Privacy Policy

Latest update time: 10/23/2020

Global Tone Communication Technology Co., Ltd., having its registered office at Room 1601, 16F, No. 20 Shijingshan Road, Shijingshan District, Beijing, (hereinafter referred to as “GTCOM” or “We”), attaches great importance to the protection of users' personal information and privacy.

During your use of GTCOM’s products or services (hereinafter referred to as “GTCOM products”), we may collect and use your personal information, so we have formulated a privacy policy that covers how to collect, store, use, share and protect users' personal information. With this Privacy Policy, we will explain to you the purpose, method and scope of our collection and use of your personal information, your rights to your personal information, and the measures we take to protect the security of your information.

This Privacy Policy applies to the related services of cnkeywords.net (hereinafter collectively referred to as the "CNKEYWORDS"). Unless otherwise specified in this Privacy Policy, this Privacy Policy does not apply to the products and/or services provided to you independently by third parties that are accessed through our products and/or services, such as those products or websites that are shown to you in search results, or other websites that are linked to by our products and/or services. Please note: When you use third-party products and/or services, if you provide your personal information to that third party, your information shall be applied to the privacy policy of the third party or similar policies; we are not liable to any improper use or disclosure of information provided by you by the third party. 。

Please read through this Privacy Policy and use the CNKEYWORDS after your fully understanding and recognition of the policy. The bold part of the policy shall be read carefully. If you/your guardian disagrees with any content of this Privacy Policy, you should stop using it immediately.

This Privacy Policy will help you understand the following content:

I.How Do We Collect Your Personal Information

II.How Do We Use Cookies and Similar Technologies

III.How Do We Use Your Personal Information

IV.How Do We Retain Your Personal Information

V.How Do We Disclose Your Personal Information

VI.How Do We Protect Your Personal Information

VII.Your Rights to Your Personal Information

VIII.How Do We Deal with the Personal Information of Minors

IX.Third-Party Service Providers and Their Services

X.How Is Your Personal Information Transferred Globally

XI.How Is This Privacy Policy Updated

I. How Do We Collect Your Personal Information

The personal information under this Privacy Policy refers to all kinds of information recorded electronically or otherwise that can identify the personal identity of natural persons alone or in combination with other information. Personal sensitive information refers to personal information that may endanger personal and property safety, and easily result in damages to personal reputation and physical and mental health or discriminatory treatment if it is disclosed, illegally provided, or abused.

Our purpose of collecting personal information is to improve the operational efficiently and provide you with the best experience. We collect personal information through the following channels: (a) the information you provide to us; and (b) the information collected during your use of products or services.

The information we collect depends on the GTCOM products you actually use, the environment in which you interact with us, the choices you make, including your privacy settings, and the products and functions you use. Our products and functions include core business functions and value-added business functions. You are not required to provide us with personal information when we collect information. However, for core business functions, if you choose not to provide it, we may not be able to provide you with relevant products or services, or respond to or solve the problems you encounter. For non-core business functions, you may choose whether to agree to our collection of information. If you refuse to agree, it may lead to the failure of relevant business functions, but it will not affect your use of our core business functions.

Please understand that the functions and services we provide to you are constantly updated and developed. If a function or service is not included in the following description and your information is collected, we will further explain to you the content, scope and purpose of information collection through page prompts, interactive processes, site notices, separate agreements and other means for your consent.

1. The information you provided to us

1.1 To create and maintain your service account

When using the CNKEYWORDS, you may choose to register as a user of the CNKEYWORDS. You should register a service account for the CNKEYWORDS for specific functions such as giving likes, collecting entries, and applying for creation of entries. In order to create your service account, you should provide us with your email addressand set your account password. The above information is necessary for us to create a service account for you. If you refuse to provide the above information, we will not be able to register an account for you and you will not be able to use certain functions, but this will not affect your use of the basic functions of the CNKEYWORDS (such as the retrieval, reading, translation and sharing of all information on the website).

1.2 To provide you with feedback function

The CNKEYWORDS provides feedback functions. If you are required to provide us with feedback, we will require you to provide and collect your personal information, including your email address and your comments, so that we can contact you in time and give you feedback on the processing results. You may choose to submit feedback to us, which will not affect your using of the basic functions of the CNKEYWORDS.

1.3 To provide you with promotional or marketing activities

We may invite you to participate in promotional or marketing activities such as sweepstakes, contests and questionnaires, held by us during your use of the CNKEYWORDS. If you agree to participate in our promotional or marketing activities, you will be required to provide us with your name, mobile phone number and email address so that we can contact you and present you with gifts. If you refuse to provide the above information, you may not be able to participate in our promotional or marketing activities, but it will not affect your using of the basic functions of the CNKEYWORDS.

1.4 To facilitate your application for entry creation

You may apply to create entries on the CNKEYWORDS. If you choose to use this function, we will collect and review the entries you submit. Please note that: Please be cautious that the content and information you voluntarily provide, upload or publish when using our products and/or services (such as the information you submit when applying for entry creation) may reveal your sensitive personal information. If you disclose your personal information in the information uploaded or posted in a public area visible to other users, or in your response to the information uploaded or posted by other people, such personal information may be collected and used by others. If you find that others have improperly collected or used your personal information, you may contact us through the contact information disclosed in this Privacy Policy.

2.Information collected during your use of products or services

In order to ensure the security of the CNKEYWORDS and user accounts, provide better products and/or services and improve the user experience, we will collect the information on how you and your device interact with GTCOM products or services during your use of the CNKEYWORDS, including:

(1) Logs and operation history: For example, your use of our products or services, the operation after your account is logged in to (including password modification, and modification of the bound mobile phone number, email address, and complaint record), search query words entered through the services, software event information (such as restart, upgrade, error and crash), IP address, URL of the service accessed, browser type and language used, downloading, installation or use of mobile applications and software, and the information communicated with the communication software and the date, time, duration and browsing information of accessing the services.

(2) Location information: We may obtain your location information from third parties so that we can understand the language type used by you and your browser. You may turn off the positioning function to stop collection of your geographic location information, but then you may not be able to get relevant services or functions, or you may not achieve the desired effects of relevant services.

Please understand that the functions and services we provide to you are constantly updated and developed. If a function or service is not included in the above statement and your information is collected, we will further explain to you the content, scope and purpose of information collection through page prompts, interactive processes, site notices, separate agreements and other means for your consent.

3.Information obtained from third parties

Where permitted by law and authorized by you, in order to provide you with better services and meet your individual needs, we may receive your personal information or other information from our affiliates or partners (for example, we may obtain your geographic location information from search engine service providers so that we can understand the language type used by you and your browser). In addition, we will also collect shared personal information about you provided by other parties when using our products or services.

4.Where permitted by law and authorized by you, in order to provide you with better services and meet your individual needs, we may receive your personal information or other information from our affiliates or partners (for example, we may obtain your geographic location information from search engine service providers so that we can understand the language type used by you and your browser). In addition, we will also collect shared personal information about you provided by other parties when using our products or services.

In accordance with relevant laws, regulations and national standards, we may legally collect and use your personal information without your consent in case the information is:

(1) related to GTCOM’s fulfillment of the obligations stipulated by laws and regulations;
(2) directly related to national security and national defense security;
(3) directly related to public safety, public health, and major public interests;
(4) directly related to criminal investigation, prosecution, trial and execution of judgments;
(5) for safeguarding your or other individuals’ major legal rights, such as life or property, but it is difficult to obtain the authorization or consent of the information subjects;
(6) disclosed to the public by yourself;
(7) required to sign and fulfill the contract according to your requirements;
(8) collected from legally disclosed information, such as news coverage and government information disclosure;
(9) required to maintain the safe and stable operation of products or services provided, such as the finding or disposal of products or services failure;
(10) required for legal news coverage;
(11) required for academic research institutions to conduct statistical or academic research based on the public interest, and the personal information contained in the results are de-identified when the results of academic research or description are provided externally;
(12) Other circumstances stipulated by laws and regulations.

II. How Do We Use Cookies and Similar Technologies

Cookie Cookies are a type of neutral technology that allows website servers to store data on the client or read data from the client. We use cookies to allow you to use our website products and/or services quickly and efficiently, and to help us count the number of unique visitors. Through use of cookies, we can provide you with more thoughtful personalized services and allow you to set your specific service options.
One of the main purposes of cookies is to provide a practical function that saves time. When you use the CNKEYWORDS, cookies will help us understand your regional location and the language type information used by the browser, which can simplify the process of choosing the default language on the CNKEYWORDS. In addition, we will not use cookies for any other purposes.
You may choose to refuse cookies by modifying your browser settings. Some functions of our products and/or services rely on cookies. If you refuse or delete cookies, you may not be able to log in or use some of our services or functions that rely on cookies.

III. How Do We Use Your Personal Information

1.Your personal information will be used in the application scenarios specified under "How Do We Collect Your Personal Information”.
Your personal information may be used in the following scenarios that are directly or reasonably related to the purpose stated under "How Do We Collect Your Personal Information”:

（1）Providing and improving the products and services: We will use the collected information to provide and improve our products and services, and make necessary business operations, such as operating products or providing services, evaluating, maintaining and improving the performance of the products or services, participating in the market surveys concerning our products and services, developing new products or services, and providing customer support.

（2）Statistical analysis on the use of products:In order to improve our products and services, we may also conduct statistics and analysis on the use of products. At the same time, we may share this statistics with the public to display the overall use trend of our services, but this statistics will not include any information that can identify you.

（3） Information and notification services: We will send you information and notifications, including but not limited to the verification code required to ensure the completion of the services, the push notification required to use the products or services, news coverage about GTCOM and its products or services, and marketing activities and special promotions or other content that may be of interest to you. If you do not want to receive the above information any longer, you may unsubscribe according to the method provided in the information.

3.We may combine the information collected when you use different GTCOM products to conduct comprehensive statistics and analysis to better meet your individual needs (for example, to enable you to obtain more personalized recommendations). You agree to authorize us and our affiliates, or other partners to share necessary information so that we can provide you with better personalized products or services in general.

4. We may also synthetically analyze the collected information, comprehensively judge your account security and transaction risks based on your transaction habits and commonly used software information, conduct identity verification, detect and prevent security incidents, keep necessary records, perform audits and analysis, take treatment measures to better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks and network intrusions, and more accurately identify violations of laws, regulations or agreements related to products and services, so as to protect the legitimate rights and interests of you, other users, us or affiliates.

5.We will notify you again and obtain your express consent for any use of your personal information that is not directly or reasonably related to the purpose stated under "How Do We Collect Your Personal Information”.

IV. How Do We Retain Your Personal Information

The retention period of personal information we collect is the minimum time required to achieve the collection purposes set forth in this Privacy Policy, unless a longer retention period is required by laws and regulations. If the above retention period expires, we will delete or anonymize your personal information. In the case that we stop operating some or all of our products or services due to special reasons, we will timely notify you and stop the collection and processing of personal information related to products or services, and delete or anonymize the personal information in our possession in connection with such products or services, unless otherwise stipulated by laws and regulations.

V. Sharing, Transfer and Public Disclosure of Personal Information

1. Currently, we will not actively share or transfer your personal information to any third party other than GTCOM. In the event that it is required to share or transfer your personal information or you require us to share or transfer your personal information to a third party other than GTCOM, we will obtain or confirm that the third party has obtained your authorization and consent to the above actions.

2. In the event of a merger, acquisition or bankruptcy involving a transfer of personal information, we will require the company or organization newly holding your personal information to continue to be bound by the Privacy Policy; otherwise we will require the company or organization to re-request you for authorization and consent. If the transfer of personal information is not involved, we will fully inform you and delete or anonymize all personal information in our possession. Internally, in the previous acquisition and merger activities, the data (including user data) managed by the acquired and merged company or organization will be processed and protected by the same standards and requirements as the data owned by GTCOM.

3.We will abide by relevant laws and regulations and keep your personal information confidential. We will not publicly disclose your personal information except with your express consent or authorization in advance, or as required by law.

4.In addition, in accordance with relevant laws, regulations and national standards, we may share, transfer or publicly disclose personal information without prior authorization and consent of the subject of personal information in case the information is:

VI. How Do We Protect Your Personal Information

1.In order to ensure the security of your information, we will take reasonable and necessary measures to protect your information under the current technical level, and adopt physical, technical and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure and modification, including but not limited to transmission layer data encryption, firewall and encrypted storage, physical access control, and information access authorization control. To this end, we have security programs in place to protect your information from unauthorized access. All personal information is encrypted and stored inside professional firewalls.

2.We have established relevant systems, procedures and organizations to ensure the security of your information. For example, we strictly limit the scope of people who can access information and require them to comply with confidentiality obligations.

3、When you use our services, please take good care of your account number and password, as we will identify you by your account number and password. Once your account number and password are known by others, you may lose your information and may have adverse legal consequences against you. If you find that your account and password have been or will be known by others for any reason, you should contact us immediately so that we can take appropriate measures to prevent or reduce the relevant losses.

4、In the event of a security incident such as personal information leakage, we will initiate an emergency plan to prevent the expansion of the security incident, and notify you in the form of push notifications, announcements, etc.

5. The Internet environment is not completely secure, and we will do our best to ensure or guarantee the security of any information you send to us. In the event that our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, thereby causing damage to your legitimate rights and interests, we will bear the corresponding legal liability.

VII. Your Rights to Your Personal Information

We respect your right to your personal information. The following lists your legal rights and explains how we will protect them.

1.Right to be informed:We inform you of how we deal with your personal information by publishing this Privacy Policy. We are committed to ensuring transparency in the use of your information.

2.Access right: You can directly query or access your personal information in our product or service interface, for example, you can log in to your account at any time through the product page to access personal information related to your account, including basic information, operation history, storage and downloads history; you can also browse information about your use of products or services at any time, for example, you can access your browsing history in a browser.
You can query and access your personal information through: [Logging into CNKEYWORDS - Personal Center]

3.Right of correction: You have the right to ask us to correct or supplement the personal information we deal with about you if you find that it is incorrect or incomplete. For some of your personal information, you can directly correct or modify it on the relevant function page of the product or service. For personal information that has not yet been provided to you with a channel for self-modification, you can also contact us through the contact information disclosed in this Privacy Policy to request us to correct or supplement your personal information. We will deal with and send feedback on it in a timely manner in accordance with laws and regulations.
You can correct your personal information by: [Logging into CNKEYWORDS -- Personal Center -- Personal Profile/Security Settings].

4.Right to delete: You can delete specific information submitted by you directly from the product interface through your account, such as your profile photo and user name. If we collect and use your personal information in violation of our agreement with you, you can also contact us through the contact information disclosed in this Privacy Policy to request us to delete your personal information. We will deal with and send feedback on it in a timely manner in accordance with laws and regulations.
You can delete your personal information by: [Logging into CNKEYWORDS -- Personal Center -- Personal Profile/Security Settings].

5.Right of logout: We provide account logout service for you. You may choose to log out your account in the product interface. After you choose to log out your account, we will delete or anonymize all your personal information in a timely manner in accordance with laws and regulations, unless otherwise provided by laws and regulations. After you log out, we will no longer be able to provide you with account registration services and products or services that require account login.
You can request for logging out your account by: [Clicking "Contact Us" at the bottom of any page of the CNKEYWORDS to submit your logout request.]

6.Right to revoke consent: Each business function needs some basic personal information to work properly (see the section "How Do We Collect and Use Your Personal Information" of this Privacy Policy). You may change the scope of your authorization to continue to collect personal information or revoke your authorization by deleting information, logging out your account, etc.
Besides, you can change your consent or authorization by [Logging into the CNKEYWORDS -- Personal Center -- Personal Profile/Security Settings to change your consent or authorization by deleting information, or by clicking "Contact us" at the bottom of any page on the CNKEYWORDS to submit your request to revoke consent.]
If you do not want to receive the commercial ads we send you, you can cancel it at any time by: [Clicking "Contact us" at the bottom of any page on the CNKEYWORDS to submit your request.]
If you revoke your consent, we will no longer be able to provide you with the services corresponding to the revoking of consent or authorization. After you revoke your consent, we will no longer process the corresponding personal information, but your decision to revoke your consent will not affect the personal information processing activities previously carried out based on your authorization.

7.Right to complain: You have the right to contact us for complaints through the contact information disclosed in this Privacy Policy. We will reply you within 15 working days from the date of receipt of your complaint. If you are not satisfied with our reply, especially our personal information processing behavior has harmed your legitimate rights and interests, you can also file a complaint or report to regulatory authorities such as Internet information authorities, public security authorities, and industrial and commercial administrations, or file a lawsuit in a competent court.

Please note that for security reasons, we may verify your identity before processing your request. We do not charge for reasonable requests in principle. But for repeated requests that exceed reasonable limits, we will charge a certain cost as appropriate. We may reject requests that are gratuitously repeated, require excessive technical means (for example, the need to develop new systems or fundamentally change existing practices), pose a risk to the legitimate interests of others, or are highly impractical. In addition, if your request directly involves any matters directly related to the public interest, such as national security, national defense security, public health, and criminal investigation, or may cause serious damage to the legitimate rights and interests of you or other individuals or organizations, we may not be able to respond to your request in the circumstances related to GTCOM’s performance of its obligations under laws and regulations.

VIII. How Do We Deal with the Personal Information of Minors

1. Our products, websites and services are mainly for adults. If you are a minor under the age of 18, you should obtain the consent of your guardian before using our products and/or services. We will only use or disclose children’s personal information collected with parents’ consent to the public according to laws after getting the guardians’ explicit consent or when it is necessary for protection of children. With regard to the personal information of children under the age of 14 that may be involved, in addition to complying with the provisions of this Privacy Policy on the personal information of users, we will also uphold the principles of legitimacy, necessity, informed consent, clear purpose, security and legal use, and strictly follow the requirements of laws and regulations such as the Provisions on the Cyber Protection of Children's Personal Information to store, use, and disclose children's personal information, and protect the legal rights of children and their guardians with regard to the relevant children’s personal information.

2. If we find ourselves collecting personal information about a minor without the prior consent of a certified guardian, we will try to delete the data as soon as possible.

3. If you are the guardian of a minor, if you have questions about the handling of the information of a minor under your guardianship, or if you have evidence that a minor has registered to use our products and/or services without the consent of the guardian, please contact us through the contact details below.

IX. Third-Party Service Providers and Their Services

Our websites, products, applications and services may contain links to third-party websites, products and services. You may choose whether to visit or accept the websites, products and services provided by third parties. The "Follow Us" function on the official website will guide you to visit our official account on the social network platform, where you can learn about the marketing or promotional information posted by us.

We have no control over the privacy and data protection policies of third parties who are not bound by this Privacy Policy. Please check and understand the privacy policies of these third parties before submitting personal information to third parties.

X. How Is Your Personal Information Transferred Globally

In general, the personal information we collected and generated within the People's Republic of China will be stored in the territory of the People's Republic of China. If some products or services are cross-border related and we need to transfer your personal information overseas, we will strictly comply with applicable laws and regulations and ensure the security of your personal information.

XI. How Is This Privacy Policy Updated

In the event of a major change, our privacy policy may be amended. Without your explicit consent, we will not limit the rights you shall enjoy under the Privacy Policy. We will post any amendment to the Privacy Policy on particular pages. If you continue to choose to use our products or services, it means that you agree to be bound by the updated Privacy Policy and its relevant policies.

In addition, we will provide a more conspicuous notification for major amendments (including, we will give a notice by way of website announcement for some certain services, specifying specific amendments to the Privacy Policy).

Major amendments referred in the Privacy Policy include, but are not limited to:

(1) Major changes in our service model. For example, the purpose for processing user information, the type of user information handled, and the use of user information;

(2) Major changes in our control rights, equity structure and organizational structure. For example, change of owners caused by business adjustment, bankruptcy and merger;

(3) Changes in the main objects of user information sharing, transfer or public disclosure;

(4) Major changes in your rights to participate in the processing of user information and the way of exercising such rights;

(5) Changes in the department in charge of user information security, contact information, and complaint channels.

This Privacy Policy is effective as of the date of update.

If you have complaints and reports about network information security, or if you have any questions, comments or suggestions about this Privacy Policy, your information-related matters, and questions about this statement or GTCOM's privacy measures, please contact us through the following contact information. We will deal with and send feedback on it in a timely manner in accordance with laws and regulations:

E-mail: cnky@gtcom.com.cn