Privacy Policy
This privacy policy is closely related to your personal information and your use of our website, products or services. Please read it carefully and make proper choices using your own good judgment!
Lysora Technology Inc. and its subsidiaries (“Lysora” or “We”) are fully aware of the importance of personal information to you, and are committed to respecting and protecting your privacy. To this end, we will make every effort to protect the security and reliability of your personal information, and regard this duty as the core of our business development and as a part of our social responsibilities and obligations. Before you access or use our website, products or services, please read and understand this Privacy Policy (this “Policy”). This Policy is applicable to Lysora’s website, products, services or business activities with this Policy shown or a link to this Policy. If you have any questions, comments or suggestions, please contact us via any of the means below: e-mail: [ marketing@lysoratech.com].
This Policy describes how we collect, use, store, share and process your personal information and other content when you access or use our website, products or services, as well as the way we provide for you to access, update, control and protect your information, but this Policy might not have covered all possible data processing scenarios. The information collection policy on product- or service-specific data may be published by Lysora in supplementary policies, subsequent updates to this Policy, policy statements accompanied to products or services, or notifications provided specifically when data are collected. For residents from the European Economic Area (“EEA”) or the UK, please also refer to our EEA/UK Specific Terms for additional terms that will apply to the processing of personal data relating to you.
This Policy will help you understand the following:
I. What Personal Information We Collect About You
II. What Personal Information About You Do We Receive From Third Parties
III. How We Use Cookies and Similar Technologies
V. How to Access or Modify Your Personal Information
VI. How We Protect Your Personal Information
VII. How We Process Children’s Personal Information
VIII. Exceptions to the Application of this Policy
IX. How Your Personal Information is Transferred Globally
XI. How to Get in Touch with Us
- What Personal Information We Collect About You
On our website, you can ask for help, register to request for materials, or join the community to participate in our activities; you can also obtain performance support you may need via our related products or services to meet your business and daily needs. We need to collect some information for providing you with certain business functions. If you choose to use this business function, you need to provide us or allow us to collect the necessary information, including general personal information (including your name, phone number, and e-mail，company name); network identification information (including system account number, devices and topology, IP address, e-mail address and password, passphrase, and passphrase-protected key related to the foregoing); personal browsing history (referring to user operation records stored in logs, including website browsing history, software use history, and click history); frequently used personal device information (including hardware and software serial number, device MAC address, software list, and unique device identification code); specific personal location information (including country 、 region、 address ) ;user experience feedback, such as any feedback you provide about the use of our products and services, purchase requirements, comments, and satisfaction depending on what you actually provide or what we actually collect.
If more information needs to be collected from you during the service process, we will explain the reason to you and collect it after obtaining your consent.
- What Personal Information About You Do We Receive From Third Parties
Sometimes, we receive information about you from third parties; in particular, we may receive information about you from business partners and third parties where you have been referred by them. The information we collect from such third parties include:
- [your contact information and information related to your profile, when you interact with us on social media platforms such as [Facebook, LinkedIn, and YouTube] (depending on your privacy preferences on those platforms)];
- [usage and technical information through cookies and related tracking technologies, such as Web Dissector Analytics (please see our Cookie Notice for more details)].
- How We Use Cookies and Similar Technologies
Our site uses cookies or similar technologies (e.g. web beacons). A “cookie” is a small file of letters and numbers that is sent to your computer by a website and automatically saved on your computer by your web browser (e.g. “Internet Explorer”). Each time you request a page from the website, your web browser sends this cookie back to the website server. Please check our Cookie Notice for further details.
- How We Collect and Use, Entrust Other to Process, Share, Transfer, and Publicly Disclose Your Personal Information
(1) Purposes for collecting and using personal information
We may collect and use your personal information for the purposes described below:
1. Registering for a login account.
When you register as a normal user, you need to provide us with your email address. We will verify your identity by sending an verification code. Your account name is your email address. You can also contact us by email to modify or add your information，including your name, mobile phone number, country of residence, and company name, all of which are classified as your “account information.”
Your supplementary account information will help us provide you with personalized services. In addition to the mandatory information required by the system, you may provide any further information you would like to provide. If you wish to become our partner, please follow the tips we give you regarding how to choose the operation steps that are suitable for you and register for the relevant account. If you are visiting our website or using our products or services on behalf of your organization or other entity that authorizes you to do so, please make sure that you have obtained full authorization from the entity before performing related operations.
2. Providing you with general services:
(1) Responding to your transaction or service requests, including fulfilling orders; delivering, activating or verifying products or services; after-sales service;
(2) Providing training and certification, and managing and handling training and certification results;
(3) Asking or reminding you to participate in online or offline activities;
(4) Providing you with the information you request (such as marketing materials, white papers for products or services);
(5) Synchronizing, sharing and storing the data you upload or download and the data required to perform the upload and download; and
(6) Providing other general services such as technical support.
3. Sending you e-mails, messages or announcements for providing personalized services:
(1) Promotional services: sending you information about products and services that you may be interested in; inviting you to participate in Lysora’s activities, market surveys or satisfaction surveys; or sending you marketing messages; providing you with a personalized user experience and personalized information; collecting relevant information for purposes of data analysis and research, understanding the effectiveness of our business operations, improving our products and services, and maintaining and enhancing the security of websites, products, and services.
(2) Key notifications such as updates: such as notifications of operating system or application updates and installations.
(3) Certifying and managing business partners, communicating or conducting business with business partners; and
(4) Other personalized services.
4. Abiding by and enforcing applicable laws, regulations, standards and policies.
(2) Entrusted processing
Some certain modules or functions we provide to you may be provided by third-party service providers. For example, we may hire a service provider to assist us in providing customer support.
We will sign strict confidentiality agreements with all companies, organizations and individuals with whom we entrusted the processing of personal information, and will require them to process personal information in accordance with our requirements, and any other related confidentiality and security measures.
(3) Sharing
1. We may share your personal information with third parties such as our affiliates and partners (to ensure the smooth completion of services provided to you). However, we will only share personal information that is necessary, and such sharing is restricted to the purpose stated in this Policy. If our affiliates intend to change the purpose of processing personal information, we will ask for your further consent where required under applicable law, and sign strict confidentiality agreements with them.
2. We will not share your personal information with any company, organization or individual other than Lysora without your consent or authorization where required under applicable law, but we may share your personal information under the circumstances below:
(1) We may provide information in order to comply with applicable laws and regulations;
(2) We may provide information in order to comply with judicial rulings or other legal processes;
(3) We may provide information in order to comply with the requirements of administrative authorities or other legally authorized organizations;
(4) We may provide information for the purpose of “collecting and using personal information”;
(5) We may provide necessary information in order to protect the public interests, or to protect the personal and property safety or legal rights and interests of us, our affiliates or partners, you or other users of us to the extent permitted by law.
(6) Other circumstances permitted by laws and regulations or agreed in this Policy.
(4) Transfer
We will not transfer your personal information to any company, organization or individual without your consent or authorization, except as follows:
1. We may transfer information in order to comply with applicable laws and regulations, judicial rulings or other legal processes, or the requirements of administrative authorities or other legally authorized organizations;
2. When we are in a process of merger, acquisition, asset transfer, bankruptcy liquidation or similar transaction, and if such process involves a transfer of your personal information, we will require the new company or organization that will take hold of your personal information to continue to be bound by this Policy, otherwise we will require this company or organization to ask for your further consent.
(5) Public disclosure
We will publicly disclose your personal information only under the circumstances below, and provided that we have taken industry-standard security measures:
1. Where we have obtained your explicit consent; or
2. Where we are required to publicly disclose your personal information according to the law, legal proceedings, litigation or mandatory requirements of the competent government departments. We will limit the disclosure to the minimum extent reasonably possible by upholding the principle of prudence.
For legal basis of processing personal data relating to residents from the European Economic Area (“EEA”) or the UK, please also refer to our EEA/UK Specific Terms.
- How to Access or Modify Your Personal Information
First of all, you shall ensure that all personal information provided to us is accurate and that you shall properly keep your account number, password and other information. Then, we will make every effort to maintain the accuracy and completeness of your personal information, and timely update the data according to the information you provide.
To the extent permitted by the law, you may have the right to access, update or correct your personal information; remove your personal information; and change the scope of your authorization and consent.
To exercise these rights, you can give your feedback to us. Your written request may be required for security. We may decline the request if we have reasonable grounds to believe that your request is fraudulent, unfeasible or may jeopardize the privacy of others.
If allowed by applicable laws, you also have the right to withdraw your consent at any time when we process your personal information based on your consent. However, your withdrawal does not affect the legitimacy and effectiveness of how we process your personal information based on your consent before the withdrawal is made; nor does it affect any information processing based on any justification other than your consent.
We do not charge any cost for your reasonable request in principle, but we will charge a certain cost for repeated requests that exceed a reasonable limit. We may reject requests that are unreasonably repeated, require too many technical mechanisms (e.g., the need to develop new systems or radically change existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical (e.g., involving backing up information stored on a magnetic tape).
In the following circumstances, we will not be able to respond to your requests:
(1) Related to the fulfillment of obligations by the controller of personal information according to any law and regulation;
(2) Directly related to national security and national defense safety;
(3) Directly related to public safety, public health and major public interests;
(4) Directly related to crime investigation, prosecution, trial and execution of judgments;
(5) The controller of personal information has sufficient evidence to believe that the subject of personal information harbored subjective malice or committed abuse of rights.
(6) For the purpose of protecting the life, property and other major legitimate rights and interests of the subject of personal information or other individuals where the consent is difficult to obtain;
(7) Responding to the request of the subject of personal information will cause serious damage to the legitimate rights and interests of the subject of personal information or other individuals and organizations;
(8) Involving trade secrets.
If you think that the way we process your personal information does not comply with applicable data protection laws, please contact us.
For rights of data subjects from the EEA/UK, please refer to our EEA/UK specific terms.
- How We Protect Your Personal Information
We have used industry-standard security measures to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and feasible measures to protect your personal information. We will retain your personal information for no longer than is necessary for the purposes or objectives stated in this Policy, unless extension of the retention period is required or permitted by the law.
- How We Process Children’s Personal Information
Our websites, products and services are primarily intended for adults. A child must not create a user account without parental or guardian consent. We do not knowingly collect or solicit personal information from children under the age of 16. If you are a child, when registering your name, address, phone number, or other personal information, or when purchasing at our website, make sure that one of your parents or guardians are present. If we find ourselves collecting children’s personal information without having obtained guardian consent, we will take steps to delete the relevant data as soon as possible. Despite different definitions of children in local laws and customs, we will consider anyone under the age of 16 as a child.
- Exceptions to the Application of this Policy
For the sake of better service experience, you may receive content or web links from third parties other than us (“Third Parties”) through our website. Please note that links from our website to third-party websites are provided to you for convenience only. If you use these links, you will leave our website. These websites may collect personal information about you. We do not endorse, or make any representations, or assume any liability for these websites and any information, software or other products, materials obtained through these websites, or any results from using them. The information protection practices of third-party websites linked to our website are outside the scope of this Policy. Please make your choice carefully!
- How Your Personal Information is Transferred Globally
We maintain servers around the world and your information may be processed on servers located outside of the country where you live. Regardless of where your information is processed, we apply the same protections described in this policy and applicable law. We will also keep this Privacy Policy in compliance with significant legal frameworks relating to the transfer of data.
For data subjects from the People’s Republic of China, in principle, the personal information we collect and produce in the territory of the People’s Republic of China will be stored in the same territory. Since we may provide products or services through resources and servers outside the People’s Republic of China, this means that with your authorization, your personal information may be transferred to, or accessed from, foreign jurisdictions in the country in which you use the products or services. Such jurisdictions may have different data protection laws, or even have not enacted relevant laws. By using our website and solutions, or providing any personal information to us, where the applicable law permits, you acknowledge and agree to the transfer, processing and storage of such information outside your country of residence where data protection standards may be different.
For transfers of personal data from EEA/UK to a third country, please refer to our EEA/UK specific terms.
- Updates to This Policy
This Policy is subject to change. We reserve the right to update or change this Policy at any time. We will post any changes to this Policy on this page. In addition, if any major changes are made to this Policy, we may notify you through different channels, for example, posting a notice on our website or directly sending you a notification by e-mail. However, without your express consent, we will not diminish any of your rights under this Policy.
- How to Get in Touch with Us
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at e-mail: [marketing@lysoratech.com] ，or by writing to [Building 19, Juyuanzhou Industrial Park, No. 618 Jinshan Road, Cangshan District, Fuzhou, Fujian, China]. We have appointed a representative in the EEA, which can be contacted at [add contact details]].
- EEA/UK SPECIFIC TERMS
In addition to our Privacy Policy, the following terms will apply to the processing of personal data of data subjects in the European Economic Area (“EEA”) or the UK.
- LEGAL BASIS OF GDPR FOR PROCESSING YOUR PERSONAL DATA
We process this personal data for the following purposes:
- To fulfil a contract, or take steps linked to a contract: this is relevant where you register an account with us to use our service. This includes:
- verifying your identity;
- communicating with you;
- providing customer services or otherwise, carrying out our obligations arising from any contracts entered into between you and us and to provide with you the information and services you request from us;
- As required by us to conduct our business and pursue our legitimate interests, in particular:
- we will use your information to provide products and services you have requested, and respond to any comments or complaints you may send us;
- we monitor use of our apps, websites and other online services, and use your information to help us monitor, improve and protect our products, content, services and websites;
- we use information you provide to personalise our website, products or services for you;
- we monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
- we use information you provide to investigate any complaints received from you or from others, about our website, apps, or our products or services;
- we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
- we will notify you about changes to our services, where applicable.
- Where you give us consent:
- providing you with information relating to Lysora or promotional details about services that may be of interest to you, as well as marketing mailings (electronic or otherwise) or other communications;
- we place cookies and use similar technologies in accordance with our Cookies Notice and the information provided to you when those technologies are used; and
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
- For purposes which are required by law, such as:
- in response to requests by government or law enforcement authorities conducting an investigation, or to comply with the requirements imposed by applicable law or any court order.
- YOUR RIGHTS RELATING TO YOUR PERSONAL DATA
You are entitled to the following rights (see Art. 15 ff GDPR):
a) right of access to your personal data;
b) right to data portability (i.e. you have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller);
c) right to correction if your personal data is not complete or accurate;
d) right to deletion or restriction of your personal data, as permitted by law;
e) right to object (i.e. objecting to our processing of your personal data) (e.g. in case we process your data for direct marketing purposes) , as permitted by law.
Where we have asked for your consent, you may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your personal data based on the consent you provided before you withdrew it.
These rights are not absolute, they may be limited in some situations. For example, where we can demonstrate that we have a legal requirement to process your data or if making the information available to you would reveal personal data about another person or if we are legally prevented from disclosing such information. In some instances, this may mean that we are able to retain data even if you withdraw your consent.
We hope that we can satisfy any queries you may have about the way we process your data. In the event you still have unresolved concerns, you also have the right to lodge a complaint with a supervisory authority, in particular to the data protection authority in the country of your habitual residence or place of work.
- TRANSFER OF PERSONAL DATA OUTSIDE OF THE EEA/UK
In situations where we transfer your personal data to countries outside of the EEA or the UK to an organisation in a country which is not subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the applicable laws by using the European Commission approved Standard Contractual Clauses, a vendor’s Processor Binding Corporate Rules or by relying on such other data transfer mechanisms as available under applicable data protection laws, and where necessary, by implementing further (organisational/contractual/technical) supplement measures in order to ensure the effectiveness of the transfer mechanisms.
Where we transfer your personal data from EEA/UK to other affiliated entities of the Lysora in China, we use the European Commission approved Standard Contractual Clauses. A copy of the relevant mechanism can be obtained for your review on request by using the contact details stated in How to Get in Touch with Us.