Privacy Policy

Last Updated: May 8, 2024

Pixelhue Technology Ltd. (hereinafter referred to as “Pixelhue” or “we”) are committed to protecting and respecting your privacy. Therefore, we have developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal data while you use Spirit Stone visual control platform (SVCP) software or services (“Services”). Please read carefully and familiarize yourself with our privacy practices before using our Services or providing your personal data.

This policy will help you understand the following:

 

I     Definitions

II    How We Collect and Use Your Personal Data

III    How Long We Keep Your Personal Data

IV    How We Disclose Your Personal Data

V     How We Protect Your Personal Data

VI    Your Rights with Regards to Your Personal Data

VII    How We Process Children's Personal Data

VIII   How Your Personal Data Is Transferred Globally

IX    How This Privacy Policy is Updated

X     Contacting us

 

I Definitions

“Affiliated Company” refers to a company that is related to Pixelhue due to joint ownership or control.

“Third Parties” refer to companies or persons who do not have a related relationship arising out of joint ownership or control with Pixelhue (i.e., a non-affiliated company) or other non-related persons. Third parties can be financial or non-financial companies, or persons other than you and Pixelhue.

“Personal Data” refers to any information relating to an identified or identifiable natural person.

 

II How We Collect and Use Your Personal Data

1. Personal data we collect

Personal data directly provided by you

The Services we provide don’t require you to provide certain personal data directly to us. Thus we may not collect your personal data by providing Services.

We may ask you to provide personal data under other circumstances, such as when you contact us for customer support, register to receive our questionnaire survey, newsletter, or participate in promotional or marketing activities organized by us or our business partners. The information you provide helps us design and improve the Services. We may match your personal data with third-party data to better understand your needs.

 

2. How we use your personal data

(1) We may process your personal data for the purposes described in this Privacy Policy, to perform our obligations to you under our user agreement and/or service contract,

a. with your prior explicit consent which can be withdrawn at any time at your request;

 

b. so that we can perform or carry out a contract with you in relation to our Services;

 

c. for compliance with a legal obligation to which Pixelhue is subject;

 

d. when necessary for the purposes of the legitimate interests pursued by Pixelhue or a third party to whom it may be necessary to disclose information. Where we process your information in reliance on such grounds, we will only do so where we have appropriately balanced such interests against your right to privacy. Such legitimate interests may include (without limitation), as follows:

  Customer support.We use data to diagnose product issues, repair customer equipment, and provide other customer care and support services. We may also collect your phone number, email address, social media account such as WeChat and Skype to reply your questions or comments.

  Commercial promotion activities.If you register to receive our newsletter, or participate in promotional or marketing activities organized by us or our business partners, we will use the personal data you provide to manage such activities.

 

(2) We will strictly abide by the terms of this Privacy Policy and any updates to it (any material changes to the Privacy Policy will be notified to you according to Section IX) when we use your personal data. Your personal data will only be used for the purposes determined at the time it is collected.

 

(3) When we want to use the information for other purposes not covered by this Privacy Policy, we will notify you and ensure we comply with applicable requirements.

 

(4) We do not take any decisions involving the use of algorithms or profiling that significantly affects you. If certain of our Services require us to do so in the future, we will inform you in advance.

 

III How Long We Keep Your Personal Data

Our retention period for personal data is the minimum time necessary to realise the purpose of collection unless a longer retention period is required by law. Beyond the above retention period, we will delete or anonymise your personal data.

 

IV How We Disclose Your Personal Data

1. At times Pixelhue may make certain personal data available to affiliated companies and other third parties that work with Pixelhue necessary to provide Services. Your information will not be shared with third parties for their own independent marketing or commercial purposes.

(1) Affiliated Companies: your personal data may be shared with Pixelhue’s affiliated companies. We only share necessary personal data subject to the purposes stated in this Privacy Policy.

(2) Sharing with other third parties: to realise the purposes stated in this Policy, some of our Services will be provided by other third parties. We may share some personal data with them to provide better services and user experience.

(3) If we sell any of our business or assets, we may need to disclose your personal data to the prospective buyer for due diligence purposes and on completion of the sale.

We will only share your personal data for lawful, legitimate, necessary, specific and clear purposes, and only personal data necessary for service provision will be shared. Our partners are not allowed to use the shared personal data for any other purposes.

2. We will only publicly disclose your personal data under the following circumstances:

(1) After we obtain your explicit consent;

(2) Disclose in accordance with laws: we may disclose your personal data if it is compulsorily required by laws, such as to comply with a subpoena or other legal proceedings, legal actions or government agencies, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

 

V How We Protect Your Personal Data

1. We have taken reasonably practical and technical measures to protect the collected personal data related to our Services. While we have taken reasonable measures to protect your information, no websites, Internet transmissions, computer systems or wireless connections are absolutely secure.

2. We have taken safeguarding measures in accordance with industry standards to protect the personal data you provided and prevent data from unauthorised access, public disclosure, use, modification, damage or loss. ?

3. In case of personal data security incident, we will act, in accordance with the applicable law.

 

VI Your Rights to Your Personal Data

We respect your legal rights to your personal data. We list below your legal rights and the measures we take to protect these rights.

1. The right to be informed: Pixelhue is publishing this Privacy Policy to keep you informed as to what we do with your personal data. We strive to be transparent about how we use your data.

2. The right to access: If you wish to access your personal data, you are entitled to ask us.

3. The right to rectification: If you find that your personal data we hold is inaccurate or incomplete, you are entitled to ask us to make rectifications.

4. The right to erasure: You can submit a request to us to delete personal data if we do not have a legal reason to continue to process and hold it.

5. The right to restriction of processing: You have the right to ask us to restrict how we process your personal data. This means we are permitted to store the data but not further process it unless we are legally entitled to continue processing.

6. The right to data portability: To the extent permitted by laws and regulations, you have the right to obtain a copy of your personal data in a structured, commonly used and machine-readable format.

7. The right to object: You have the right to object to Pixelhue processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purpose of statistics.

8. The right to withdraw consent: If you have given us your consent to process your personal data but change your mind later, you have the right to withdraw your consent at any time, and Pixelhue must stop processing your data.

9. The right to object automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling.

10. The right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process your personal data with the data protection authority of your jurisdiction.

 

You can exercise your rights by submitting a request to support@hynamic.cn. In principle, we do not charge a fee for your reasonable request. However, for multiple and repetitive requests that exceed reasonable limit, we may charge a reasonable fee to cover some costs depending on the nature of the request. We may refuse requests that are manifestly unfounded, unreasonably repetitive, or require disproportionate technical effort (for instance, require the development of new systems). In addition, we may not respond to requests that directly concern significant issues of public interest or may cause serious damage to the legitimate rights and interests of you or other individuals or entities.

 

VII How We Process Children’s Personal Data

1. Our Services are mainly adult-oriented and may not be used by children without guardian consent. A child should not create his/her own user account. We treat anyone under 16 years old (or equivalent minimum age for full legal capacity in relevant jurisdiction) as a child.

2. When we find that a child’s personal data is collected without expressed and verifiable guardian’s consent, we will delete the relevant data as soon as reasonably possible.

 

VIII How Your Personal Data Is Transferred Globally

1. We provide Services through resources and servers around the world. This means, in compliance with applicable laws, your personal data might be transferred to or accessed from?jurisdictions outside of the jurisdiction where you use our products or services.

2. In case your personal data is transferred to countries located outside of the European Economic Area (EEA) and United Kingdom (UK), we will ensure that it will be protected in a manner that is consistent with legal requirements. This can be done in a number of different ways, such as:

(1) the recipient of the personal data is located within a country that benefits from a full “adequacy” decision of the European Commission;

(2) the recipient may have adhered to binding corporate rules (only for intragroup transfers); or

(3) the recipient has signed a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data.

The personal data that we collect from you may also be otherwise transferred to, and stored at, destinations outside the EEA or UK. It may also be processed by individuals operating outside of the EEA and UK who work for our affiliates or for one of our suppliers.

In all cases, however, we will ensure that any transfer of your personal data is compliant with the applicable data protection law.

 

IX How This Privacy Policy Is Updated

We reserve the right to update or modify this Privacy Policy from time to time. If there is any material change to this Privacy Policy, we will notify you by posting a notice on our website or by sending you an email notice or in a form we deem appropriate.

 

X Contacting us

Pixelhue Technology Ltd. is the controller of your personal data

If you have questions or concerns regarding our Privacy Policy or practices, please contact us at:

[Room 612, 5 / F, 15 West Fourth Ring North Road, Haidian District, Beijing,China]

Email: support@hynamic.cn