Focodesign Privacy Policies

Your esteemed Focodesign users:

Welcome to use Focodesign. Since we attach great importance to protect the privacy and personal information of our users, please carefully read the privacy polices and make sure to have fully understood the rules of Focodesign (hereafter called “we”, “platform” or “Focodesign”) in terms of gaining and using your personal information. Please contact us for any doubts rising in the process; if you keep using our products and/or service after registering or we update the privacy polices (we will prompt you the updated situation in a timely manner), that means you have agreed with the privacy policies and the updated content as the supplementary to “Focodesign Users Service Agreement”, moreover, you have agreed to authorize us to collect, use, preserve ad share your relevant information in accordance with the privacy policies.

The privacy policies (“the policies”) aim at explaining that you are supposed to understand the following content when using Focodesign:

I.How do we collect and use your personal information

II..How do we use Cookie and technologies of such kind

III.How do we share, transfer and publicly disclose your personal information

IV.How do we protect your personal information

V.How do you manage your personal information

VI.How do we deal with the personal information of juveniles

VII.How is your personal information transferred around the globe

VIII.How are the policies updated and noticed

IX.How do you contact us

Since we attach great importance to your right of privacy related to personal information and we are also committed to maintaining your trust to us, we promise to protect your personal information by taking corresponding protective measures in accordance with the mature safety standards in the industry.

Please carefully read and understand such policies before using our products and service

I. How do we collect and use your personal information

We will collect and use your personal information for the following purposes in the policies:

(I)Users’ registering

When you start using Focodesign platform and relevant service, we suggest you to register a Focodesign account so that you may completely experience all the functions of Focodesign. In the process, we are able to complete the registering procedure by relying on the third-party channels (Facebook, Google) and authorize the third-party channels to provide us with the information from the third-party network, including account, nickname, head portrait, registering time and so on. But you don’t have to register Focodesign account and provide the above information if you just want to browse website content and enjoy the basic service as making videos.

If you provide the following additional information to complete your account information, it will help us provide you with more personalized products or services: birthday, industry category, occupation. The provision of the above information will only affect your use of personalized products or services, and will not affect your use of basic browsing, searching, drawing, ordering and other functions of Focodesign.

If you need to modify your avatar, we will ask you to agree to access your photo album or authorize the camera to take pictures to add as your avatar.

(II)Display of templates information

In order to further improve our platform functions and relevant service, as well as provide personalized information display and promotion service, we will display and promote information based on the above features in accordance with your browsing records, using records, collection records, device information, location and so on after abstracting your browsing and using preferences.

(III)Template Making and Usage

1. Album Authority: In order to add the pictures or videos in your mobile album into Focodesign, we will read multi-media files in your album; after the template is completed, this authority can be used to save your finished products of design in the album.

2. Camera Authority: For the convenience of shooting the pictures or videos that you need and adding them into Focodesign, we ask you to turn on your camera authority.

3. Microphone Authority: If you need to use the function of “recording” in the tools of “video editing”, we will visit your microphone.

(If you refuse to provide the authorization of the above-mentioned three authorities, relevant functions will be not available, but your normal use of Focodesign’s other functions will not be affected. )

4. Content Uploaded: We will store the pictures and videos loaded by you and written messages entered by you for your convenience of reuse. In addition, we will not use them for other purposes.

5. Record of Graphing: We will store the final finished product of your design for your review. In addition, we will not use it for other purposes.

(IV)Search

When you use the search service of Focodesign, we will collect the keyword information that you searched and log record. In order to provide you with efficient search service, some of the above-mentioned messages will be temporarily saved in your local storage device, and the content of search results and search history will be presented to you.

(V)Purchase of products and services

When you register the member of Focodesign or purchase the products or services provided by Focodesign (if any), we will generate your purchase order which clearly states the product or service information, payment amount and time of purchase through the system. The reason why we collect this necessary information is to help you successfully complete transaction, guarantee your transaction safety and facilitate your query of order information.

(VI)Safe operation

We will possibly use or integrate your account information, trade information, device information, log information and so on to comprehensively judge the trading risks within your account, carry out identity verification, inspect and prevent safety issues and take necessary recording, auditing, analyzing and disposing measures according to the laws in order to enhance the safety level of the service provided by Focodesign platform, protect the personal and property safety of you, other users or the public from being damaged, prevent safety risks from the relevant phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusion, etc and more accurately identify the situations breaching relevant laws and regulations and the relevant agreements of Focodesign.

1. Device information: we may receive and record the relevant device information that you have used (such as device model, version of operational system, device settings, the software and hardware features information including unique device identifier and so on), relevant location information of the device (such as IP location), which is made in accordance with the specific rights authorized by you in the installation and using process on the platform.

2. Log information: when you use the products or service provided by Focodesign, we will automatically collect the detailed using situation of our service and preserve it as the network log, such as your edition time, downloading time, using situation, browsing situation,Results graph.

Please note that it is impossible for the single device information, log information and so on to identify the specific natural person’s information. If such kind of non-personal information is combined with other information for identifying the specific natural person’s identity or it is combined with personal information, such non-personal information will be regarded as personal information in this regard.

(VII)Improvement of the necessary functions of our platform and/or service

In order to provide you with better experience, we are committed to constantly improving our service, so in the process, we will possibly collect the information about your template browsing situation, its usage and other data for further analysis and forming user’s portrait, which is conductive to understanding the service demands of users. We will also be likely to obtain other information related to you due to the reasonable demands of us to provide better service and enhance service quality, including the information you have provided to the service personnel of us during communication, the questionnaire reply information provided to us when you are engaged in questionnaire survey and the information we have obtained when you interact with the relevant parties of us, as well as our cooperative partners. In terms of the information we have obtained from various devices of yours, we will connect them so that we are able to provide service which is in line with your demands. We are likely to integrate the information from one service item with other service items so that we are able to provide you with service, customized content and suggestions.

(VIII)Other usages

We will ask for your permission in advance if we are planning to use the information for other purposes not specified in the policies or adopt the information collected for some specific purposes in the situations beyond the original purposes.

(IX)Exception of obtaining authorization and consent

According to the stipulations of relevant laws and regulations, we don’t have to obtain your authorization and consent before collecting your personal information in the following situations:

1.Matters related to national safety and national defense;

2.Matters related to public safety, public health, major public interests;

3.Matters related criminal investigation, prosecution, trial and judgment enforcement and so on;

4.The situations in which it is hard to obtain your consent in advance before taking actions to protect the major legal interests of the individual or others, including life safety and property safety;

5.The personal information we have collected that has already been disclosed to the public by yourself;

6.The personal information collected from those varieties which have been disclosed to the public legally, such as legal news reports, disclosed information of the government and so on.

7.The information that is necessary for singing contracts according to your demands;

8.The information that is necessary to maintain the safe and stable operation of the products and service we have provided, such as guarantee to find out and dispose products and services;

9.Other situations stipulated by laws and regulations.

Please understand that the functions of products and services provided by us are constantly updating and developing. If one specific function or service collects your information not in accordance with the situations mentioned above, we will inform you by page prompts, interaction process, website announcement and other means and explain to you about the content of the information collected, range and purpose, which is to obtain your consent accordingly. If the Focodesign platform or service is stopped, we will also stop collecting your personal information in a timely manner and the notice will be sent to you respectively or in announcement. Finally, all the personal information we have kept will be deleted or disposed in anonymous state.

II.How do we use Cookie and technologies of such kind

In order to ensure the normal operation of the platform, we will store the small-data files by the name of cookie in your computer or mobile devices. The cookie usually contains the identifier, site name, some numbers and characters. By relying on the cookie, our platform can store your preferences and other data so that it is possible for us to avoid some repeated information and other complex content related to history research; meanwhile, we can also use the above technologies to recommend, display, promote content that you are interested in. You may manage or delete the cookie according to your preferences, but please note that you may not be able to enjoy the best service experience if you stop using the cookie.

Except for the cookie, we will also use the technologies of same kind in Focodesign and they can be managed by you through browser or revised by contacting us.

III. How do we share, transfer and publicly disclose your personal information

(I)Sharing

We will never share your personal information with the companies, organizations and individuals beyond the service provider of Focodesign platform, but the following cases are exceptions:

1.Sharing on the premise of obtaining clear consent: we will share your personal information with other parties after obtaining your clear consent.

2.Sharing in legal situations: we will be like to share your personal information with other relevant parties according to the stipulations of laws and regulations, the needs to solve litigation disputes or the legal demands proposed by the relevant administrative and judicial organs.

3.Sharing with Authorized Partner

We may authorize the authorized partners of the below types to provide you with relevant services or perform functions on behalf of us. We will only share your information in line with the legal, rightful, necessary, specific and clear purposes stated in this privacy policy, and authorized partners can only be exposed to the information required for their performance of duties and are not allowed to use this information for other purposes.

Currently, our authorized partners include the following types for the following authorization purposes:

(1)Specific Function. When software providers, smart equipment providers or system service providers cooperate with us to provide your with services, such as authentication service, short message service and so on, we will collect the information of your relevant equipment (such as model number of hardware, version number of operating system, IMEI and MAC), and provide them to the above-mentioned providers after de-identification.

(2)Advertising Pushing. We may share information with the partners which entrust us to promote and launch advertising; instead of the information used to identify your personal identity such as your name, phone number and so on, we will only provide the user portrait label and statistical information after de-identification or anonymization which can hardly identify your personal identity, so as to increase the effective rate of sending advertising under the premise of not identifying your personal identity.

(3)Product Analysis. In order to analyze the condition of using our services and improve users’ use experience, we will share the statistical information of the condition of using products (breakdown and crash) which can hardly identify your personal identity by combining with other information.

(II)Transfer

We will never transfer your personal information to any companies, organizations and individuals except for the following cases:

1.We will transfer your personal information to other parties on the premise of obtaining your clear consent;

2.If personal information transfer is associated during merger, acquisition or bankruptcy liquidation, we will demand the new companies and organizations holding your personal information to accept the privacy policies continuously, otherwise, we will require the companies and organizations to ask for your authorization and consent again.

(III)Public disclosure

We will publicly disclose your personal information in the following cases:

1.After obtaining your clear consent;

2.Legal disclosure: we will be like to publicly disclose your personal information in the situation that the relevant laws, legal procedures, litigation or government authorities have strongly demanded for such information disclosure.

(IV)Exceptions to obtaining prior consent when sharing, transferring, or publicly disclosing personal information

In the following situations, sharing, transferring, and publicly disclosing your personal information does not require your prior consent:

1. Related to national security and national defense security;

2. Related to public safety, public health, and major public interests;

3. Related to judicial or administrative law enforcement such as crime investigation, prosecution, trial and judgment enforcement;

4. It is difficult to obtain the consent of the individual in order to protect your or other individuals' important legal rights and interests;

5. Personal information that you disclose to the public;

6. Collection of personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

IV. How do we protect your personal information

1.We have already adopted safety measures to protect your personal information which are in line with the standards in the industry to prevent the relevant data from being visited without authorization, publicly disclosed, used, revised, damaged or lost. Moreover, we will adopt all the reasonable measures to protect your personal information, for example, we provide Focodesign platform with HTTPS protocol security browsing mode; we will use encryption technology to ensure the confidentiality of the data; we will use reliable protective mechanism to prevent the data from being maliciously attacked; we will deploy visit control mechanism to ensure that only the authorized personnel can visit the personal information; moreover, we will hold training classes for safety and privacy protection, which is to strengthen the consciousness of the employees on the importance of personal information protection.

2.We will take every possible and reasonable measures to avoid collecting the irrelevant personal information and we will just keep your personal information within the duration and for the purposes mentioned in the polices agreement except for duration extension or legal permission.

3.Since Internet is not the absolutely-safe environment and email, instant messaging APP and other communication ways with other users are not encrypted at all, we strongly suggest you not to send your personal information by such means. It is required that you may use complex codes to assist us in account safety protection.

4.Unfortunately, in the cases that your personal information has been disclosed, we will inform you according to the requirements of laws and regulations: the basic situations of the safety case and its possible effects, the countermeasures taken and to be taken by us, suggestions you may take to autonomously prevent and reduce risks, the remedies you can take and so on. In terms of the relevant situation of the event, we will inform you by email, letter, tel, promotional notice and so on. If it is impossible for us to inform the subjects of personal information, we may release an announcement in reasonable and effective ways. At the same time, we will also report the disposal situation of the safety events related to personal information according to the requirements of supervision department.

V. How do you manage your personal information

(I)Visiting, revising and correcting your personal information

You can choose to visit, revise, and delete the registration information and other personal information you have provided when using Focodesign platform and enjoying its service. If you find out that the data collected by us is not complete or incorrect, you may tell us to revise. If it is impossible for you to take the above measures or you have any doubts, you may contact us for further solutions according to the contact information of us.

(II)Deleting your personal information

Under the following circumstance, you can ask us to delete your personal information:

1.If our behavior of dealing with personal information violates laws and regulates;

2. If we collect and use your personal information without your permission;

3. If our behavior of dealing with your personal information violates the agreement with you;

4. If you cancel the account of Focodesign;

5. If we terminate service and operation

If we decide to respond to your request for deletion, we will inform the third parties which obtain your personal information from us of deleting your personal information timely unless otherwise required by laws and regulations or when these third parties have obtained your authorization. When your personal information is deleted from our services, we may delete the information when the backups are updated instead of immediately deleting corresponding information in the backup system.

(III)The range allowed to cancel your authorization and consent

For each service function, some basic personal information may be required. Additionally, if you hope to cancel the consent for us to collect, use and disclose other personal information, you may contact us and cancel your authorization and consent accordingly.

After your consent is canceled, we will stop disposing your personal information. But your decision to cancel the consent will not affect the disposal of personal information carried out based on your relevant authorization.

(IV)Transferring and taking your personal information

You can require us to provide the structured, generalized and machine-readable personal information on the premise that automatic treatment and technical operation are possible. Then, you are able to transfer the obtained data to other data controllers, but you are supposed to keep your transferred and obtained data properly and cautiously.

(V)Objection to allow us to dispose your personal data

You have the right to object us to dispose your personal data for direct profiting and other special circumstances, such as religion, race and so on and we will stop disposing the relevant personal information after receiving your notice.

(VI)Cancellation of account

You may cancel the account by yourself or submit relevant application of cancellation, then we will stop providing products or services for you, furthermore, your personal information will be deleted or disposed in anonymous state according to the requirements of applicable laws.

(VII)Other rights

In your country, maybe some specific rights beyond the above-mentioned rights will be granted to dispose your personal information. If you have some proposals in terms of your personal information, you may contact us.

(VIII)Response to your above-mentioned requirements

To ensure your information safety, you will possibly be required to provide written applications or prove your identity in other ways. We may require to verify your identity firstly and dispose your requirements afterwards.

In terms of your reasonable request, we charge no fees in principle, but for the repeated requests beyond the reasonable limit, we will charge the fees as cost of service according to the situations. But for the requests which are repeated for no reasons, require excessive technical means (for example, it is required to develop new system or the current conventions should be changed in root), bring risks for the legal rights and interests of other or have no practical foundations, we are very likely to reject them.

In the following cases, we can not respond to your requests according to the requirements of relevant laws and regulations:

1. Matters related to national safety and national defense;

2. Matters related to public safety, public health, major public interests;

3. Matters related criminal investigation, prosecution, trial and judgment;

4. There is adequate evidence showing that the subject of personal information has subjective malice or abuse of rights;

5.The legal rights and interests of yours or other individuals and organizations will be seriously damaged if your request is responded;

6.The matter that is related to business secrets.

VI. How do we deal with the personal information of juveniles

Focodesign will never collect or obtain the personal information of juveniles under 18 years old on purpose and our service and content are not for children below 18 years old. Without the consent of parents or the guardians, juveniles are not allowed to establish their own account. If you are juveniles, we suggest you to let your parents or the guardians to read the privacy policies carefully, use our service or provide us with relevant information on the premise of obtaining the consent of your parents or the guardians.

We will delete the information as soon as possible if it is collected from the juveniles without the consent of their parents or the guardians; for the situation that the personal information of juveniles is collected with the consent of their parents or the guardians in terms of using our products or service, we will just use, share, transfer or disclose such information in the necessary situations with permission of relevant laws and regulations, consent from their parents or the guardians or the purpose of protecting the juveniles.

VII. How is your personal information transferred around the globe

We provide our products or services for you by relying on the resources and servers distributed all around the globe, that means your personal information may be transferred to the overseas jurisdictions in the countries/regions where you will use such products or services or it will be visited by such jurisdictions, which is based on your authorization and consent.

Such category of jurisdictions may have different data protection laws and even have no relevant laws. In such situation, we will ensure that your personal information will be protected equally as within the country you are located. For example, we will ask for your consent on personal information cross-border transfer or take safety measures such as data de-labeling and so on before cross-border data transfer.

For those users within the European Economic Zone, we will transfer your personal information to the third-party suppliers beyond the European Economic Zone and sign relevant standardized contract with them, as well as provide proper protective measures for your information. We are more likely to ask for your consent from time to time so that we will be able to transfer your personal information to the third country beyond European Economic Zone.

VIII. Revision and Notice of Privacy Policy

(I) In order to provide you with better service, Focodesign and relevant services will be updated and changed from time to time, and we will revise this privacy policy timely, which constitutes a part of this privacy policy and has the same effect as this privacy policy. Without your permission, we will not cut off the rights that you should enjoy according to the currently effective privacy policy.

(II) After updating this privacy policy, we will launch new version on the mobile client of Focodesign and remind you of the updated content in proper ways such as notice, announcement and so on before the updated clauses become effective, so that you can timely understand the latest version of this privacy policy. If you continue using our service and agree to receive the content of the revised policy, your permission will be asked for in a prominent way when the updated content needs to collect new personal sensitive information.

(III) For major alternation, we will provide more prominent notice (for example, we will inform you of the specific content of the alternation of the privacy policy by email)

1. Our service mode is changed significantly such as purpose of dealing with personal information, types of personal information that we deal with and usage mode of personal information;

2. Our ownership structure and organizational structure are changed significantly, such as ownership change caused by business adjustment, bankruptcy, merger and acquisition;

3. Main objects of sharing, transferring or disclosing personal information in public are changed significantly

4. Rights that you participate in personal information processing and ways of exercising rights are changed greatly;

5. The department in charge of dealing with personal information security, contact ways and compliant channels are changed;

6. The evaluation report of personal information security influence indicates that there are high risks. We will keep the old version of this policy on archives for your review.

IX. How do you contact us

(I) If you have any problems, advice or suggestions on the matters related to the privacy policies or your personal information, please send email to support@focodesign.com and contact us any time you want.

(II) We will check the problems involved as soon as possible and deal with these problems after authentication within 15 days at most or make response within the time limit stipulated by laws and regulations