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NextVPU Account User Agreement

Welcome to register and use NextVPU Account!

This Agreement is entered into by and between you and NextVPU (Shanghai) Co.,Ltd. with respect to the registration and use of the NextVPU Account. NextVPU (Shanghai) Co.,Ltd. (hereinafter referred to as “NextVPU”) hereby reminds you to carefully read and fully understand the terms and conditions of this Agreement, especially the clause of service fees, the exemption and limitation of NextVPU’s liability, restrictions on your rights, dispute resolution, applicable law, etc. These terms are emphasized in bold form. Please read carefully and choose to accept or not accept this Agreement (minors shall be under the guidance of a guardian or legal representative while reading this Agreement). You shall not have the right to register and use NextVPU Account unless you accept all the terms and conditions of this Agreement. Your registration and continuing use of the NextVPU Account will be deemed that you have fully understood this Agreement and agree to be bound by the terms and conditions of this Agreement.

I. Introduction to NextVPU Account

1. NextVPU Account refers to the identification tool which is owned and managed by NextVPU and which is used for verifying the identity of the user. As a registered user, you only have the right to use the NextVPU Account initially registered in your own name.

2. You may enjoy the services including but not limited to NextVPU Website, NextVPU Store, NextVPU forum, provided by NextVPU and its affiliates by registering for a NextVPU Account.

3. All the products and services of NextVPU and its affiliates shall be governed by this Agreement. When you enjoy any individual service, you shall be bound by the terms and conditions of this Agreement.

II. Use Rules of Account

1. Registration of Account

1.1 Before you start the registration procedure and use NextVPU Account, you shall be a person with full capacity for civil conduct. Minors are permitted to use NextVPU Account only with the consent of their parent or guardian. You are subject to, and are solely responsible for abidance by all laws and regulations of the jurisdiction in which you reside and from which you access or use NextVPU Account.

1.2 You shall provide timely, detailed and accurate personal information, and constantly update the registration information in line with the aforementioned requirements. You warrant that all information you have submitted at the time of registration (including but not limited to mobile phone number, email address.) is truthful, accurate, legal, and valid and belongs solely to you. NextVPU will not be responsible for any related problems arising from untruthful registration information or untimely updates. You may check and correct your information on the NextVPU Account setting web pages. You shall use the real identity information to authenticate the registered account, and all registration information such as the account name, avatar and profile submitted by you shall not be illegal or harmful. If the above situation exists after NextVPU’s examination, the registration will not be allowed by NextVPU; meanwhile, after the registration, if NextVPU finds that you swindle the account name for registration with false information, or if your account avatar, profile and other registration information are illegal or harmful, NextVPU has the right to take measures unilaterally, including but not limited to requesting correction within a time limit, suspending of use and termination the use of your account. You will have a right to use NextVPU Account and become a NextVPU user if you follow the registration page prompts to fill out the information, read and accept all the terms of this Agreement and complete all registration procedures.


2. Use of Account

2.1 You shall be responsible for all acts related to your NextVPU Account.

2.2 Your NextVPU Account contains the details about your personal information and NextVPU business information, therefore your NextVPU Account is for your personal use only. Without the consent of NextVPU, the behavior that you directly or indirectly authorize a third party to use your NextVPU Account or obtain information related to your account is invalid. If NextVPU determines that the use of your NextVPU Account may endanger the security of your account and NextVPU's information safety, NextVPU may refuse to provide services or terminate this Agreement.

2.3 If you choose to log in NextVPU's service using a third-party account, the third-party account will be associated with your NextVPU Account. NextVPU will use your information (such as avatar) in accordance with the information you provide to the third party. Your subsequent conducts of the use of such NextVPU Account shall be subject to this Agreement.


3. Custody and Retrieval of Account

3.1 NextVPU Account includes account name and password. You may log in with the created account name (including account ID, mobile phone number) and password. You shall safeguard your account and password, and change your password regularly.If you need to retrieve the NextVPU Account information due to losing account issue caused by yourself, please provide the corresponding information in accordance with the process of NextVPU Account retrieval, and ensure that the information provided is legal, truthful and valid. If the information provided fails to meet the requirements and cannot pass the NextVPU security verification, NextVPU has the right to refuse to provide account retrieval service;

3.2 If your current NextVPU Account is not initially registered by yourself or is obtained through other ways provided by NextVPU, provided that you know the password of such NextVPU Account, you shall not log in with such NextVPU Account or take any action except notifying NextVPU or the person initially registered this NextVPU Account.


4. Assignment of Account

4.1 You may use the NextVPU Account within the scope as agreed in this Agreement. You shall not maliciously register the NextVPU Account, nor give, borrow, rent, assign or sell the NextVPU Account with or without compensation, or otherwise permit the non-initial registrant to use the NextVPU Account. NextVPU has the right to independently determine and deal with the aforementioned behaviors.

4.2 NextVPU has the right to take the following measures against you in accordance with laws and regulations:

4.2.1 If you violate laws and regulations, NextVPU has the right to make independent judgments and take measures, including but not limited to requesting correction within a time limit, suspending of use, termination the use of your NextVPU Account, and to decide whether to resume the use of such account pursuant to actual conditions.

4.2.2 If NextVPU finds that you are not the initial registrant for such account, NextVPU has the right to terminate the use of your account.

4.2.3 NextVPU will, in accordance with this Agreement or relevant laws and regulations, require you to correct within a time limit, suspend or terminate the use of your NextVPU Account.


5. Account Withdrawal

5.1 In order to make full use of the resources available through your NextVPU Account, if you fail to login your NextVPU Account for 24 consecutive months or login your account through other methods approved by NextVPU, NextVPU has the right to terminate the use of your NextVPU Account and discontinue its provision of services to you. If there is any pending transaction or balance and the like related to this account, NextVPU may assist you in the reasonable manner. Please follow the instructions of NextVPU.


6. Account Security

6.1 Your account is created and safeguarded by yourself. NextVPU will not require you to provide your password at any time. We recommend that you take appropriate measures to protect your account, including but not limited to installing anti-virus Trojan software, changing your password regularly.

6.2 NextVPU will not be liable for any losses and consequences arising out of your accidental disclosure, attacks or fraud by others. You shall recover from the infringer through judicial, administrative authorities and other remedies.


7. Account Cancellation

7.1 You may apply for cancellation of your NextVPU Account if you decide to terminate the use of NextVPU Account service. And the following conditions shall be fulfilled.

7.1.1 You may only apply for cancellation of your own account in accordance with NextVPU's process;

7.1.2 You shall still be responsible for your behaviors when you enjoy the NextVPU services prior to cancellation of your NextVPU Account.

7.1.3 You shall be aware that the termination of NextVPU Account means user information will be removed from NextVPU's database.


III. User’s Rights and Obligations

1. You are subject to, and are solely responsible for abidance by all laws and regulations of the jurisdiction in which you reside and from which you access or use NextVPU Account. When you use NextVPU services in the People’s Republic of China, you shall not use NextVPU services for any illegal or improper activities, including but not limited to the following activities:

1.1 Uploading, displaying, posting, spreading or otherwise transmitting information containing one of the following contents:

· 1.1.1 Opposing the basic principles specified in the Constitution;

· 1.1.2 Endangering national security, revealing state secrets, subverting state power, and undermining national unity;

· 1.1.3 Damaging the country's honors and interests;

· 1.1.4 Inciting ethnic hatred, ethnic discrimination, and destruction of national unity;

· 1.1.5 Breaking religious policies of the State, or blazoning forth evil cults or feudal superstition;

· 1.1.6 Disseminating rumors, disrupting social order and undermining social stability;

· 1.1.7 Spreading obscenity, pornography, violence, encouraging gambling, murder or terrorism;

· 1.1.8 Insulting or slandering others and infringing the legal rights of others;

· 1.1.9 Containing false, harmful, coercive content, and invasion of privacy, harassment, infringement, slander, vulgarity, obscenity, or otherwise morally objectionable content;

· 1.1.10 Report and comments on social public affairs including but not limited to political, economic, military and diplomatic, and social emergency events;

· 1.1.11 Involving other contents restricted or prohibited by Chinese laws, regulations, rules, ordinances and any legally binding norms;

1.2 Do not use the NextVPU services to engage in the following activities:

· 1.2.1 Entering the computer information network or using computer information network resources, without permission;

· 1.2.2 Deleting, modifying or adding the computer information network function, without permission;

· 1.2.3 Deleting, modifying or adding the data and applications stored, processed or transmitted in the computer information network, without permission;

· 1.2.4 Deliberately making and disseminating destructive programs such as computer viruses and the like;

· 1.2.5 Conducting any commercial activities such as advertising, sale of goods, or any illegal acts that infringe on the interests of NextVPU, such as selling coins, game coins, plug-ins, and props, etc.;

· 1.2.6 Other behaviors that endanger computer information network security.

2. If there is any claim, requirement or loss (including reasonable attorney feesasserted by any third party against NextVPU, NextVPU’s partner companies and affiliates arising from your violation of the provisions of this Agreement or the relevant terms of services, you agree to indemnify and hold harmless NextVPU, NextVPU’s partner companies and affiliates from any damage. At the same time, NextVPU has the right, depending on the nature of your conduct, to take measures including but not limited to deleting the published information, suspending the use of the NextVPU Account, terminating the services, restricting the use of the NextVPU Account, and seeking liability. Meanwhile, NextVPU will assist the investigation at the requirements of the judicial departments.

3. You shall not replicate, copy, sell, resell or use for any other commercial purposes concerning any part of NextVPU services or the use or acquisition of the NextVPU services.

4. You shall be legally responsible for your behaviors in the use of NextVPU services. The forms of legal liabilities include but are not limited to, compensation for the victim, and the equivalent compensation that you shall reimburse to NextVPU after NextVPU first assumes the responsibility for administrative punishment or tort damage arising from your behaviors.


IV. Disclaimer

1. NextVPU shall not assume any legal liability in any of the following circumstances:

1.1 Providing your personal information to third parties in accordance with legal provisions or at the requirements of relevant government departments;

1.2 Any disclosure of any personal information arising from improper use by yourself or other reasons;

1.3 Any circumstance that fails to meet your requirements arising out of service interruption, blockage, etc. caused by hacker attacks, invasion of computer viruses, illegal information, shielding of harassment information, government regulations, and any other reasons such as network, technology, communication lines, information security management measures, etc.;

1.4 Any circumstance arising from third party’s (such as operator's) communication line failures, technical problems, network issues, computer failure, system instability and other losses caused by force majeure;

1.5 Any risk arising from the use of NextVPU’s products, programs and services that may have anonymous or impersonating information containing threats, defamatory, offensive or illegal content;

1.6 Any interaction between users and other users through this website or NextVPU’s products, programs and services, results in or may result in any psychological, physical damage and economic loss due to misleading or deceptive;

1.7 NextVPU services expressly declares that the timeliness, safety and accuracy of NextVPU and its partner companies' services are not guaranteed by express, implied or in any form.

1.8 No content posted by you using the NextVPU Account shall be represent and reflect any opinions or policies of NextVPU, and NextVPU shall not be responsible for it.

1.9 Under no circumstances shall NextVPU be liable for any indirect, consequential, punitive, incidental, special or penal damages, including but not limited loss of profits arising from your use of the NextVPU services. Notwithstanding any conflicting provision contained herein, our entire liability to you, whatever any reason or any behavior, shall not exceed the fees (if any) that you paid to NextVPU for the use of the NextVPU Service during the registration period.

2. You may choose to use your existing third-party account to associate the NextVPU Account. NextVPU shall be not responsible for any damage caused to you by third party’s reason.


V. Intellectual Property Rights

1. The information you publish in NextVPU shall not infringe the intellectual property rights of any third party. Without the prior written consent of the relevant intellectual property owner, you shall not, upload, post, modify, spread or replicate any copyrighted materials, trademarks or proprietary information belonging to others by any means. After receiving appropriate notice from any copyright owner or its legal representative to NextVPU, we will remove such content of the copyright infringement based on the appropriate examination.

2. The intellectual property rights of the original contents (such as the texts, pictures and software) posted and uploaded by enjoying NextVPU Service through NextVPU Account belong to you, provided that you confirm that your publication and uploading of such contents shall be deemed that you non-exclusively, permanently and irrevocably authorize NextVPU to use, copy, and exercise other rights of all intellectual property rights relating to such contents, and you agree that NextVPU may sublicense above-mentioned rights.

3. You shall not use any intellectual property rights of NextVPU without prior written consent of NextVPU. You warrant, represent and undertake that you respect the intellectual property rights of NextVPU. You will not apply or allow any third party to apply for any trademark, domain name, wireless website, Internet search term or any trade name, service mark similar to the brand of NextVPU or its affiliates for any marketing, advertising, promotion or other purposes by any means in any jurisdiction. In the event of the above circumstances, you shall transfer all relevant rights to NextVPU at your expense. You warrant, represent and undertake that you will not use the following names (including but not limited to “Zhao Guan”, “NextVPU”, “Tian Shi Yan”, “AngelEye”, etc.), and the affiliated logos and designs of the above brands (including but not limited to etc.), as part of the name of the company, merchant, service or product, nor will use intellectual property rights of the NextVPU trademark or similar trademark. The loss caused to NextVPU arising from your violation of the provisions of this Article shall be borne by you.

VI. Amendment

1. In consideration of the rapid development of Internet-related technologies, markets, business models, etc., you agree that NextVPU has the right to regularly formulate and revise this Agreement and various rules in accordance with the changes of relevant laws and regulations of the People's Republic of China, the development of the Internet, and the adjustment of the company's operating conditions and business strategies. If there is any amendment, NextVPU will notify you of the changes by relevant means. If you disagree with the above amendments, you shall immediately stop using the services under this Agreement. Your logging into or continuing to use the NextVPU services means that you recognize and accept the revised agreements and rules.


VII. Termination

1. This Agreement shall become effective as of the date of your acceptance, and shall remain in force during your use of the NextVPU services until terminated in accordance with this Agreement;

2. Notwithstanding the foregoing, if you use the NextVPU services before you accept this Agreement, you hereby know and agree that this Agreement will be effective for the first time you use the NextVPU services, unless terminated earlier in accordance with this Agreement.

3. We may reserve right to allow you to use the NextVPU services or NextVPU Account in accordance with the law; we have the right to terminate this Agreement at any time for any reason with or without notice, including NextVPU believe that you have violated our user policy or other provisions of this Agreement.

4. Without being subject to the provisions of the preceding paragraph, if you infringe the copyright of a third party, and NextVPU receives a notice from the copyright owner or its legal representative, NextVPU reserves the right to terminate this Agreement.


VIII. Miscellaneous

1. Feedback

1.1 Your suggestion (or “feedback”) to NextVPU shall be deemed that you transfer all rights of “feedback” to NextVPU, and agree that NextVPU has the right to use this “feedback” and related information in any reasonable way. NextVPU will treat such feedback information as non-confidential and non-proprietary;

1.2 You agree that you will not provide NextVPU with any information that you consider to be confidential and proprietary;

2. Privacy Policy

2.1 Please refer to our “Privacy Policy” that has the same effect with this Agreement and is an integral part of this Agreement.

3. Notice

3.1 You shall provide a valid email address or cellphone number.. Notices of announcements issued by NextVPU sent to you constitute a valid notice.

4. Applicable Law

4.1 This Agreement shall be governed by the laws of the People's Republic of China.

4.2 If there is any dispute between the parties, the dispute shall be settled through friendly negotiation; if the negotiation fails, either parties shall file a lawsuit in the People's Court of Pudong New District, Shanghai. In the event of any conflict between the terms of Independent Agreements and this Agreements on the issue of jurisdiction, the Independent Agreements shall prevail.

5. Independence

5.1 If any provision of this Agreement is invalid or unenforceable for any reason, then that provision shall be modified in order to be valid and enforceable in accordance with the law. However, the remaining provisions of this Agreement shall remain valid and binding.

Privacy Policy

NextVPU (Shanghai) Co.,Ltd. and its affiliates (collectively, " NextVPU", "we", "us", and "our") respect your privacy. Please read the following to learn more about our Privacy Policy ("this Policy"). This Policy applies to Huawei websites, products, and services that display or provide links to this Policy.

This Policy describes how NextVPU processes your personal data, but it may not address all possible data processing scenarios. NextVPU may inform you of product- or service-specific data collection through supplementary policies or notices provided before collection.

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

Our commitment to you

This Privacy Policy sets out how we collect, use, disclose, process and protect any information that you give us when you use our products and services located atAngelEye reader app (hereinafter referred to as “App”), and our Suite of applications that we offer on our mobile devices. Should we ask you to provide certain information by which you can be identified when using NextVPU products and services, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, as well as full confidence that ultimately, you have control of any personal information provided to NextVPU.

In 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 NextVPU has access about that individual. Such personal information may include but not limit to the information you provide to us or upload, the information specific to you that may be assigned by us, your financial information, social information, device or sim-related information, location information, log information.

By using NextVPU products and services or other acting permitted by the applicable laws, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time. In order to comply with applicable laws, including local data protection legislation (e. g. General Data Protection Regulation in Europe Union), we will specifically seek prior explicit consent to the particular processing of special categories of personal data. Furthermore, we are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, and we are equally committed to ensuring that all our employees and agents uphold these obligations.

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarized in this Privacy Policy, please contact  dpo@nextvpu.com  to address your specific concerns. We will be happy to address them directly.

What information is collected and how can we use it?

Types of information collected

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. If you do not provide your personal information, we may not be able to provide you with our products or services.

We will only collect the information that is necessary for its specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. We may collect the following types of information (which may or may not be personal information):

· Information you provide to us or upload (including your contact details): we may collect any and all personal information you provide to us, like your name, gender, age, visual status, mobile phone number, email address, delivery address, order, invoicing details, having AngelEye series products or not you may sync through NextVPU forum, information in relation to creating an account and participating in the NextVPU Forum, phone numbers you insert into your contacts or to send a message, feedback, and any other information you provide us.

· Information specific to you that may be assigned by us: we may collect and use information such as your NextVPU Account ID.

· Information specific to you that may be assigned by Third Party Service Providers: we may collect and use information such as your advertising ID assigned by Third Party Service Providers.

· Financial information: information related to completing purchases. For example, bank account number, account holder name, credit card number etc.

· Social information: information related to your social activities. For example, name, gender, age, visual status, mobile phone number etc.

· Device or SIM-related information: information related to your device. For example, IMEI number, IMSI number, MAC address, Serial number, Android version, Android ID, screen display information, device keypad information, device manufacturer details and model name, network operator, connection type, hardware usage information such as battery usage, device temperature.

· Application information: information related to your software usage. For example, application status record (e.g. downloading, installing, updating, deleting), application ID information, SDK version etc.

· Location information (only for specific services/functionalities): various types of information on your location. For example, region, country code, city code, mobile network code, mobile country code, cell identity, longitude and latitude information, time zone settings, language settings.

· Log information: information related to your use of certain functions, apps and websites. For example, cookies and other anonymous identifier technologies, IP addresses, network request information, temporary message history, standard system logs, crash information.

· Other information: environmental characteristics value (ECV) (i.e. value generated from NextVPU Account ID, phone device ID, connected Wi-Fi ID and location value).

We may also collect other types of information which are not directly or indirectly linked to an individual and which is aggregated, anonymized or de-identified. For example, the device model and system version number of the user’s NextVPU mobile phone device may be collected when using a particular service. Such information is collected in order to improve the services we provide to you.

How the personal information can be used

Personal information is collected for providing services and / or products to you, and legal compliance on our part under applicable laws. You hereby consent that we may process and disclose personal information to our affiliated companies (which are in the communications, social media, technology and cloud businesses), Third Party Service Providers (defined below) for the purposes stated in this Privacy Policy.

We may use your personal information for the following purposes:

· Providing, processing, maintaining, improving and developing our goods and/or services to you, including after-sales and customer support and for services on your device or through our websites.

· Communicating with you about your device, service or any general queries, such as updates, customer inquiry support, information about our events, notices.

· Conducting marketing related activities, such as providing marketing and promotional materials and updates. For more information on marketing and promotional activities, please refer to the Direct Marketing section below.

· Allowing you to post appropriate comments in NextVPU forums.

· Conducting promotional activities, such as sweepstakes and events on social media platforms.

· Analyzing and developing statistical information on use of our products and services to better improve our products and services.

· Optimizing the performance of your device, such as analyzing the memory usage or CPU utilization of our applications.

· Storing and maintaining information about you for our business operations or legal obligations.

· Providing local services without communicating with our servers.

Here are more details on how we use your information (which may include personal information):

· Setting up your NextVPU Account. Personal information collected when creating a NextVPU Account on our web sites or through our mobile devices is used for creating the personal NextVPU Account and profile page for the user.

· Processing your purchase orders. Information relating to e-commerce orders may be used for processing the purchase order and related after-sales services, including customer support and re-delivery. In addition, the order number is used to cross check the order with the delivery partner as well as the actual delivery of the parcel. The receipt details, including name, address, phone number and postal code are for delivery purposes. The email address is used to send parcel tracking information to the user. The list of purchased item(s) is used for printing the invoice and allowing users to see what is in the parcel.

· Allowing you to participate in NEXTVPU Forum. Personal information in relation to the NEXTVPU Forum or other NextVPU Internet platforms may be used for profile page display, interaction with other users, participating in the forum.

· Providing NextVPU Cloud and other NEXTVPU services. Information (device or SIM card-related information including IMEI number, IMSI number, phone number, device ID, device operating system, MAC Address, device type, system and performance information and location information including mobile country code, mobile network code, location area code and cell identity) is collected for activating related services.

· Providing other NextVPU services. Other information collected for each of the NextVPU services may be used for performing the functions of that service, and to facilitate the provision of that service for the benefit of the user, e.g. downloading, updating, registering, performing or optimizing activities related to NEXTVPU services.

· Improving user experience. Some opt-in features, such as the User Experience Program, allow NextVPU to analyze data about how users use the mobile phone and NEXTVPU services, so as to improve the user experience, such as sending crash reports.

· Collecting user feedback. The feedback you choose to provide is valuable in helping NextVPU make improvements to our services. In order to follow up on the feedback you have chosen to provide, NextVPU may correspond with you using the personal information that you have provided and keep records.

· Sending notices. From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies.

· Conducting promotional activities. If you enter into a sweepstake, contest, or similar promotion, e.g. via NextVPU Community or other NextVPU’s social media platforms, we may use the personal information you provide to administer those programs.

· Conducting analysis of your device to provide better user experience. NextVPU may conduct the hardware or software analysis, so as to further improve the performance of your device.

Direct marketing

· We may use your name, phone number, and email address, NextVPU Account ID and IMEI number to provide marketing materials to you relating to goods and services of NextVPU companies and our business partners which offer network, mobile applications and cloud products and services. To provide better user experience, we may recommend above-mentioned products, services and activities based on information about your purchase history, website browsing history, birthday, age, gender, and location. We will only so use your personal data after we obtain your prior explicit consent and involve a clear affirmative action or indication of no objection in accordance with local data protection laws, which may require separate explicit consent. You have the right to opt out of our proposed use of your personal data for direct marketing. If you no longer wish to receive certain types of email communications you may opt-out by following the unsubscribe link located at the bottom of each communication. We will not transfer your personal data to our business partners for use by our business partners in direct marketing.

Cookies and other technologies

· What information is collected and how we can use them: Technologies such as cookies, tags, and scripts are used by NextVPU and our Third Party Service Providers. 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.

· 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.

· Advertising: We partner with our Third Party Service Providers to either display advertising on our website or to manage our advertising on other sites. Our Third Party Service Provider may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. We will obtain your prior explicit consent and involve a clear affirmative action before providing this advertising service to you.

· Mobile Analytics: Within some of our mobile applications we use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where crashes occur within the application. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.

 

With whom we share your information

We do not sell any personal information to third parties.

We may disclose your personal information on occasion to third parties (as described below) in order to provide the products or services that you have requested.

Disclosure may be made to Third Party Service Providers and affiliated companies listed in this section below. In each case described in this section, you can be assured that NextVPU will only share your personal information in accordance with your consent. Your consent to NextVPU will engage sub-processors for the processing of your personal information. You should know that when NextVPU shares your personal information with a Third Party Service Provider under any circumstance described in this section, NextVPU will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. NextVPU will contractually ensure compliance by any Third Party Service Providers with the privacy standards that apply to them in your home jurisdiction.

Sharing with our group and third party service providers

From time to time, in order to conduct business operations smoothly in providing you with the full capabilities of our products and services, we may disclose your personal information from time to time to other NextVPU affiliated companies (in communications, social media, technology or cloud businesses), or our third party service providers which are our mailing houses, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and marketing service providers, agents acting on behalf of NextVPU, [related corporations, and/or other third parties] (together “Third Party Service Providers”). Such Third Party Service Providers would be processing your personal information on NextVPU’s behalf or for one or more of the purposes listed above.

Sharing with others

NextVPU may disclose your personal information without further consent when required under applicable law.

Information not requiring consent

· We may share anonymized information and statistics in aggregate form with third parties for business purposes, for example with advertisers on our website, we may share them trends about the general use of our services, such as the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.

· For the avoidance of doubt, NextVPU may collect, use or disclose your personal information without your consent if it is and only to the extent it is allowed explicitly under local data protection laws.

Security safeguards

NextVPU’s security measures

We are committed to ensuring that your personal information is secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect on your mobile device and on NextVPU websites. We will use all reasonable efforts to safeguard your personal information.

For example, when you access your NextVPU Account, you can choose to use our two-step verification process for better security. When you send or receive data from your NextVPU device to our servers, we make sure they are encrypted using Secure Sockets Layer (“SSL”) and other algorithms.

All your personal information is stored on secure servers that are protected in controlled facilities. We classify your data based on importance and sensitivity, and ensure that your personal information has the highest security level. We make sure that our employees and Third Party Service Providers who access the information to help provide you with our products and services are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. We have special access controls for cloud based data storage as well. All in all, we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.

We will take all practicable 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 which is transferred from you or to you via the Internet.

We will take upon the personal data breach, notifying the breach to relevant supervisory authority or under some circumstances, notifying the personal data breach to the data subjects by complying with applicable laws, including your local data protection legislation.

What you can do

· You can play your part in safeguarding your personal information by not disclosing your login password or account information to anybody unless such person is duly authorized by you. Whenever you log in as a NextVPU Account user on NextVPU websites, particularly on somebody else's computer or on public Internet terminals, you should always log out at the end of your session.

· NextVPU cannot be held responsible for lapses in security caused by third party accesses to your personal information as a result of your failure to keep your personal information private. Notwithstanding the foregoing, you must notify us immediately if there is any unauthorized use of your account by any other Internet user or any other breach of security.

· Your assistance will help us protect the privacy of your personal information.

Retention policy

Personal information will be held for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal information, or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information. If further processing is for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to the applicable laws, the data can be further retained by NextVPU even if the further processing is incompatible with original purposes.

Accessing other features on your device

Our applications may need access to certain features on your device such as enabling emails to contacts, SMS storage and Wi-Fi network status, as well as other features. This information is used to allow the applications to run on your device and allow you to interact with the applications. At any time you may revoke your permissions by turning these off at the device level or contacting us at dpo@nextvpu.com.

You have control over your personal information

Controlling settings

NextVPU recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways NextVPU makes available for you to choose to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings:

· Toggle on/off for the User Experience Program and Location Access functions;

· Log in and out of the NextVPU Account;

· Toggle on/off for the NextVPU Cloud sync functions; and

· Delete any information stored on App through remving App;

· Toggle on/off for other services and functionalities which deal with sensitive or personal information.

You may obtain more details in relation to your device’s security status in the NEXTVPU Security Center as well.

If you have previously agreed to us using your personal information for the abovementioned purposes, you may change your mind at any time by writing or emailing us at dpo@nextvpu.com.

Access, update, correct, erase or restrict processing your personal information

· You have the right to request access to and/or correction of any other personal information that we hold about you. When you update your personal information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your personal information, we shall proceed to respond to your request within any timeframe set out under your applicable data protection 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 of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.

· If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the email address below. Email:  dpo@nextvpu.com.

· For details relating to the personal information in your NextVPU Account, you may also access and change them by logging into your account on your device.

· If you are Europe Union user under General Data Protection Regulation (GDPR), you have the right to obtain from us the erasure of your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.

· If you are Europe Union user under GDPR, 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.

· If you are Europe Union user under GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

· If you are Europe Union user under GDPR, you have the right to receive your personal information in a structured, commonly used format and transmit the information to another data controller.

Withdrawal of consent

· You may withdraw your consent for the collection, use and/or disclosure of your personal information in our possession or control by submitting a request. This may be done by accessing your NextVPU Account management center at App. 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.

· Please recognize that your withdrawal of consent could result in certain legal consequences. Depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that you will not be able to enjoy NextVPU’s products and services.

Transfer of personal information outside of your jurisdiction

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies (which are in the communications, social media, technology and cloud businesses) or Third Party Service Providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You will have the right to be informed of the appropriate safeguards taken by NextVPU for this transfer of your personal information.

NextVPU is a China-headquartered company operating globally. As such, complying with applicable laws, we may transfer your personal data to any subsidiary of the NextVPU group worldwide when processing that information for the purposes described in this Privacy Policy. We may also transfer your personal data to our third party service providers, who may be located in a country or area outside the area of the European Economic Area (EEA).

Whenever NextVPU shares personal data originating in the EEA with a third party which may or may not be a NextVPU entity outside the EEA, we will do so on the basis of EU standard contractual clauses or any other safeguards provided for in the GDPR.

NextVPU may use overseas facilities operated and controlled by NextVPU to process or back up your personal information. Currently, NextVPU has data centers in Beijing, United States, Germany, Russia and Singapore. These overseas jurisdictions may or may not have in place data protection laws which are substantially similar to that in your home jurisdiction. You have understood that the risks under applicable data protection laws are different and we may transfer to and store your personal information at our overseas facilities. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy.

Miscellaneous

Minors

· We consider it the responsibility of parents to monitor their children’s use of our products and services. Nevertheless, it is our policy not to require personal information from minors or offer to send any promotional materials to persons in that category.

· NextVPU does not seek or intend to seek to receive any personal information from minors. Should a parent or guardian have reasons to believe that a minor has provided NextVPU with personal information without their prior consent, please contact us to ensure that the personal information is removed and the minor unsubscribes from any of the applicable NextVPU services.

Order of precedence

If you have agreed to our applicable User Agreements, in the event of inconsistency between such User Agreements and this Privacy Policy, such User Agreements shall prevail.

Updates to the privacy policy

We keep our Privacy Policy under regular review and may update this privacy policy to reflect changes to our information practices. If we make material changes to our Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) or post the changes on the NextVPU websites or through our mobile devices, so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of products and services on the websites, mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal information from you or when we wish to use or disclose your personal information for new purposes.

Do I have to agree to any third party terms and conditions?

Our Privacy Policy does not apply to products and services offered by a third party. NextVPU products and services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to 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.

Social media (features) and widgets

Our websites include social media features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our websites. Your interactions with these Features are governed by the privacy policy of the company providing it.

About our systematic approach to manage your personal information

If you are Europe Union user under GDPR, NextVPU will provide systematic approach to manage personal data deeply engages our people, management processes and information systems by applying a risk management methodology. According to the GDPR, for instance, (1) NextVPU set up a Data Protection Officer (DPO) in charge the data protection, and the contact of DPO is dpo@nextvpu.com; (2) procedure like data protection impact assessment (DPIA).

Contact us

If you have any comments or questions about this Privacy Policy or any questions relating to NextVPU’s collection, use or disclosure of your personal information, please contact our Data Protection Officer at the address below referencing “Privacy Policy”:

NextVPU (Shanghai) Co.,Ltd.
218,Building 5,No, 3000 Longdong Road, Pudong New District, Shanghai
Singapore 201210
Thank you for taking the time to understand our Privacy Policy!

 

address:218, Building 5, 3000 Longdong Road, Pudong New District, Shanghai, China +86 21 5077 3678