Aurora SendCloud's Privacy Policy

Regardless of the following scenarios for the collection and use of your and/or your end-user's personal information, we will generally only do so with your consent, except in certain circumstances where personal information is collected from you and/or your end-users based on a legal obligation or where it may be necessary to protect your or another person's vital interests.

The purposes, methods, types of personal information, and rules for collecting and processing information about you and your end-users in the course of Aurora SendCloud's provision of services are as follows:

(i)Your personal information as an Aurora SendCloud developer customer (or potential developer customer)

In order to fulfill the business functions of the Platform, we may need to collect and use information about you. Our business functions and the types of information required to fulfill them are described in more detail below, and if you refuse to provide them, you will not be able to use the relevant products and/or services of the Platform.

1.When you register/login to your Aurora SendCloud account, you will need to provide your email address, password to complete the account registration and real name authentication.

2.When you authenticate your business, we collect contact name, contact phone number, organization name, website url, business phone number, business address, and business license, which are used to verify the authenticity of your business information and to ensure that you meet the requirements for using Aurora SendCloud services.

3.When you use our products/services to pay for your order, we will collect your PayPal account number/bank card number/alipay account number/remittance receipt voucher information in order to carry out the payment and settlement, depending on the payment method you choose.

4.You can forward the platform's blogs by our blog function, and we will not collect your personal information when you do so.

5.To facilitate your management of the account, you can enter the platform "Account Settings - Member Management" to set up other members of the account operation and management. You need to add administrator member information, including username, email, setup permissions.

6.When you browse or log in to use our products/services, we will use cookies to store some non-private data, such as: the user's language preference, website skin settings, browser type and version. We will use this cookie information, according to the type and version of the browser, to give friendly product tips. Based on the user's language preference, we will also provide default language support for future visits, saving the user's operation steps and improving the user's browsing experience. It is convenient for you to use our platform services better.

In addition, you understand and consent that, based on the information you provided as described above, we may send you service details, marketing materials, or other information relevant to our products and/or services, along with any other information for which you've given us authorization. You have the option to unsubscribe at any time by following the instructions provided within the marketing message, (e.g., by replying to the message with "Reject Please Reply R" or "Unsubscribe to T") to cancel the operation.

(ii)Your end-user's personal information

When utilizing our email service, you will upload the email addresses of your end-users, along with the content of the messages intended for them, to your account on our platform. These details will be used to send out email messages.

When you toggle open on email tracking, you can learn about the reach of your delivered messages, and we collect data on your end-users' opens, clicks, and unsubscribes to emails, IPs, device brands, browsers, operating systems, and other information.

You know and confirm that when utilizing our email service, we only act as a technical service provider to accept your entrustment to realize the purpose of sending information to your end-users, and you agree that we can entrust our partners to realize the aforementioned purpose. You need to obtain your end-user's prior consent so that you have the right to obtain your end-user's e-mail address or cell phone number and other information that we must collect under the above functional scenarios, and that they agree that you or a third party may be commissioned to send information to them.

(iii)Your personal information that we obtain from third parties

1.We may collect and use your personal information from third parties (our partners) within the scope of your authorized consent. We guarantee that your personal information will be handled in strict accordance with the contract signed with the third party and relevant laws, and please read the privacy policy and user agreement of the third party in detail. If you refuse the collection, use or transfer of your personal information by a third party in connection with the provision of services, you may not be able to use the corresponding services of Aurora SendCloud.

2.We may obtain and appropriately use publicly available information about you through publicly available means, such as web pages, or obtain operational information about your business from third-party providers that has been publicly available to help us better understand our customer base, such as your industry, the size of your business, and the URL of your business's website.

In particular, you are reminded that information that does not individually or in combination with other information identify you and/or your end-users personally is not your and/or your end-users' personal information within the meaning of the law, and that when information about you and/or your end-users identifies you and/or your end-users personally, either individually or in combination with other information, or where we are unable to establish a link to any particular personal information, such information is treated and protected in accordance with this Policy for the duration of the combined use. When data is used in combination with other personal information about you and/or your end-users, such information will be treated and protected as personal information about you and/or your end-users in accordance with this Policy for the duration of the combination.

When you use our services, to ensure the proper functioning of the website, we may store on your computer or mobile device a small data file called a cookie, which usually contains an identifier, the site name, and some numbers and characters. The main function of a cookie is to facilitate your experience of the Platform's products and/or services, as well as to help the website count the number of unique visitors, etc. Using cookie technology, we can tailored design our services and allow you to set your specific service options. Cookies are sent to your device when you use the Platform's products and/or services, and we allow cookies (or other anonymous identifiers) to be sent to our servers when you interact with the services we provide to our partners.

We will not use cookies for any purpose other than those described in this policy. You can manage or delete cookies according to your preferences; you can clear all cookies stored on your computer, and most web browsers have features to block cookies. However, if you do so, you will need to personally change your user settings each time you visit our site, and you may not be able to log in or use Aurora SendCloud services or features that rely on cookies because of such changes.

For more information about the types of cookies we use, why we use them, and how to control them, see AboutCookies.org.

You, as our business partner, are well aware that in order to provide you and/or your end-users with the Aurora SendCloud services you have selected, we collect, store, and process personal information about end-users from your application in a de-identified or anonymized manner; and that you, as the end-user's information controller, are being provided with the data processing services but we do not have any control over how you may use the data that belongs to or about you, or about your end-users. Therefore, by accepting this Policy and integrating our SDK, API or other developer tools into your product, you acknowledge and guarantee that:

1.You have informed the end-user and obtained the end-user's full, necessary and express authorization, consent and permission to allow us to collect and use its information for the purpose of providing the Services.

2.Unless otherwise provided by applicable laws, you have informed the end-user and obtained the end-user's full and necessary authorization, consent and permission to allow us to de-identify the personal information we have collected, and to allow us to use the collected and processed information for the purposes of the services set out in Part I of this Policy, subject to compliance with relevant laws and regulations.

3.You have complied with and will continue to comply with applicable laws, regulations and regulatory requirements, including but not limited to the development and publication of relevant policies regarding the protection of personal information and privacy protection.

4.You have provided end-users with easy-to-use mechanisms for the realization of user rights, explaining how and when users can exercise the right to choose, how to access and correct their personal information, exercise the right to delete, change the scope of their authorized consent and other operations.

(i)Sharing

Except as already described in this policy, information about you and/or your end-users will not be shared in an identifiable form with third parties. The exceptions to this are as follows:

1.Sharing with Explicit Consent. We may share information about you and/or your end-users with other parties with your and/or your end-users' express consent.

2.We may share information about you and/or your end-users in accordance with applicable laws, regulations, legal processes, or governmental requests (including fulfilling national security, emergency service, or law enforcement requests).

3.To the extent required or permitted by law, it is necessary to provide personal information about you and/or your end-users to third parties in order to protect against harm to your interests, property or safety or that of the public.

4.Personal information that you and/or your end-users disclose on their own, or that we are able to obtain from other lawful public sources.

If you refuse to allow our partners to use personal information about you or your end-users that is necessary for the provision of the Services, this may result in you being unable to use the Services provided by the Platform through such partner.

(ii)Transfers

We do not transfer information about you and/or your end-users to any companies, organizations, and individuals, except as follows:

1.With the express consent of you and/or your end-users.

2.Personal information that you and/or your end-users disclose on their own or that we can obtain from other lawful public sources.

In the event of a merger, acquisition or liquidation, which may involve the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this Statement. In the event of any changes to the collection and processing of personal information as agreed in this statement, the company or organization will request your authorization and consent again.

(iii)Public disclosure

Subject to applicable laws and regulations, we will not publicly disclose personal information about you and/or your end-users unless we have your and/or your end-users' express consent.

(i)Storage locations

You acknowledge and agree that we may store your and/or your end-user's personal information, corporate information collected in Singapore. If your use of our services involves data export compliance, you are required to fulfill the legal procedures for data export in accordance with local laws and regulations.

(ii)Storage period

We store your and/or your end-users' personal information only for the purposes described in this policy and for the minimum period required by law or regulation, and we will delete or anonymize your personal information after the storage period has expired. However, we may extend the period of storage of your and/or your end-user's personal information to comply with applicable laws and regulations, for the purposes of defense of lawsuits, to protect the public interest, to protect the safety of personal property, or to protect legal rights.

1.We have used industry standard security measures to protect the information you provide against unauthorized access, disclosure, misuse, alteration, damage or loss of data. We take all practical measures to protect the security of your and/or your end-user data. For example, the exchange of data between your browser and the Service is protected by SSL encryption; we also provide https secure browsing on the Aurora SendCloud website; we use encryption to ensure the confidentiality of data; and we use trusted protection mechanisms to prevent malicious attacks on data; We deploy access control mechanisms to ensure that only authorized personnel have the right to access personal information; and we hold regular training sessions on security and privacy protection to enhance employee awareness of the importance of protecting personal information.

2.We have obtained the following certifications: "Information System Grade Protection Level 2 Certificate" and "ISO 27001 Information Security Management System Certification".

3.Our data security capabilities: build security defense around the data life cycle, covering data collection, transmission, storage, use, circulation, archiving, deletion and other data processing stages.

4.We will take all reasonably practicable steps to ensure that no unrelated personal information is collected. We will only retain information about you and/or your end-users for as long as it is necessary to fulfill the purposes set out in this Privacy Policy, unless an extended retention period is required or permitted by law.

5.The Internet is not an absolutely secure environment, please use complex passwords and change your password regularly to help us ensure the security of your account.

6.The Internet environment is not 100% secure and we will endeavor to ensure or guarantee the security of any information you send to us. Although we have made all necessary and reasonable efforts, there is a risk of theft, unlawful possession or misuse which may result in personal, property and reputational damage to you and your users. You understand these risks and accept them voluntarily.

7.After the unfortunate occurrence of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation of the security incident and its possible impact, the disposal measures that we have taken or will take, the suggestions that you can take on your own to prevent and minimize the risks, and the remedial measures for you. We will promptly inform you of the situation related to the incident by email, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to publish an announcement.

8.We will also take the initiative to report on the handling of personal information security incidents as required by the regulatory authorities.

We attach great importance to the management of personal information by you and/or your end-users and make every effort to protect your rights related to the query, access, modification, deletion, complaint reporting, and setting up of privacy functions of your personal information, in order to safeguard the privacy and information security of you and/or your end-users.

(i)For direct users of Aurora SendCloud (developer customers)

1.Inquire and modify your personal information

You have the right to inquire and modify your personal information, except for the exceptions stipulated by laws and regulations. If you wish to exercise your right to access or change your data, for example, if you wish to access or edit your corporate/personal information, account details, change your password, etc., you can do so after logging in by clicking on the account icon in the upper right-hand corner - Account Settings.

If you are unable to access this personal information through the above methods, you could send an email to us which is listed in Part X. We will do an inquiry and modification for you according to your email. When inquiring or changing the relevant information, we may ask you to authenticate your identity in order to protect the security of your account.

Please understand that some of your requests may not be responded to due to technical limitations, legal and regulatory requirements. Some of your information may be inaccessible due to legal and regulatory requirements, information security and other legitimate reasons.

2.Delete your personal information

In any of the following cases, you may request deletion of the Personal Information by sending an e-mail for Customer Service:

(1)We collect or use personal information in violation of laws and regulations.

(2)We collect or use personal information in violation of our agreement with you.

(3)If we share or transfer personal information to a third party in violation of laws and regulations or in violation of our agreement with you, we will immediately stop the sharing or transfer and notify the third party to delete it promptly.

(4)If we publicly disclose personal information in violation of laws and regulations or our agreement with you, we will immediately stop the public disclosure and issue a notice requesting the relevant recipient to delete the corresponding information.

When deleting the relevant information, we may ask you to verify your identity in order to protect the security of your account. Once the above deletion request is responded to, your personal information will be deleted, except for information that is required to be retained by laws and regulations.

3.Withdrawal of your authorization

Each function often requires the collection of some basic personal information in order to operate, for the collection and use of your personal information, you could send email to us to request withdrawal of consent. When you withdraw your consent, we will no longer collect and use your personal information, but please understand that when you withdraw your consent or authorization, we will not be able to continue to provide you with the specific functions and/or services for which you withdrew your consent or authorization. Your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization.

4.Cancellation of accounts

You may cancel your previously registered account at any time by requesting customer service by email to close and cancel your account. You should be aware that canceling your Aurora SendCloud account will result in you permanently losing access to your account and the data in your account. We will cancel your account after we have verified your identity and disposed of the assets in your account in consultation with you. In order to provide you with a more convenient way to cancel your account, we will continue to optimize our product and inform you of this through a notice on this page. After cancellation of your Aurora SendCloud account, we will stop providing you with products or services and delete or anonymize your personal information as soon as possible upon your request, unless otherwise stipulated by laws and regulations.

5.Obtaining copies of personal information

You could send email to customer service at any time to obtain a copy of your personal information. Where technically feasible, e.g. data interface matching, we may also transfer a copy of your personal information directly to a third party designated by you at your request.

6.Responding to your request above

For security purposes, we may require verification of your identity before processing your request. You may be required to provide a written request or otherwise prove your identity. For all your requests under this section, we will, in principle, respond to your request within fifteen work days of receiving it and verifying your user identity.

(ii)If you are an end-user of an application that uses Aurora SendCloud's products or services and are not a direct customer of Aurora SendCloud (Developer Customer), we recommend that you:

According to the privacy policy of the application provider, please send the request related to your personal information directly to the relevant application provider for processing and seeking assistance, Aurora SendCloud will actively cooperate and respond to the request after receiving the relevant request from the application provider and verifying the authenticity and legitimacy of the request.

(iii)In principle, we do not charge a fee for reasonable requests from you and/or your end-users as described above. We may refuse requests that are unnecessarily repetitive, require excessive technical means (e.g., require the development of new systems or fundamental changes to existing practices), pose a risk to the legitimate interests of others, or are highly impractical (e.g., involve backing up information stored on magnetic tapes).

We will not be able to respond to requests from you and/or your end-users in the following situations:

1.Related to the fulfillment of our obligations under laws and regulations.

2.Directly related to public safety, public health, and significant public interests.

3.We have sufficient evidence that you have subjective malice or abuse of rights.

4.For the purpose of safeguarding your or other individuals' life, property and other important legal rights and interests but it is difficult to obtain my consent.

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

6.Involving trade secrets.

(iv) If you and/or your end-users have questions about the realization of the above rights, you may contact us in accordance with the relevant contact details in the manner described in Part X of this Policy.

The Platform provides services that do not accept minors to register as our users. If you provide personal information about a minor as an end-user, please be aware of this and provide it with caution. If your application is designed and developed for minors, please make sure that your end-user is a guardian who has read and agreed to the application's privacy policy.

Due to existing technology and business models, it is difficult for us to proactively identify information about minors. If the guardian of a minor discovers that there is unauthorized collection of the minor's personal information, the guardian may notify us to delete it, or if we discover on our own that you are a minor, we will also proactively delete it, unless we are required by law to retain such information.

In order to provide you with a better service, the Platform and related services will be updated and changed from time to time, we will revise this Policy from time to time, these revisions form part of this Policy and have the same effect as this Policy, and we will not reduce the rights that you and/or your end-users are entitled to in accordance with this Privacy Policy without your express consent.

When this Policy is updated, we will issue an updated version on our official website and remind you of the update by appropriate means before the updated terms take effect, so that you can keep abreast of the latest version of this Policy.

For significant changes, we will also provide more prominent notice (including, for certain services, sending a notice by email or in the form of a letter to you or by means of a bulletin stating the specific changes to the Privacy Policy). Accordingly,please feel free to review and understand the Privacy Policy to which you are subject. If you do not agree to be bound by this Privacy Policy, please stop accessing and using our Services.

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

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

2.We experience significant changes in our ownership structure, organizational structure, etc. Such as changes in ownership due to business restructuring, bankruptcy and mergers and acquisitions.

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

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

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

6.When the personal information security impact assessment report indicates a high risk.

This Policy is an integral part of Aurora SendCloud's Terms of Service. All rights not expressly granted in this Privacy Policy are reserved by Aurora SendCloud.

We hope to be able to resolve any disputes relating to data protection practices between us. Aurora SendCloud has set up a Dedicated Privacy Group. You could get in contact with Dedicated Privacy Group by email to globalservice@sendcloud.im.

If you have questions, suggestions or complaints about your account information, personal information or other documentation technology or to exercise your rights. Please don't hesitate to contact us for any questions or issues for which you need help. We will normally respond within fifteen work days.

Specific terms used in this policy shall have the meanings set forth below:

1.We: refers to Wuhan SendCloud Technology Co., Ltd.

2.Affiliated companies: refers to the affiliated companies of Wuhan SendCloud Technology Co., Ltd. Any of the above companies is or will be controlling, controlled or under common control with them.

3.Control: is the possession, directly or indirectly, of the ability to influence the management of the company referred to, whether through ownership, voting shares, contracts or other legally recognized means.

4.You: refers to the registered user who uses our products and/or services and the purchaser of paid services.

5.Your end-users: refers to the end-users who use the application/service provided by you.

6.Aurora SendCloud or this platform: means Aurora SendCloud platform.

7.Personal information: refers to all kinds of information recorded electronically or by other means that can, alone or in combination with other information, identify a specific natural person or reflect the activities of a specific person.

8.Subject of Personal Information: A natural person identified by personal information.

9.De-identification: refers to the process by which personal information is technically processed in such a way that the subject of the personal information cannot be identified without the aid of additional information.

10.Anonymization: A process whereby personal information is technically processed so that the subject of the personal information cannot be identified, and the processed information cannot be recovered.