Your trust is important to us. We are aware of the importance of personal information to you. We will take corresponding security measures according to the requirements of laws and regulations, and try our best to protect your personal information. Whereas, the service provider of the APP “Visit Shanghai” (hereinafter referred to as "We/Us") formulate this Privacy Policy (hereinafter referred to as "this Policy/this Privacy Policy") and remind you that:
Before using the products or services of the APP “Visit Shanghai”, please read this Policy carefully and understand it thoroughly, and use the related products or services after confirming your full understanding and consent. Once you start using the products or services of Visit Shanghai, it means that you have fully understood and agreed with this Policy. If you have any questions, comments or suggestions about this Policy, you can contact us through the Customer Service of Visit Shanghai.
Visit Shanghai APP: refers to the mobile client side operated by the service provider of Visit Shanghai APP.
Service Provider of Visit Shanghai APP: refers to Shanghai City Image Promotion Co., Ltd. (上海城市形象推广有限公司), i.e., the network and software technology service provider of Visit Shanghai APP.
Personal information: refers to all kinds of information recorded electronically or in other ways that can identify a particular natural person's identity or reflect the activities of a particular natural person independently or in combination with other information.
Personal sensitive information: including, among others, ID card number, personal biometric information, bank account, property information, whereabouts, transaction information, personal information of children under 14 years old (inclusive).
Personal information deletion: refers to the removal of personal information in the system involved in the realization of daily business functions, so that it cannot be retrieved and accessed.
This Privacy Policy will help you understand the following:
1. How do we collect and use your personal information
2. How do we use Cookie and similar technologies
3. How do we share, transfer and publicly disclose your personal information
4. How do we protect your personal information
5. How do you manage your personal information
6. How do we deal with minors' personal information
7. How can your personal information be transferred globally
8. How to update this Privacy Policy
9. How to contact us
I. How do we collect and use your information?
We will collect and use your personal information for the following purposes stated in this Policy:
(I) Help you become our member
Visit Shanghai APP will provide you with services. You need to create a Visit Shanghai APP Platform Account, provide your mobile phone number and the user name and password you intend to use. If you only need to use basic services such as browsing and search, you do not need to register an account with the Visit Shanghai APP and provide the above information.
The user name of your Visit Shanghai APP Account is also the "member nickname" of your Visit Shanghai APP membership.
If you already have an Visit Shanghai APP Account, we may display your personal information mentioned above in the Visit Shanghai APP Platform Service, as well as the operations you perform on the Visit Shanghai APP Platform or in the products and services associated with the Visit Shanghai APP Platform Account, such as centralized display of your personal data or trading orders through the Visit Shanghai APP Platform Account. We will respect your settings at the Visit Shanghai APP Platform Service and the Visit Shanghai APP Platform Account.
(II) Display and promote goods or services for you
In order to improve our products or services and provide you with custom-made information search and trading services, we will extract your browsing, search preferences, behaviors, habits, location information and other features based on your browsing and search records, device information, location information and order information, and carry out indirect crowd portraits and display and push information based on feature labels.
If you do not want to receive the commercial advertisement we send you, you can unsubscribe by replying “TD” through SMS prompt or by other means provided by us.
(III) Provide you with goods or services
1. Due to the particularity of products or services in the Visit Shanghai APP, some of the goods or services you choose need further information to complete the reservation. For example, when you book an air ticket, you should provide at least the name of the passenger, the type of the certificate, the number of the certificate, the name of the contact person, the mobile phone number and the e-mail, so that the merchant can provide you with the services of ticket booking, information notification and subsequent refund and ticket change; when you book a hotel, you should provide the name of the person checking in, the mobile phone, so that the merchant can help you complete the hotel booking, notification and other services. Other goods or services requiring your further information to complete the booking shall be subject to the reminder and authorization of the specific booking procedures. Please read such procedures carefully.
At the same time, you can save the above information as commonly used information, so that you can choose to use it directly next time you make a booking without needing to fill it in again.
To complete the transaction, you may need to provide Alipay account and/or UnionPay card number so that we can understand your payment status.
You can book goods or services for others by Visit Shanghai APP. You need to provide the de facto user's information according to the prompt. Before providing the de facto user's information to Visit Shanghai APP, you shall ensure that you have obtained the consent of the de facto user and that he or she knows and accepts this Privacy Policy.
2. The information we collect during your use of the service
In order to provide you with page presentation and search results that better meet your needs, let you understand product adaptability, and identify abnormal status of the account, we will collect and correlate information about the services you use and how you use them, including:
Device information: We will, according to the specific permissions granted by you in software installation and use, receive and record the relevant information of the device you use (such as device type, operating system version, device settings, unique device identifier, software and hardware features and device environment information), location-related information of the device (such as IP address, GPS location and the sensor information such as Wi-Fi access point, Bluetooth and base station that can provide relevant information.
Log information: When you use the products or services provided by our website or client side, we will automatically collect your detailed usage of our services and save them as relevant network logs. For example, your searches, IP address, browser type, telecom operators, language used, access date and time, and the web page you visit, etc.
Please note that separate device information, log information, etc. are information that cannot be used to identify a particular natural person. If we use this kind of non-personal information in combination with other information to identify a particular natural person, or use it in combination with personal information, such non-personal information will be regarded as personal information during the combined use period. Unless we obtain your authorization or other otherwise provided by laws and regulations, we will anonymize and de-identify such personal information.
In order to display the order information of your account, we will collect the order information generated in the process of using our service to show you such information and facilitate your order management.
When you contact us, we may save your correspondence/call record and content or the contact information you left, so as to contact you or help you solve problems, or record the solutions to and results of related problems.
3. We collect your personal information through indirect access
In order to confirm the transaction status and provide after-sales and dispute resolution services for you, we will collect your transaction, payment, ticketing, hotel booking, logistics information related to the transaction progress through the third party information system (hotel’s central booking system, etc.), payment agencies, logistics companies and so on, or share your transaction information with the above service providers.
(IV) Provide you with security
In order to improve the security of your use of services provided by us and our affiliated companies and business partners, protect your or other users or the public’s personal and property security from harm, better prevent the security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusion, and more accurately identify violations of laws and regulations or relevant rules of Visit Shanghai APP. We may use or integrate your membership information, transaction information, device information, relevant network logs, and information shared by our affiliated companies and business partners authorized by you or in accordance with the law to comprehensively evaluate your account and transaction risks, conduct identity authentication, detect and prevent security incidents, and take necessary records, audits, analysis and disposal measures in accordance with the law.
(V) Other uses
Your consent will be sought in advance when we use information for other purposes not specified in this Policy, or when information collected for specific purposes is used for other purposes.
(VI) Exceptions to obtaining consent
According to relevant laws and regulations, collecting your personal information in the following situations does not require your consent:
1. Relating to national security and national defense security;
2. Relating to public safety, public health and major public interests;
3. Relating to criminal investigation, prosecution, trial and execution of judgments;
4. For the purpose of safeguarding the material legal rights and interests of the subject of personal information or the life and property of other individuals, but it is difficult to obtain your consent;
5. The personal information collected is disclosed to the public by yourself.
6. Collecting personal information from lawfully disclosed information, such as legitimate news reports, information disclosure by the government, etc.;
7. It is necessary to sign a contract according to your requirements.
8. It is necessary to maintain the safe and stable operation of the products or services provided, for example, to detect and dispose of faults in the products or services;
9. It is necessary for legitimate news reporting;
10. It is necessary for academic research institutions to carry out statistical or academic research based on public interest, and when the results of academic research or description are provided to the public, the personal information contained in the results is de-identified;
11. Other circumstances prescribed by laws and regulations.
If we stop operating Visit Shanghai APP’s products or services, we will stop collecting your personal information in time, notify you of the cease of operation in the form of service on a one-by-one basis or announcement, and delete or anonymize the personal information we hold.
II. How do we use Cookie and similar technologies
(I) Cookie
To ensure that the networks operate properly, provide you with a more convenient access experience, and recommend content that you may be interested in, we will store Cookie, Flash Cookie or other commonly included identifiers, site names, and local storage of numbers and characters (collectively referred to as "Cookie") provided by browsers or affiliated applications on your computer or mobile device. With Cookie, websites can store data such as your preferences or goods in shopping carts.
If your browser or browser add-on service allows, you can modify the acceptance of Cookie or reject our Cookie. For more information, see AboutCookies.org. But if you do so, in some cases it may affect your safe access to our website, and you may need to change user settings every time you visit our website.
(II) Website beacons and pixel tags
In addition to Cookie, we will also use other similar technologies such as website beacons and pixel tags on our websites. For example, the e-mail we send you may contain an address link that links to the content of our website. If you click on this link, we will track this click to help us understand your product or service preferences so that we can take the initiative to improve the customer service experience. Website beacons are usually transparent images embedded in websites or e-mails. With the help of the pixel tags in the e-mail, we can know whether the e-mail is opened or not. If you do not want your activities to be tracked in this way, you can always unsubscribe from our mailing list.
III. How do we share, transfer and publicly disclose your personal information
(I) Sharing
We will not share your personal information with companies, organizations and individuals other than Visit Shanghai APP’s service provider, except in the following cases:
1. Sharing on your own initiative: If you take the initiative to purchase goods and book services by Visit Shanghai APP, we will share the necessary information of the transaction and your order information with the suppliers of related goods and services to meet your demand for purchasing goods or booking services from them, and to enable them to complete subsequent after-sales services.
2. Sharing with your explicit consent: With your explicit consent, we will share your personal information with other parties. For example, if we entrust a third party to provide you with products or services, we will share the above information with a third party with your consent. If you refuse to provide such information, we will not be able to deliver the relevant services.
3. Sharing under statutory circumstances: We may share your personal information with the outside world in accordance with the provisions of laws and regulations, the need to settle litigation disputes, or the requirements of administrative and judicial organs according to law.
4. Sharing with affiliated companies: In order to facilitate our service to you based on the Visit Shanghai APP Platform Account, recommend information you may be interested in or hold harmless the personal property of Visit Shanghai APP’s affiliated companies or other users or the public, your personal information may be shared with our affiliated companies. We will only share the necessary personal information and be bound by the purposes stated in this Privacy Policy. If we share your personal sensitive information or the affiliated company changes the use and processing purposes of personal information, we will seek your consent again.
5. Sharing with authorized partners: We will entrust authorized partners to provide you with certain services or perform duties on our behalf. We will only share your information for legitimate, due, necessary, specific and definite purposes. Authorized partners can only access the information they need to perform their duties, and cannot use this information for any other purposes.
At present, our authorized partners include the following types:
(1) Authorized partners of advertising and analysis services. Unless we obtain your permission, we will not share your personal identity information (information that identifies you, such as name or e-mail, through which you can be contacted or identified) with partners providing advertising and analysis services. We will provide these partners with information about their advertising coverage and effectiveness, not your personal identity information, or we will aggregate this information so that they will not identify you personally. For example, only after advertisers agree to abide by our advertising guidelines can we tell advertisers how effective their advertisements are, or how many people have viewed their advertisements or installed applications after viewing them, or provide statistical information (e.g., "male, 25-29 years old, located in Beijing") to help them know their audience or customers without identifying the individual.
(2) Suppliers, service providers and other partners. We send information to suppliers, service providers and other partners who support our business, including providing technical infrastructure services, analyzing the way we use our services, measuring the effectiveness of advertising and services, providing customer services or conducting academic research and investigation.
For companies, organizations and individuals with whom we share personal information, we will sign strict data protection agreements with them, requiring them to process personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.
(II) Transfer
We will not transfer your personal information to any company, organization or individual except in the following cases:
1. Transfer with your explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
2. In the case of merger, acquisition or bankruptcy liquidation of the service provider of Visit Shanghai APP, or other cases involving merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require new companies and organizations holding your personal information to continue to be bound by this Policy. Otherwise, we will request the companies, organizations and individuals to seek consent from you again.
(III) Public disclosure
We will publicly disclose your personal information only in the following cases:
1. With your explicit consent or on your own initiative, we may publicly disclose your personal information.
2. If we confirm that you have violated laws and regulations or seriously violated the relevant agreements and rules of Visit Shanghai APP, or in order to hold harmless the personal property of Visit Shanghai APP’s affiliated companies or other users or the public, we may, with your consent, disclose personal information about you, including related violations and the measures taken by Visit Shanghai APP against you, in accordance with laws and regulations or relevant agreements and rules of Visit Shanghai APP. For example, if you sell fake goods in serious violation of the rules of Visit Shanghai APP, we may publicly disclose the subject information and penalties of your store.
(IV) Exceptions to prior consent for sharing, transferring or publicly disclosing personal information
In the following cases, sharing, transferring and publicly disclosing your personal information does not require prior consent from you:
1. Relating to national security and national defense security;
2. Relating to public safety, public health and major public interests;
3. Relating to criminal investigation, prosecution, trial and execution of judgments;
4. In order to safeguard your or others’ life, property and other major legitimate rights and interests, while it is difficult to obtain your consent;
5. Personal information that you disclose to the public on your own;
6. Collecting personal information from lawfully disclosed information, such as legitimate news reports, information disclosure by the government, etc.
According to the law, sharing and transferring personal information which has been de-identified while ensuring that the data recipient cannot restore the personal information and re-identify the subject, shall not be an act of external sharing, transferring and public disclosure of personal information. The preservation and processing of such data will not need to be notified to you separately and obtain your consent.
IV. How do we protect your personal information
(I) We have taken reasonable and feasible safety measures in accordance with industry standards to protect the personal information provided by you, and to prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information. For example, when exchanging data between your browser and server, you are protected by the encryption protocol of SSL (Secure Socket Layer); we will use encryption technology to improve the security of personal information; we will use trusted protection mechanism to prevent malicious attacks on personal information; we will deploy access control mechanism to ensure that only authorized personnel can access personal information; and we will organize security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.
(II) We have an advanced data-centered data security management system with the data life cycle as the basis in the industry, and thus we can improve the security of the whole system from the aspects of organizational construction, system design, personnel management, product technology and so on.
(III) We will take reasonable and feasible measures to avoid collecting irrelevant personal information. We will retain your personal information only within the time required to achieve the objectives set out in this Policy, unless it is necessary to extend the retention period or permitted by law.
(IV) The Internet is not an absolutely safe environment. We strongly recommend that you do not send personal information through communication means not recommended by Visit Shanghai APP. You can connect and share with each other through our services. When you create communication, trading or sharing through our services, you can choose the object of communication, trading or sharing as the third party who can see your transaction content, contact information, exchange information or shared content.
When using Visit Shanghai App’ service for online trading, you will inevitably disclose your personal information, such as traveler, contact information or contact address, to the counterparty or potential counterparty. Please protect your personal information properly and provide it to others only when necessary. If you find that your personal information, especially your account or password, has been leaked, please contact the Customer Service of Visit Shanghai App immediately, so that we can take appropriate measures according to your application.
Please note that the information you voluntarily share or even publicly share when using our services may involve personal information or even personal sensitive information of you or others, such as uploading pictures containing personal information when evaluating. Please consider more carefully whether to share or even publicly share relevant information when using our services.
Please use complex passwords to help us ensure the security of your account. We will try our best to ensure the security of any information you send us. If our physical, technical or management protective facilities are damaged, resulting in unauthorized access to information, public disclosure, tampering or destruction, resulting in damage to your legitimate rights and interests, we will bear the corresponding legal responsibility.
(V) We will update and publish the security risk and personal information security impact assessment report from time to time. You can get it by announcement from Visit Shanghai APP.
(VI) After unfortunate personal information security incidents occur, we will inform you of the basic situation and possible impact of security incidents, the handling measures we have taken or will take, the measures you can take to prevent and reduce risks, and the remedial measures for you, as required by laws and regulations. We will inform you of the relevant situation by email, letter, telephone, push notification and so on. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to publish the announcement
At the same time, we will report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.
V. How do you manage your personal information
Visit Shanghai APP’s Members Information
For your membership information of Visit Shanghai APP, you can manage it in the following ways:
1. Access your membership information
Account information: If you want to access or edit the personal information and payment information, change your login password, change the bound mobile phone, or exit the current account in your membership account in Visit Shanghai APP, you can perform such operations in "My" of the mobile phone client side of Visit Shanghai APP.
Order information: You can view or delete your order record and transaction record in "My" – “Order Center” of the mobile phone client side of Visit Shanghai APP.
If you cannot access such personal information through the above path, you can contact us at any time by the Customer Service of Visit Shanghai APP. We will reply to your request within 15 days.
For other personal information generated during the use of our products or services, we will provide you with the relevant arrangements based on "7. Respond to your above request" of this Article
2. Correct or supplement your membership information
You have the right to request us to make corrections or additions when you find that there are errors in your personal information we process. You can apply for corrections or supplements by methods specified in “1. Access your membership information”.
3. Delete your membership information
You can delete some of your membership information by methods specified in “1. Access your membership information”.
In the following cases, you can request us to delete membership information:
A. If we deal with personal information in violation of laws and regulations;
B. If we collect and use your personal information without your explicit consent;
C. If we deal with personal information seriously in violation of our agreement with you;
D. If you no longer use our products or services, or you deregister your account on your own initiative;
E. If we never provide you with products or services.
If we decide to respond to your deletion request, we will also notify the subjects who have obtained your personal information from us as far as possible, and request such subjects to delete your personal information in time, unless otherwise stipulated by laws and regulations, or if these subjects are authorized by you independently.
When you delete information from our services, we may not delete it from the backup system immediately, but we will delete it when the backup updates.
4. Change the scope of your consent
Each business function requires some basic personal information to be completed (see Article 1, Section II of this Privacy Policy). In addition, for the collection and use of additional personal information, you can contact Visit Shanghai APP’s Customer Service to give or withdraw your consent.
When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the personal information processing previously carried out based on your authorization.
5. Deregister accounts by personal information subjects
After you deregister your account voluntarily, we will stop providing you with products or services, delete your personal information or make it anonymous according to the applicable law.
6. Restrict the automatic decision-making of the information system
In some business functions, we may only make decisions based on non-manual automatic decision-making mechanisms such as information systems, algorithms, etc. If these decisions have a significant impact on your legitimate rights and interests, you have the right to request us for an explanation thereto. We will also provide a complaint method without infringing on the business secrets of Visit Shanghai APP’s or other users’ rights and interests as well as the public interest.
7. Respond to your above request
To ensure your safety, you may need to provide a written request or otherwise prove your identity. We may request you to verify your identity before processing your request.
We will reply within 15 days. If you are not satisfied, you can also initiate complaints through Visit Shanghai APP’s Customer Service.
For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed the reasonable limit, we will charge a certain cost according to the circumstances. We may reject requests that are unreasonably repeated and require too many technical tools (e.g., the need to develop new systems or fundamentally change current practices), that pose risks to the legitimate rights and interests of others, or that are highly impractical.
In the following cases, as required by laws and regulations, we will not be able to respond to your request:
A. Relating to national security and national defense security;
B. Relating to public safety, public health and major public interests;
C. Relating to criminal investigation, prosecution, trial and execution of judgments;
D. If there is sufficient evidence that the subject of personal information has subjective malice or abuse of rights;
E. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations.
F. Involving trade secrets.
VI. How do we deal with minors' personal information
Minors may not create their own user accounts without the consent of their parents or guardians. If you are a minor, it is recommended that you ask your parents or guardians to read this Privacy Policy carefully and use our services or provide us with information with the consent of your parents or guardians.
Personal information of minors provided by you for purchasing commodities or booking services for minors (such as air tickets, hotels, visas, etc.) and personal information of minors collected with the consent of parents or guardians for using our products or services will only be used, shared, transferred or disclosed if laws and regulations so permit, parents or guardians explicitly so consent or necessary for the protection of minors.
VII. How can your personal information be transferred globally
Personal information collected and generated during the operation in the People's Republic of China shall be stored in the territory of China, except in the following circumstances:
1. As explicitly provided by laws and regulations;
2. With your explicit authorization;
3. Cross-border transactions (such as purchasing international air tickets, booking international hotels) through the Internet by yourself and other activities on your own initiative.
In view of the above situation, we will ensure that your personal information is adequately protected in accordance with this Privacy Policy.
VIII. How to update this Privacy Policy
Our Privacy Policy may be subject to changes.
Without your explicit consent, we will not restrict your rights under this Privacy Policy.
We will inform you of material amendments to this Privacy Policy in a more conspicuous way (including by notification through Visit Shanghai APP or even by pop-up reminder).
Major changes referred to in this Policy include, but are not limited to:
1. Significant changes have taken place in our service model. Such as the purpose of personal information processing, the type of personal information subject to processing, the way of using personal information, etc.
2. Significant changes have taken place in terms of control rights. For example, ownership changes caused by M&A, reorganization, etc.
3. The main objects of personal information sharing, transfer or public disclosure have changed.
4. Significant changes have taken place in your right to participate in personal information processing and the exercise method thereto.
5. When the responsible department, contact information and complaint channels for personal information security change;
6. When the personal information security impact assessment report indicates that there is a high risk.
IX. How to contact us
You can contact us by the following means, and we will reply to your request within 15 days:
1. We have set up a personal information protection department. If you have any questions, comments or suggestions on the content of this Policy, you can contact us through the online customer service of Visit Shanghai APP’s Customer Service Center.
2. If you are not satisfied with our reply, especially when you think that our personal information processing actions have damaged your legitimate rights and interests, you can also seek solutions by filing a lawsuit in a competent court of the place where Shanghai City Image Promotion Co., Ltd. is located.