal operation of the service, and optimize the service
experience. Information about the services and usage methods of the company and
correlating the information, including log information and device information.
In order to collect the above personal device information, we will apply for
permission to access your device information.
In
order to conduct data analysis and research and improve the products/services
we provide to you, we may collect relevant information
when you interact with the XCEED platform. Such information may include: your
IP address, APP operation records, mobile phone and headset device information.
XCEED
APP permission call instructions
In
order to provide you with the service you choose to use, or to ensure the
quality and experience of the service, some functions provided by XCEED may
require your authorization to open the operating system permission. If you do
not agree to authorize the XCEED APP to obtain the relevant operating system
permissions, it will not affect your use of the basic business functions we
provide (except for the necessary operating system permissions that the basic
business functions rely on), but you may not be able to obtain extended
business services to bring you user experience.
Bluetooth
permission (Android, iOS version): We need you to authorize us to access your
Bluetooth permission to pair and connect XCEED products with other devices
(such as your mobile phone).
Permission
to read and write external storage space (Android version): We need you to
authorize us to access your permission to read and write external storage
space, which is used to store images for products.
Location
permission (Android version): We need you to authorize us to access your
location permission to search for nearby Bluetooth devices. Android 6 and above
require location services to be enabled to search for Bluetooth devices.
Read
call status permission (Android, iOS version): We need to obtain the read call
status permission, which is used for music players (such as white noise
playback) to monitor the call status of mobile phones. If music was playing
before the incoming call, it will switch to music pause, and resume music
playback after the call ends.
Get
app list permission (Android version): We need to get app list permission for
firebase SDK to collect and push messages.
Clipboard
permission (Android, iOS version): When you share or receive shared custom EQ
information, we will read your clipboard content to determine whether there is
a link, so as to realize the function of reading the link. After getting the
link, we will pop up a window prompting you to choose whether to load the EQ
data in the link, but we will only upload it to our server when we recognize
that the content of the clipboard belongs to XCEED locally.
Please
note that if you enable any permission, you authorize us to collect and use
relevant personal information to provide you with corresponding services. Once
you close any permission, it means that you cancel the authorization, and we
will no longer continue to collect based on the corresponding permission and
use relevant personal information, and cannot provide you with the services
corresponding to this permission. However, your decision to close the
permission will not affect the previous collection and use of information based
on your authorization. Unless you cancel the authorization of personal
information necessary for basic business functions, your cancellation of
authorization will not affect the use of other functions.
Please
be aware that according to the provisions of laws and regulations, under
certain circumstances, the collection and use of your personal information does
not require your prior authorization and consent. For specific exceptions,
please refer to Section 4 "Exceptions to Authorization and Consent"
in Article 4 of this Policy .
三、How
we use SDK technology
In
order to ensure the stable operation and function realization of our mobile
client, so that you can enjoy and use more services and functions, our
applications will embed third-party partners' SDKs or other similar
applications. We will conduct strict security inspections on the application
program interface (API) and software tool development kit (SDK) for third-party
partners to obtain relevant information, and agree with authorized partners on
strict personal information protection measures to make them comply with this
policy and Any other relevant confidentiality and
security measures to process personal information. Please review the
"Instructions for Collecting and Using Information by Third-Party SDKs".
Third-Party SDKs
SDK Usage Content
Tencent Bugly Log Collection AndroidID、MAC Address
四、How we process your personal information
Joint
processing and entrusted processing
You
fully understand and agree that when providing you with products or services,
we will jointly process or entrust your personal information under the
following circumstances. When the following circumstances are exceeded, we will
notify you through Article 9 Separately ask you for your authorization and
consent:
Joint
processing:
When obtaining your separate consent or in accordance with the
"Exceptions to Authorization Consent" in Section 4 of this Article 4,
we may cooperate with you to help us operate, analyze, third party partners for
improvement, customization, support and marketing jointly process your
information.
Entrusted
processing：Some specific modules and functions in some business
functions of XCEED are provided by external suppliers. The third-party partners
we entrust to process personal information can only have access to the
information they need to perform their duties, and we will supervise their
entrusted processing activities.
We
will only entrust and jointly process your information for the legal,
legitimate, necessary, specific, and clear purposes stated in this policy. We
will conduct a reasonable review of the personal information security
environment of third-party partners, and sign a strict personal information
processing agreement with them to ensure that they can only access the
information they need to perform their duties, and require them to take
adequate protection measures for your information, strictly abide by relevant
laws and regulations and regulatory requirements.
If
the agreement between us and the third-party partner on the processing purpose
and processing method changes and substantially affects the original processing
purpose and processing method, we will re-obtain your authorization and
consent. If you choose to cancel the authorization, we will stop the service
corresponding to the authorization.
Transfer
We
may transfer your personal information to other companies, organizations or
individuals when obtaining your separate consent or in compliance with
Section 4 "Exceptions to Authorized Consent" in Article 4. In the
event of a merger, acquisition, or bankruptcy liquidation, the transfer of
personal information may be involved. In this case, we will require the new
company or organization that holds your personal information to continue to be
bound by this policy. If there is any change in the collection and processing
of personal information stipulated in this policy, the company or organization
will seek your authorization again.
Public
When
obtaining your separate consent or in compliance with Section 4
"Exceptions to Authorized Consent" in Article 4, we may disclose
personal information under the premise of adopting industry-standard security
protection measures. For your personal information that is disclosed, we will
carefully review its legitimacy, rationality, and legality immediately after
receiving the application for disclosure, and take the measures described in
Article 6 of this policy when and after disclosure. for protection.
Exceptions
to Authorized Consent
Please
be aware that, according to laws and regulations, in the following cases, your
personal information does not need to be authorized and agreed in advance:
Directly
related to national security and national defense security;
To
respond to public health emergencies;
Directly
related to criminal investigation, prosecution, trial and execution of
judgments; Required;
In
an emergency, it is necessary to protect the life, health and property safety
of natural persons, such as to protect your or other personal life, property
and other major legal rights but it is difficult to obtain your consent;
Personal
information is your own It is disclosed to the public or collected from legal
and public channels (such as legal news reports, government information
disclosure, etc.);
It
is necessary to sign and perform relevant agreements or other written documents
with you;
To
perform statutory duties or Necessary for statutory obligations.
五、How we store personal information
storage
location
In
accordance with laws and regulations, we store your personal information
collected and generated during domestic operations within the territory of the
People's Republic of China. Currently, we will not transfer your personal
information overseas. However, under the following circumstances, we will
provide your personal information to possible overseas entities after
fulfilling our legal obligations:
1.
Applicable laws clearly stipulate;
2.
Obtain your separate consent;
3.
Necessary for the conclusion and performance of cross-border e-commerce
transactions and other types of contracts where you are a party. In view of the
above situations, we will protect the security of your personal information
according to this policy.
Storage
period
We
keep your personal information for the shortest period necessary to provide you
with products and services, for example: when you use our registration and
membership functions, we need to collect your mobile phone number, and after
you provide it and During your use of this function,
we need to keep your mobile phone number in order to provide you with this
function normally and protect your account and system security.
We
judge the storage period of personal information mainly by reference to the
following standards and whichever is longer:
To
complete the transaction purpose related to you, maintain the corresponding
transaction and business records, in order to respond to your possible
inquiries or complaints;
To
ensure that we provide you with products / The safety and quality of services;
Do
you agree to a longer retention period;
Whether
there are other special agreements on retention periods;
The
necessary period stipulated by law (for example, the "E-Commerce Law"
stipulates: the storage time of commodity and service information, transaction
information since the transaction not less than three years from the date of
completion).
After
the above-mentioned storage period is exceeded, we will delete or anonymize
your personal information, unless it complies with the "Exceptions to
Authorization and Consent" in Section 4 of Article 4.
六、How we protect your personal information
We
have adopted industry-standard security measures to protect the personal
information you provide to prevent unauthorized access, public disclosure, use,
modification, damage or loss of personal information. We will take all
reasonable and feasible measures to protect your personal information.
After
an unfortunate personal information security incident occurs, we will promptly
inform you in accordance with the requirements of laws and regulations: the
basic situation and possible impact of the security incident, the disposal
measures we have taken or will take, and the measures that you can
independently prevent and reduce risks. Suggestions, remedies for you, etc. We
will promptly inform you of the event-related situation by email, SMS, APP
pop-up window, APP notification bar message push, etc. When it is difficult to
notify the subject of personal information one by one, we will issue an
announcement in a reasonable and effective manner. At the same time, we will
also actively report the handling of personal information security incidents in
accordance with the requirements of the regulatory authorities.
七、How to manage your personal information
access
and update
We
encourage you to update and revise your information to make it more accurate
and current. We will take appropriate actions to set up, guide or provide
contact channels for submitting applications, and try our best to ensure that
you can access, update and correct your own information or other information
provided when using XCEED.
If
you would like to access, update and correct some of your information, you can
review and change your account profile information by logging into your
personal account and visiting your account settings page. You can also contact
us through the contact information published in Article 10 "How to Contact
Us" of this policy. Unless otherwise stipulated by laws and
regulations, when you correct your personal information, we may not immediately
correct or delete the corresponding information from the backup system, but we
will correct or delete the information when the backup is updated.
Change
the scope of your authorization or withdraw your authorization
You
can change the scope of your authorization to continue collecting personal
information or withdraw your authorization by deleting information, turning off
device functions, etc. You can withdraw all authorization for us to continue
collecting your personal information by canceling your account. Please
understand that each business function requires some basic personal information
to complete. After you withdraw your consent or authorization, we cannot
continue to provide you with the services corresponding to the withdrawal of
your consent or authorization, and we will no longer process your personal
information. However, your decision to withdraw your consent or authorization
will not affect the previous collection, processing and use of information based
on your authorization.
Cancellation
and deletion
We
provide you with the functions of canceling and deleting the registered
account. You can log in to your personal account, visit your account settings
page, and delete your account by yourself if you comply with the conditions
stipulated in the service agreement and the relevant national laws and
regulations. When your account is logged in, the path to cancel the account is:
My – Personal Information - Delete account. You can also delete your account by
submitting a request to customer service email: info@xceed.com.
In
the following situations, you can request us to delete personal information:
If
our processing of personal information violates laws and regulations;
If
we collect and use your personal information without your consent;
If
we process personal information Violation of the agreement with you;
If
you no longer use our products/services, or you cancel your account;
If
we no longer provide you with products/services.
If
we decide to respond to your deletion request, we will also notify the entities
that obtained your personal information from us as much as possible and request
them to delete them in a timely manner, unless laws and regulations provide
otherwise, or these entities obtain your independent authorization. When you
or we assist you to delete relevant information, we may not be able to delete
the corresponding information from the backup system immediately due to
applicable laws, regulations and security technologies, and we will safely
store your personal information and will not further process it processing
until the backup can be purged or anonymized.
Constrained
Information System Automatic Decision-Making
In
some business functions, we may only make decisions based on non-manual
automatic decision-making mechanisms including information systems and
algorithms. If these decisions significantly affect your legal rights, you have
the right to request an explanation from us, and we will also provide
appropriate remedies.
In
response to your above request
We
take your every request very seriously. At the same time, you understand and
agree that under the circumstances of Section 4 "Exceptions to
Authorization and Consent" in Article 4, we may not be able to respond
to your request in a timely manner.
八、protection of minors
XCEED's
products/services are not intended to be used exclusively by minors. Minors
should obtain the consent of their guardians before using our
products/services. If you are a minor, before using our products/services, you
should read this policy together under the guardianship and guidance of your
guardian, and use our products/services and submit personal information with
the guardian's explicit consent and guidance. We protect the personal
information of minors in accordance with the relevant national laws and
regulations, and will only process the personal information of minors when laws
and regulations permit and the guardian expressly agrees.
If
you are the guardian of a minor, when you have any questions about the personal
information of the minor under your guardianship, you can communicate with us
through the contact information published in Article 10 of this policy
"How to Contact Us". If we find that we have collected personal
information of minors without the prior consent of a verifiable guardian, we
will delete the relevant personal information as soon as possible.
九、Revisions and Updates to this Policy
In
order to provide you with better services, we may revise the terms of this
policy in a timely manner according to the update of XCEED's products/services
and the relevant requirements of laws and regulations, and publish any
amendments to this policy on this page, and such amendments constitute this
policy a part of. For major changes, we will also provide more prominent
notifications (including emails, text messages, APP pop-up windows, APP
notification bar message push or other methods). Major changes referred to
in this policy include, but are not limited to:
Significant
changes to our service model, such as the purpose of processing personal
information, the type of personal information processed, how the personal
information is used, etc.;
We
have undergone significant changes in the ownership structure, such as changes
in owners caused by business adjustments, bankruptcy mergers, etc.;
Major
changes in the main objects of personal information sharing, transfer or public
disclosure;
Major
changes in your rights to participate in personal information processing and
how to exercise them;
We
are responsible for processing personal information when there are major
changes in the security responsible department, contact information and
complaint channels;
When
the personal information security impact assessment report indicates that there
is a high risk;
Other
important or possible serious impact on your personal rights and interests
occurs.
If
you do not agree to such changes, you can choose to stop using XCEED services;
if you continue to use XCEED services, it means that you have fully read,
understood and agreed to be bound by the revised policy. With any revision we
make your satisfaction a top priority. We encourage you to review this policy
each time you use XCEED services.
We
may issue service-related announcements when necessary (for example, when we
suspend, change, or terminate a service due to system maintenance). If you do
not want to continue to receive the messages we push, you can ask us to stop
the push, for example: ask us to stop sending promotional text messages
according to the SMS unsubscribe guidelines, or set the mobile device to no
longer receive the messages we push; but except for the cases where we send
messages according to legal regulations or service agreements.
十、How to contact us
If
you have any questions, comments, suggestions or complaints about our privacy
policy and the handling of your personal information, please contact us through
the following methods. We will reply to you as soon as possible after receiving
your comments and suggestions and within 15 working days after verifying your
user identity.
Contact
email：info@xceed.com
十一、Effectiveness of the Privacy Policy
This
policy version was updated on December 01, 2023，come into effect on December 20,
2023.