If you do not agree with these changes and no longer wish to use our services, you may cancel your account by emailing us at email@example.com.
Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.
Our commitment to you
Group (“Towinner”, “we”, “our” or “us”) collect, use, disclose, process and protect any
information that you give us when you use our products and services located at To winner app or
website that we offer in our applications.
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.
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 (e. g. automated individual decision-making) 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.
We will be happy to address them directly.
What information is collected and how can we use it?
Types of information collectedIn 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, mobile phone number, email address, delivery address, ID card, driver license, passport details. To winner Account details (e.g. your security related information, name, birthday, gender), order, invoicing details, materials or data you may sync through Towinner or other apps (e.g. photos, contact lists).
• Information specific to you that may be assigned by us: we may collect and use information such as your Towinner Account.
• 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, current employer, current job title, education background, professional training background etc.
• Application information: information related to your software usage. For example, application list, application status record (e.g. downloading, installing, updating, deleting), application ID information, SDK version, system update settings 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 Towinner 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.
How the personal information can be usedPersonal information is collected for providing services and / or products to you, and legal compliance on our part under applicable laws.
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 comments in public forums.
• Conducting promotional activities, such as sweepstakes and Facebook events.
• 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):
• 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.
• Recording location information in photos. You have the ability to record your location information while taking a photo. This information will be visible within your photos folder and the location will be put into the header of your photos. If you do not wish to have your location recording while taking a photo, you may turn this off at any time within the camera settings of the device.
• Providing location based services. In the course of using MIUI services, location information may also be used by us or Third Party Service Providers to serve you the correct version of the service and provide accurate details about that location for the best possible user experience, e.g. weather details, location access (as part of the Android platform). You may turn this off at any time by going into the device settings or discontinue use of that application.
• Improving user experience. Some opt-in features, such as the User Experience Program, allow Towinner to analyze data about how users use the mobile phone and MIUI services, so as to improve the user experience, such as sending crash reports.
• Allowing you to use Security Center. Information collected may be used for security and system up-keeping functionalities in the Security Center, such as advertising blocker, virus scan, power saver, blocklist, cleaner, etc. Some of these functionalities are operated by Third Party Service Providers. Information (which is not personal information like virus definition lists) is used for virus scan functions.
• Providing Push Service. Towinner Account ID and IMEI numbers will also be used to provide the Towinner push service to evaluate advertising performance and send notifications from Towinner about software updates or new product announcements, including information about sales and promotion. Furthermore, under entrust of selected third party (the data controller of your personal information), the Towinner push service may also evaluate advertising performance or send notifications by using your Towinner Account ID and IMEI numbers. You consent to our use of your personal information for the purpose of sending you pushing services (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties. You may opt out of this at any time through changing your preferences under “Settings”, or through the selected third party you consent.
• Verifying user identity. Towinner uses the ECV value to verify the user identity and ensure there is no log-in by hackers or unauthorized persons.
• Collecting user feedback. The feedback you choose to provide is valuable in helping Towinner make improvements to our services. In order to follow up on the feedback you have chosen to provide, Towinner 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 Towinner’s Facebook page or other social media platforms, we may use the personal information you provide to administer those programs.
Direct marketing • We may use your name, phone number, and email address, Towinner Account ID and IMEI number to provide marketing materials to you relating to goods and services of Towinner 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 Towinner 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. If you wish to not have this information used for the purpose of serving you interest-based ads.
• 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.
• Local Storage – HTML5/Flash: We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content and preferences. Third parties with whom we partner to provide certain features on our Sites or to display advertising based upon your web browsing activity also use HTML5 or Flash cookies to collect and store information. Various browsers may offer their own management tool for removing HTML5 LSOs.
With whom we share your informationWe 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 Towinner will only share your personal information in accordance with your consent. Your consent to Towinner will engage sub-processors for the processing of your personal information. You should know that when Towinner shares your personal information with a Third Party Service Provider under any circumstance described in this section, Towinner will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. Towinner 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 providersFrom 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 Towinner 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 Towinner, [related corporations, and/or other third parties] (together “Third Party Service Providers”).
Such Third Party Service Providers would be processing your personal information on Towinner’s behalf or for one or more of the purposes listed above.
We may share your IP address with third parties when using certain mobile applications on our device in order to provide you with some of the services you requested.
If you no longer wish to allow us to share this information, please contact us at firstname.lastname@example.org.
Sharing with othersTowinner 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, Towinner 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.
Towinner´s security measuresWe 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 Towinner app and websites. We will use all reasonable efforts to safeguard your personal information.
For example, when you access your Towinner Account, you can choose to use our two-step verification process for better security. When you send or receive data from your our app 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 Towinner Account user on app or websites, particularly on somebody else's computer or on public Internet terminals, you should always log out at the end of your session.
• Towinner 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 policyPersonal 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 Towinner even if the further processing is incompatible with original purposes.
Accessing other features on your deviceOur 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 email@example.com.
Accessing other features on your deviceControlling settings
Towinner recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways Towinner 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 Towinner Account;
• Delete any information stored on Towinner data base
• Toggle on/off for other services and functionalities which deal with sensitive or personal information.
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 firstname.lastname@example.org.
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: email@example.com
• For details relating to the personal information in your Towinneri Account, you may also access and change them at Towinner app or 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 Account management at Towinner. 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 Towinner’s products and services.
Transfer of personal information outside of your jurisdictionTo 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 Towinner for this transfer of your personal information.
Whenever Towinner shares personal data originating in the EEA with a third party which may or may not be a Towinner 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.
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.
• Towinner 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 Towinner with personal information without their prior consent, please contact us to ensure that the personal information is removed and the minor unsubscribes.
Here are third party terms and privacy policies that apply when you use these specific products:
• By using the Google Input Method, you are agreeing to Google’s terms: http://www.google.com/policies/privacy
Single sign-onDepending on your jurisdiction, you may be able to log in to our website using sign-on services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal information (such as your name and email address) with us, and to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this website to your profile page to share with others within your network.
About our systematic approach to manage your personal information
If you are Europe Union user under GDPR, Towinner 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)Towinner set up a Data Protection Officer (DPO) in charge the data protection, and the contact of DPO is firstname.lastname@example.org; (2) procedure like data protection impact assessment (DPIA).
Towinner . Ltd.
• We updated the types of personal information that we collected and the purposes of collecting such information. For example, we collected hardware usage information to conduct statistical analysis and optimize the performance of your devices.
• By complying with GDPR and providing better data privacy protection, we updated the relevant content about users’ rights under GDPR, and how we process the personal information for our Europe Union users. We also described our data privacy management method additionally.
• We updated the relevant content of third parties’ products and services which may be involved during the use of our products and services.