隐私政策

Our Privacy Policy was updated on January 19, 2024.

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

About us

Zhenshi Information Technology (Shanghai) Co., Ltd., and its affiliated companies within the Zhenshi (hereinafter refer to as “Zhenshi”, “we”, “our” or “us”) take your privacy very seriously. This Privacy Policy is designed with your needs in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, while ensuring that ultimately, you have control of your personal information provided to Zhenshi.

About this privacy policy

This Privacy Policy explains how Zhenshi collects, uses, discloses, processes and protects any personal information that you give us or that we collect from you. Should we ask you to provide certain information by which you can be identified when you use the services on our platform, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users. Under this Privacy Policy, “personal information” means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information Zhenshi has access to about that individual, except as otherwise specifically provided by applicable laws in your region. We will use your personal information strictly in accordance with this Privacy Policy.

How we can help you

Ultimately, what we want is the best for all our users. Should you have any questions with our data handling practices as summarized in this Privacy Policy, please contact us by [business@mibrofit.com] to address your specific concerns. We will be happy to hear from you.

1 What information is collected by us and how do we use it?

1.1 What information is collected by us

In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. We will only collect the information that is necessary for its specified, concrete, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our services or respond to your queries. Depending on the service you choose, we may collect the following types of information:

1.1.1 Information you provide to us

We may collect any personal information you provide to us, which is necessary for the service you choose. For example, you may provide us your email address if you wish to receive news or updates from us.

1.1.2 Information that we collect in your use of services

We may collect log information related to your use, such as cookies, IP addresses. Log information is information related to your use of certain features of the websites.For example, cookies and IP addresses, network request information, standard system logs, crash information, log information generated by using the services (such as access time, activity time, etc.). We use such information in aggregated form to improve your experience while using our apps and websites.

We collect information such as information about your activities on our websites.

We use such information in aggregated form to provide you with more useful information and to understand which parts of our websites, products and services you are most interested in. In its aggregated form, data is not personal information and cannot be used to identify you. However, if we combine non-personal information with personal information, such information will be treated as personal information.

1.1.3 Non-personally identifiable information

We may also collect other types of information which are not directly or indirectly linked to an individual and which may not be defined as personal information according to applicable local laws. Such information may include statistical data generated when you use a specific service (e.g. user clicks, browsing behaviors, page access events). The purpose for such collecting is to improve the services we provide to you. The type and amount of information collected depends on how you use our services.

In its aggregated form, such data is not personal information as it cannot be used to identify you. However, if we combine non-personal information with personal information, such information will be treated as personal information.

1.2 How we use the personal information that we collect

The purpose of collecting personal information is to provide you with services, and to ensure that we comply with applicable laws, regulations and other regulatory requirements. This involves:

• Providing, processing, maintaining, improving and developing our services to you.

• Handling your questions or requests about our services, such as sending notifications.

• Conducting relevant promotional activities,such as providing marketing and promotional materials and updates. If you no longer wish to receive certain types of promotional materials, you may opt-out by the method provided in the message (such as the unsubscribe link at the bottom of the message) unless otherwise specified under applicable laws. Please also see “Your rights” below.

• Internal purposes such as data analysis, research, and development of statistical information related to the use of our services for improvement.

• Storing and maintaining information related to you for our business operations (such as business statistics) or for fulfilling our legal obligations.

• Other purposes with your consent.

We may combine this information with other information (including information across different services or devices such as computers, mobile phones and other connected devices) to provide and improve our services and content.

2 Cookies and other technologies

Technologies such as cookies, tags, and scripts are used by Zhenshi and our third party service providers and business partners (for more information see “How we share, transfer, and publicly disclose your personal information” below). These technologies are used in analyzing trends, administering the site, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. These technologies help us better understand users’ behavior, tell us which parts of our websites people have visited, as well as facilitate and measure the effectiveness of web searches. We treat information collected by cookies and other technologies as non personal information, except where Internet Protocol (IP) addresses or similar identifiers are considered personal information by local laws.

• Log files: As true of most websites, we gather certain information and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we gather about you.

• Local storage – HTML5/Flash: We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content and preferences. Third parties with whom we partner to provide certain features on our sites also use HTML5 or Flash cookies to collect and store information. Various browsers may offer their own management tool for removing HTML5 LSOs.

3 How we share, transfer, and publicly disclose your personal information

3.1 Sharing

We do not sell any personal information to third parties.

We may sometimes share your personal information with third parties (as described below) in order to provide or improve our services, including offering services based on your requirements. If you no longer wish to allow us sharing this information, please contact us by[service@mibrofit.com].

3.1.1 Sharing that you actively choose or request

With your explicit consent or at your request, we will share your personal information within the scope of your consent/request with specific third parties designated by you.

3.1.2 Sharing information with our group

In order to successfully conduct business operations and to provide you with all the functions of our services, we may share your personal information from time to time to other Zhenshi affiliates.

3.1.3 Sharing with third party service providers and business partners

To help us provide you with services described in this Privacy Policy, we may, where necessary, share your personal information with our third-party service providers and business partners.This includes our data centers, data storage facilities and other business partners. These third parties may process your personal information on Zhenshi’s behalf or for one or more of the purposes of this Privacy Policy. We guarantee that the sharing of personal information necessary for providing services to you is solely for legitimate, legal, necessary, specific, and explicit purposes. Zhenshi will conduct due diligence and have contracts in place to ensure that third-party service providers comply with the applicable privacy laws in your jurisdiction. There may be occasions that third-party service providers have their sub-processors.

To provide performance measurement, analysis, and other business services, we may also share information (non-personal information) with third parties in aggregated form. We use the information we have to help our business partners evaluate the effectiveness and coverage of their services, and understand the types of people who use their services and how people interact with their websites, apps, and services. We may also share general usage trends of our services with them, such as the number of customers in a particular group of people who purchase certain products or engage in certain transactions.

3.1.4 Other

In accordance with legal requirements, legal procedures, litigation and/or requests from public agencies and government agencies, Zhenshi may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.

In order to enforce our terms or protect our business, rights, assets or services, or to protect users, or if the disclosure is reasonably necessary for the following purposes (detecting, preventing and resolving fraud, unauthorized use of the service, violations of our terms or policies, or other harmful or illegal activities), we may also disclose information about you. (There may be occasions when Zhenshi may collect, use or disclose your personal information without your consent if it is and only to the extent it is permitted under applicable data protection laws). This may include providing your personal information to public or government agencies; communicate with third-party partners regarding the reliability of the products or services provided to you to prevent fraud, violations, and other harmful behavior.

In addition, we may share your personal information with:

• our accountants, auditors, lawyers, or similar advisers when we ask them to provide us with professional advice; and

• investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to an entity in the Zhenshi Group; and

• any other third parties, if authorized by you to do so in relation to a specific disclosure.

3.2 Transfer

Zhenshi will not transfer your information to any subject except in the following cases:

• Where we have obtained your explicit consent;

• If Zhenshi is involved in the merger, acquisition, or sale of all or part of its assets, we will notify you of any changes in the ownership, use, and any choice of your personal information you possibly possess by email and/or by posting a prominent notice on our websites.

3.3 Public disclosure

Zhenshi will only publicly disclose your personal information under the following circumstances:

• Where we have obtained your explicit consent;

• Public disclosure based on law or reasonable grounds: including laws and regulations, legal procedures, litigation, or at the request of the competent government departments.

4 How we store and protect your personal information

4.1 Zhenshi’s security safeguards

We are committed to keeping your personal information secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place all legally required physical, electronic and managerial procedures to safeguard and secure the information we collect from you. We will ensure that we safeguard your personal information in accordance with applicable law.

When you send or receive data from your Zhenshi device to our servers, we make sure they are encrypted using Transport Layer Security (“TLS”) and other algorithms.

All your personal information is stored on secure servers and protected in controlled facilities. We classify your information based on importance and sensitivity and ensure that your personal information has the required level of security. We have special access controls for cloud-based data storage, and we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.

We conduct due diligence on business partners and third party service providers to make sure that they are able to protect your personal information. We also check that appropriate security standards are maintained by these third parties by putting in place appropriate contractual restrictions, and where necessary, carrying out audits and assessments. In addition, our employees and those of our business partners and third party service providers who access your personal information are subject to enforceable contractual obligations of confidentiality.

We conduct security and privacy protection training courses and tests to enhance our employees' awareness of the importance of protecting personal information. We will take all practicable and legally required steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information when transferred from you or to you via the Internet.

We handle personal data breaches as required by applicable data protection law which includes, where required, notifying the breach to the relevant data protection supervisory authority and data subjects.

4.2 Retention policy

We retain personal information for the period necessary for the purpose of the information collection described in this Privacy Policy, or as required by applicable laws. We will cease to retain and delete or anonymize personal information once the purpose of collection is fulfilled, or after we confirm your request for erasure, or after we terminate the operation of the corresponding service. An exception to this is personal information that we are processing for public interest, scientific, historical research, or statistical purposes. Zhenshi will continue to retain this type of information for longer than its standard retention period, where permitted based on applicable laws or your request, even if further data processing is not related to the original purpose of collection.

5 Your rights

Controlling your personal information

5.1 Controlling settings

Zhenshi recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways Zhenshi makes available to you to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings, such as refuse website to use Cookies.

If you have previously agreed to us using your personal information for the aforementioned purposes, you may change your mind at any time by contacting us by [business@mibrofit.com].

5.2 Your rights to your personal information

Depending on applicable laws and regulations, you have the right to access, rectification, and erasure of any other personal information that we hold about you (hereinafter referred to as the request).

You may also write to us or contact us at [service@mibrofit.com] to access and update detailed information related to your personal information.

This Privacy Policy requires that your request satisfy applicable laws and regulations and the following conditions:

(1) Through Zhenshi's particular request submission channels listed below, and your request should be in writing (unless the local law explicitly recognizes the oral request), for the protection of your information security;

(2) Provide sufficient information to enable Zhenshi to verify your identity and ensure that you are the subject of the requested information or a personal legally authorized to act on the subject’s behalf.

Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.

In detail:

• You have the right to be provided with clear, transparent and easily understandable information about how we use your personal information and your rights. This is why we are providing you with the information in this Privacy Policy.

• Based on the requirements of applicable laws, a copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests for relevant information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.

• If any information we are holding on you is incorrect or incomplete, you are entitled to have your personal information corrected or completed.

• Based on the requirements of applicable laws, you have the right to request the deletion or removal of your personal information where there is no compelling reason for us to keep using it. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures. If the right is upheld, we may not be able to immediately remove the information from the backup system due to applicable law and/or technology limitations. If this is the case, we will securely store your personal information and isolate it from any further processing until the backup can be cleared or be made anonymous.

• You have the right to object to certain types of processing, and under certain circumstances where the legal basis for processing is our legitimate interests.

Particularly under the laws of some jurisdictions:

• You have the right to obtain from us the restriction of processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.

• You have the right not to be subject to a decision based solely on automated processing, which produces legal effects concerning you or similarly significantly affects you.

• You have the right to apply for your personal information in a structured, commonly used format and transmit the information to another data controller.

We have the right to refuse to process requests that are frivolous requests that damage others' right of privacy, extremely unrealistic requests, requests that require disproportionate technical work, and requests not required under local law, information that have been made public, information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, it may also be rejected.

5.3 Withdrawal of consent

You may withdraw your consent previously provided to us for a particular purpose by submitting a request, including collecting, using, and/or disclosing your personal information in our possession or control. Based on the specific service you are using, you can contact us by [business@mibrofit.com]. We will process your request within a reasonable time from when the request was made, and thereafter not collect, use and/or disclose your personal information as per your request.

Depending on the extent of your withdrawal of consent, please note that you may not be able to continue receiving the full benefit of Zhenshi’s products and services. The withdrawal of your consent or authorization will not affect the validity of our processing carried out on the basis of the consent up until the point of withdrawal.

5.4 Cancelling a service

If you wish to cancel a specific product or service, you can contact us by [business@mibrofit.com]. for logout service.

Cancellation may be prevented or delayed in certain circumstances.

6 How your personal information is transferred globally

Zhenshi processes and backs up personal information through a global operating and control infrastructure. Currently, Zhenshi has data centers in the Guangzhou, China. For the purposes described in the Privacy Policy, your information may be transferred to these data centers in accordance with applicable law.

We may also transfer your personal information to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions. The jurisdiction in which these global facilities are located may or may not protect personal information to the same standards as in your jurisdiction. There are different risks under different data protection laws. However, this does not change our commitment to comply with this Privacy Policy and to protect your personal information.

If we need to transfer personal information outside of your jurisdiction, whether to our affiliates or third-party service providers, we will comply with related applicable laws. We ensure that all such transfers meet the requirements of applicable local data protection laws by implementing uniform safeguards.

If Zhenshi shares personal data originating by you in the EEA to a Zhenshi Group entity or a third party service provider outside the EEA, we will do so on the basis of EU standard contractual clauses or any other safeguards provided for in the GDPR.

7 Protection of minors

We consider it the responsibility of the parent or guardian to supervise the child's use of our services. However, we do not offer services directly to a child or use personal data of children for the purposes of marketing.

If you are a parent or guardian and you believe that the minor has provided Zhenshi with personal information, please contact us by [service@mibrofit.com]. to ensure that the personal information is removed immediately and that the minor is unsubscribed from any of the applicable Zhenshi services.

8 Do i have to agree to any third party terms and conditions?

Our Privacy Policy does not apply to products or services offered by a third party. Depending on the service you use, it may incorporate a third parties’ products or services. Some of these will be provided in the form of links to third parties’ websites. Your information may also be collected when you use these services. For this reason, we strongly suggest that you take the time to read the third party’s privacy policy just like you read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

9 How we update this privacy policy

We review the Privacy Policy periodically based on changes in business and technology, and we may update this Privacy Policy. If we make a material change to this Privacy Policy, we will publish on Zhenshi websites or notify you via mobile devices so that you can learn about the information we collect and how we use it. Such changes to Privacy Policy will apply from the effective date specified in the notice or website. We encourage you to check this page regularly for the latest information on our privacy practices. Your continued use of the services on the website, mobile and/or any other device will be deemed acknowledgement of the updated Privacy Policy. We will ask for your explicit consent when we collect additional personal information from you or when we use or disclose your personal information for new purposes.

10 Contact us

If you have any comments or questions about this Privacy Policy or any questions relating to Zhenshi’s collection, use, or disclosure of your personal information, please contact us at the address below referencing “Privacy Policy”. When we receive privacy or personal information questions about access/download requests, we have a professional team to solve your problems. If your question itself involves a significant issue, we may ask you for more information. If you are not satisfied with the response you received, you can hand over the complaint to the relevant regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your actual situation.

Zhen Shi Information Technology (Shanghai) Co., Ltd.

Address: Block A, 5th Floor, Building 3, No. 401, Caobao Road, Xuhui District, Shanghai

Email: service@mibrofit.com

Thank you for taking the time to read our Privacy Policy!