365 Liquor Industry Co., Ltd. products, 365 wine cellar APP privacy policy related instructions.
The privacy policy respects and protects the personal privacy rights of all users of the privacy policy network services. In order to provide you with more accurate and personalized services, our privacy policy covers the ways in which we collect, use, disclose, transmit, and store your information. But privacy policies will treat this information with a high degree of diligence and prudence. The privacy policy may be updated from time to time. When you agree to the Privacy Policy Network Service Use Agreement, it is deemed that you have agreed to all the contents of this Privacy Policy. This privacy policy is an integral part of the Privacy Policy Network Service Use Agreement. You are not required to provide the personal information we require, but in many cases, if you choose not to provide it, we will not be able to provide you with our products or services, nor will we be able to respond to any issues you may encounter.
1、 How do we collect information
We only collect information necessary to achieve product functionality based on the principles of legality, legitimacy, and necessity. The main sources of personal information collected by our company include: information provided by you, information obtained during your use of our products or services, and your information shared by third parties. We will collect and use your personal information for the purpose of the following product features. If you do not provide relevant information or do not agree to our collection of relevant information, you may not be able to register as our user, enjoy certain services we provide, or achieve good service results.
1. If you provide account registration, login functions, and services, you may need to provide the following account registration information:
When you register an account, you will provide us with your phone number and login password.
When you choose to log in with a third-party account, we will read the profile picture and nickname information you used when registering with the third-party account. The aforementioned third-party accounts include QQ, WeChat, Weibo, or other third-party accounts, and the actual third-party accounts connected to the specific products and services shall prevail.
The purpose of collecting the aforementioned account information is to (1) better provide you with services through account management. By logging in to your account, you can synchronize your relevant information. (2) If you provide real and valid mobile phone numbers, QQ accounts, Weibo accounts, and WeChat accounts for binding, you can easily retrieve your account and password when you encounter problems with lost or forgotten registered accounts. (3) We will de identify and statistically analyze the collected relevant information in order to gain a more accurate understanding of user habits, and continuously improve the product, service quality, and user experience based on this foundation
2. The information you submitted through our customer service or when participating in our events. To contact you in a timely manner, provide feedback on customer service issues or related activity information, you may provide us with your contact information for timely communication.

3. Equipment information
Device information refers to the information about the devices you use when using our products or services. In order to provide necessary adaptation and security services for products and services with devices, you will collect information related to the device name, device model, device identification code, operating system and application version, language settings, resolution, and service provider network ID (PLMN) when using products or services from 365 Winery Co., Ltd. Collecting this information is to assist us in bug analysis, ensure your normal use of our products and services, improve and optimize our product experience, and ensure the security of your account. Unless otherwise specified in this policy, we will not provide your device information to any third party. But we cannot guarantee that other third parties will not obtain your device information through other means and combine it with other information to identify your personal identity. If this causes any losses to you, you should seek compensation from the third party. The above device information is the basic information collected for providing services. If you do not want the device information to be collected by us, it may cause us to be unable to provide you with normal services.
4. Location information
Location information refers to the information collected about your location when you enable device positioning and use location-based services, mainly including:
When you enable device positioning and use related products or services, we may use GPS, WiFi, or other technical methods to collect and process information about your actual location. The trajectory and precise positioning information are personal sensitive information, and our products or services will not collect such personal sensitive information except as required by specific product or service functions.
Real time information provided by you or other users that includes your geographical location. This includes shared information uploaded by you or others that displays your current or past geographic location, as well as geotagged information contained in photos shared by you or others.
If you do not want to be accessed, you can choose to turn off the relevant functions in the device or product/service, but this may affect our ability to provide you with relevant services.
5. Log information
For the sake of service security, when you use products and services, the system may automatically collect certain information through cookies or other means and store it in server logs. This type of information may include:
The detailed usage of our products and services, which may include the web search terms you use, the page addresses you visit, and other information and content details you browse or request when using the services; Device or software information, in addition to the device information mentioned above, we may collect the version number and browser type of the software you are using. To ensure the security of your operating environment or provide services, we will collect information about the mobile applications and other software you use. Equipment event information, including crash, system activity information, and other related information.

6. Other information collected with your consent
To provide you with more convenient, high-quality, and personalized products or services, certain specific features of our products and services may require you to provide specific personal sensitive information to achieve. If you choose not to provide such information, you may not be able to use the corresponding functions normally, but it does not affect your use of other functions in the service. These features include:
(1) Camera based application functions: You can complete video shooting, taking photos, scanning QR codes, and facial recognition functions after enabling camera/camera permissions. In the future, we may apply facial recognition technology to more scenarios, but at that time, we will confirm with you again whether you are willing for us to use your facial information to achieve these extended functions.
(2) Application function for accessing and uploading images/videos based on photo albums (picture/video libraries): You can use the corresponding function to edit and process your photos/images/videos after enabling photo album permissions.
(3) Application function based on microphone voice technology: You can directly use the microphone to record or implement corresponding functions after enabling microphone permission. In these functions, we will collect your recordings to recognize your voice content and achieve corresponding functional effects.
(4) Application function based on contact information: We will collect your contact information after you enable contact permission, so that you can more conveniently access the contact information in your contact book when using the corresponding function, without the need for manual input.
(5) Application function based on mobile file reading: You can use the corresponding function to edit and process files in your phone after enabling file reading/uploading permissions.
You understand and agree that the above application functions may require you to enable access to your camera (camera), album (picture library), microphone (voice), and mobile file reading on your device, in order to collect and use the information involved in these functions. Please note that before collecting sensitive personal information, we will obtain your consent through pop ups or similar prominent means. If you voluntarily provide your personal sensitive information, it means that you agree that we will process your personal sensitive information in accordance with the purposes and methods described in this policy
7. Your information shared by other third parties
There are mainly two situations: (1) Other users may include your information in the information they post. (2) The information generated or shared by you when using third-party partner services, when you log in to our software products or services using Weibo, QQ account, or other third-party accounts, we need to verify your identity or bind your account information, and with your authorization, associate the relevant account with our products or services.

2、 How do we use the collected information
We strictly abide by the provisions of laws and regulations and the agreements with users, and use the collected information for the following purposes. If we use your information beyond the following purposes, we will explain it to you again and obtain your consent.
1. Meet your personalized needs, such as language settings, location settings, and personalized help services.
2. We provide you with services, product development, and service optimization: for example, when our system malfunctions, we will record and analyze the information generated by the system failure to optimize our services.
3. Security measures: For example, we will use your information for identity verification, security prevention, anti fraud monitoring, archive backup, customer security services, and other purposes. For example, the security software you download or install will detect malicious programs or viruses, or identify fraudulent information for you.
4. Recommend advertisements, information, etc. that you may be interested in.
5. Evaluate and improve the effectiveness of our advertising and other promotional and promotional activities.
6. Management software: For example, conducting software certification, software upgrades, etc.
7. We invite you to participate in a survey about our services.
According to laws and regulations, collect and use your relevant information in the following situations without obtaining your authorization.
Related to national security and national defense security;
Related to public safety, public health, and major public interests;
Related to criminal investigation, prosecution, trial, and enforcement of judgments;
For the purpose of protecting the significant legitimate rights and interests of personal information subjects or other individuals, such as life and property, but it is difficult to obtain my consent;
Necessary for maintaining the safe and stable operation of the provided products and/or services, including discovering and dealing with faults in the products and/or services;
Necessary for legitimate news reporting;
When academic research institutions conduct statistical or academic research based on the public interest and provide academic research or descriptive results to the public, they de identify the personal information contained in the results;
Other situations stipulated by laws and regulations.
9. Other uses approved by you.
In order to provide you with a better experience, improve our services, or for other purposes agreed upon by you, and subject to compliance with relevant laws and regulations, we may use the information collected through certain services for our other services. For example, using your information while using one of our services to showcase personalized content or advertisements to you in another service, or for user research, analysis, and statistical services.
To ensure the security of our services and help us better understand the operation of our applications, we may record relevant information, such as the frequency of your use of the application, fault information, overall usage, performance data, and the source of the application. We will not combine the information we store in the analysis software with the personal identification information you provide in the application.

3、 How do we share, transfer, and publicly disclose your personal information
We are fully aware of the legal responsibilities that should be borne by the personal information subject in case of damage caused by illegal sharing, transfer, and public disclosure of personal information. For all sharing, transfer, and public disclosure of your personal information, we will strictly follow the following terms:
（1） Sharing
Respecting the personal privacy of users is a fundamental principle of ours. We will not share your personal information with any company, organization, or individual except for the following situations:
1. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.
2. We may share your personal information with the public in accordance with the requirements of judicial or administrative authorities.
3. Sharing with related parties: Your personal information may be shared with our affiliated companies. We will only share necessary personal information and are bound by the purposes stated in this privacy policy. If affiliated companies want to change the purpose of processing personal information, they will seek your authorization and consent again.
4. Sharing with authorized partners: Some of our services will be provided by authorized partners solely for the purposes stated in this policy. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for legitimate, legitimate, necessary, specific, and clear purposes, and only share personal information necessary for providing services, such as sharing your information with logistics companies when you purchase our products online. Our partners have no right to use the shared personal information for any other purpose.
We will sign strict confidentiality agreements with companies, organizations, and individuals with whom we share personal information, requiring them to handle personal information in accordance with our instructions, this privacy policy, and any other relevant confidentiality and security measures.
（2） Transfer
We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:
1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties.
2. When it comes to mergers, acquisitions, or bankruptcy liquidation, if it involves the transfer of personal information, we will require the new company or organization that holds your personal information to continue to be bound by this privacy policy. Otherwise, we will require the company or organization to seek your authorization and consent again.
（3） Public disclosure
We will only publicly disclose your personal information in the following circumstances:
1. Disclose your designated personal information in a disclosure method that you explicitly agree to
2. In cases where it is required by laws, regulations, mandatory administrative enforcement or judicial requirements to provide your personal information, we may publicly disclose your personal information based on the type and disclosure method required. Subject to compliance with laws and regulations, when we receive a request for disclosure of the aforementioned information, we will require the issuance of corresponding legal documents, such as subpoenas or investigation letters.

4、 How can we protect your personal information
1. We have used security measures that comply with industry standards to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable and feasible measures to protect your personal information. For example, being protected by SSL encryption when exchanging data (such as credit card information) between your browser and the "service"; We also provide HTTPS secure browsing for the website; We will use encryption technology to ensure the confidentiality of data; We will use trusted protection mechanisms to prevent data from being maliciously attacked; We will deploy access control mechanisms to ensure that only authorized personnel can access personal information; And we will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.
2. We will take all reasonable and feasible measures to ensure that unrelated personal information is not collected. Unless we obtain your written permission, we will retain your personal information only for 36 months after you delete or cancel your account. After this period, we will anonymize or destroy your personal information.
3. The Internet is not an absolutely secure environment, and email, instant messaging, and communication with other users are not encrypted. We strongly recommend that you do not send personal information through such methods. Please use complex passwords to assist us in ensuring the security of your account.
4. The Internet environment is not 100% secure. We will try our best to ensure or guarantee the security of any information you send us. If our physical, technological, or management protective facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, which damages your legitimate rights and interests, we will bear corresponding legal responsibilities.
5. In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with the provisions of Article 42 (2) of the Cybersecurity Law: the basic situation and possible impact of the security incident, the measures we have taken or will take to dispose of it, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant situation of the event through email, letter, phone, push notifications, and other means. If it is difficult to inform the personal information subject one by one, we will take reasonable and effective measures to publish an announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with regulatory requirements.

5、 How do you manage your personal information
1. You can access, modify, and delete the registration information and other personal information you provide while using our services, or you can contact us according to the notification guidelines. The scope and methods of accessing, modifying, and deleting personal information will depend on the specific services you use.
For example, if you want to stop sharing your geographic location information while using location-related services, you can stop sharing by disabling the mobile location function, software and hardware service providers, and communication service providers. We recommend that you carefully read the relevant guidelines.
2. We will collect and use your information solely for the purpose of achieving the functionality of our products or services, as stated in this policy.
If you find that we have violated the provisions of laws, administrative regulations, or the agreement between both parties in collecting and using your personal information, you can request us to delete it.
If you find any errors in the personal information we collect and store, you can also request us to make corrections.
When you access, modify, and delete relevant information, we may require you to perform identity verification to ensure the security of your account.
3. In the following situations, according to legal requirements, we will not be able to respond to your request:
Directly related to national security and national defense security.
Directly related to public safety, public health, and major public interests.
Directly related to criminal investigation, prosecution, trial, and enforcement of judgments.
There is sufficient evidence to suggest that you have subjective malice or abuse of power.
Responding to your request will result in serious damage to your or other individuals or organizations' legitimate rights and interests.
Involving trade secrets.

6、 Personal information about children
Our products, websites, and services are primarily aimed at adults. Minors are not allowed to create their own user accounts without the consent of their parents or guardians. For cases where personal information of minors is collected with the consent of parents, we will only use or publicly disclose this information when required by judicial or administrative authorities, explicitly agreed upon by parents or guardians, or necessary to protect minors.
Although local laws and customs define minors differently, we consider anyone under the age of 16 to be a minor.
If we find ourselves collecting personal information of minors without obtaining verifiable parental consent in advance, we will try to delete the relevant data as soon as possible.
7、 Integrated third-party SDK
1. Alipay payment SDK, WeChat payment SDK
Provide online payment of membership fees for APP end users, and redirect to the corresponding application during payment. User information is not collected within this APP.
2. Authorize login to SDK on WeChat development platform
Provide WeChat authorization login function for APP end users, making it convenient for users to quickly log in to the APP.
3. In order to send real-time notification messages to users and integrate the push SDK, the SDK collects and uses personal information including device information, application information, device parameters and system information, network information, and geographic location information; Collecting information is to provide users with better services, improve technology, and enhance user experience.
Device information includes: device identifiers (IMEI, IDFA, Android ID, MAC, OAID, IMSI) and other related information
Application information includes: application crash information, notification switch status, software list, and other related information
System information includes: device type, device model, operating system, and hardware related information
Network information includes: IP address, WiFi information, base station information, and other related information

8、 Sensitive Information Statement
Camera permissions: Obtain camera permissions for uploading, modifying, and commenting on avatars.
Album permissions: Obtain camera permissions for uploading, modifying, and commenting on avatars.
Location permissions: Obtain location permissions for users to register and obtain location functions.
Storage permission: Obtain storage permission to locally save user information and class hour records.
Collecting mobile phone numbers: Users need to fill in their registration information, which is mainly used to send text messages to users and notifications for system business.
9、 How to update this policy
Our privacy policy will be updated from time to time.
Normally, we will not reduce your rights under this privacy policy. We will publish the updated version on this page and notify you of any changes made to this policy in a prominent manner such as a pop-up or equivalent. By agreeing, you agree to be bound by the revised policy.
10、 Contact information
Consultation hotline: +65 62229077
Enterprise email: Sg@365-wines.com