Updated: September 13, 2024
Published date: September 13, 2024
Effective Date: September 13, 2024
The VTransPen Privacy Policy (hereinafter referred to as the "Policy") only applies to the VTransPen products and/or services provided to you by Shenzhen Beibo Intelligent Technology Co., Ltd. (hereinafter referred to as "we", "us" or "our"). Please read this Policy carefully before using the Software to understand the details of our processing of your personal information. We have reminded you of the important content related to sensitive personal information and your personal information rights and interests in bold form, so please pay special attention to it. If you are a minor under the age of 14, please read and fully understand this Policy carefully accompanied by your parents or other guardians, and obtain the consent of your parents or other guardians before using VTransPen products and/or services.
Special Notes:
1. You agree that this policy only means that you have understood the functions provided by VTransPen and the necessary personal information required for the operation of the functions.
2. For sensitive personal information, we will obtain your consent through a pop-up window before collection.
3. The corresponding device permissions will not be enabled by default, and when important or sensitive device permissions are involved, we will enable them after obtaining your consent through a pop-up window when you use the corresponding business functions. After the permission is enabled, you can disable the permission at any time on the "My - General Settings" page or on the device system permission settings page. If you do not agree to enable the permissions corresponding to a business function, the normal use of other non-related business functions will not be affected.
This policy will help you understand the following:
1. Definitions and Interpretation
2. How We Collect and Use Your Personal Information
3. How We Share, Transfer, and Publicly Disclose Your Personal Information
4. How We Protect Your Personal Information
5. How We Protect the Personal Information of Minors
6. How Your Personal Information Is Transferred Globally
7. How We Update this Policy
8. How to Contact Us
9. Miscellaneous
1. Definitions and Interpretation
1.1 VTransPen products and/or services: including the VTransPen App (hereinafter referred to as the "Software").
1.2 VTransPen Service: refers to the service provided to users by Shenzhen Beibo Intelligent Technology Co., Ltd., the operator of VTransPen, hereinafter referred to as the "Service"
1.3 Shenzhen Beibo Intelligent Technology Co., Ltd.: the operator of VTransPen, specializing in intelligent speech and language technology research, software product development, voice information and other services. Registered address/common office address: 201, Building F, Yuanfen Industrial Zone, Taoyuan Community, Dalang Street, Longhua District, Shenzhen, Tel: 0755 27189290;
1.4 User: means the user who registers, logs in, and uses the Software and enables, browses, or uploads data to the VTransPen service, more commonly referred to as "you" in this Policy.
1.5 Affiliates: means any party that directly or indirectly controls, is controlled by us or is under common control with us. The terms "controlled" and "controlled" refer to the right to steer a party's management policies, whether through voting rights, contracts, or other means, respectively.
1.6 Account: refers to the user account that you enjoy after completing the registration of real information, and the user account is kept by you; You shall be legally responsible for all actions carried out under your account.
1.7 Personal information: Personal information refers to all kinds of information related to identified or identifiable natural persons recorded electronically or by other means, excluding anonymized information. For the avoidance of doubt, personal information includes, but is not limited to, sensitive personal information.
1.8 Sensitive personal information: Sensitive personal information refers to personal information that, once leaked or illegally used, is likely to cause infringement of a natural person's personal dignity or endanger the safety of their person or property, including biometrics, religious beliefs, specific identities, medical and health information, financial account numbers, whereabouts and track information, and the personal information of minors under the age of 14.
1.9 Processing of personal information: The processing of personal information includes the collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal information.
1.10 Personal information processors: Personal information processors refer to organizations and individuals that independently decide the purpose and method of processing in the processing of personal information.
1.11 Personal Data Subject: Personal Data Subject refers to the natural person identified or associated with Personal Information.
1.12 Automated decision-making: Automated decision-making refers to the activities of automatically analyzing and assessing an individual's behavioral habits, interests and hobbies, or economic, health, and credit status through computer programs, and making decisions.
1.13 De-identification: De-identification refers to the process by which personal information is processed in such a way that it is impossible to identify a specific natural person without the help of additional information.
1.14 Anonymization: Anonymization refers to the process by which personal information cannot be processed to identify a specific natural person and cannot be recovered.
1.15 Device: means a device that can be used to access the VTransPen Service, such as a desktop computer, laptop, tablet or smartphone.
1.16 Unique Device Identifier: A unique device identifier (unique ID or UUID) is a string of characters programmed into a device by the device manufacturer that can be used to uniquely identify the device (the IMEI number of the mobile device).
1.17 IP address: Every device that surfs the Internet is assigned a number, called an Internet Protocol (IP) address. These numbers are usually assigned based on geographic areas. An IP address can often be used to identify where a device is located when it connects to the Internet.
1.18 SSL: SSL (Secure Socket Layer), also known as Secure Socket Layer, is a security protocol implemented on the transmission communication protocol (TCP/IP). SSL supports various types of networks and provides three basic security services, all of which use public key and symmetric key technologies to achieve information confidentiality.
1.19 Information Collection Technologies: The "automatic collection" we refer to in this Policy includes the following methods:
(1) Cookie (web cookie) A cookie is a small text file placed by the web server on the client (your computer, mobile phone or other smart terminal) when you browse the web page, which can be used to improve your experience.
(2) Log files: Log files store certain amounts of data that are automatically collected. This data includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
(3) ET Tag (Physical Tag) ET Tag is an HTTP protocol header that is transmitted between the Internet browser and the Internet server, which can be used instead of cookies to track individual users, so that we can better understand and improve our services.
(4) JavaScript (Scripting Language) JavaScript is a programming language that is used to make more interactive and dynamic web pages. JavaScript can set cookies, read cookies, and delete cookies.
2. How We Collect and Use Your Personal Information
As a processor of personal information, we will follow the principles of legality, legitimacy, necessity and good faith to collect and use your personal information for the purposes described below.
According to the Provisions on the Scope of Necessary Personal Information for Common Types of Mobile Internet Applications, VTransPen is a "utility" app. The main function of VTransPen: After connecting the scanner, the OCR content of the scanner can be transferred to the VTransPen in real time, and the OCR content can be downloaded and exported. You only need to provide us with the basic and necessary personal information corresponding to each function, except for the special requirements of relevant laws, regulations and normative documents. If you refuse to provide it, we will not be able to provide you with the corresponding functional services. Please note that if you provide personal information that is not your own, please ensure that you have obtained the consent of the relevant subject. Details of the full functionality of VTransPen and the personal data to be processed are as follows:
2.1 Connect the scanning pen:
(1) Scope of necessary information and non-essential information
When you connect the scanner, we will collect your connection log data and the device information (device SN and MAC address) of the scanner for the pairing connection between the software and the scanner. This information is necessary to connect to the functional services of the scanner. Please be aware that when you encounter problems during use and need us to intervene to solve them, we need you to provide the aforementioned information.
After the pairing and connection of the scanner is completed, we will only use the software to transmit real-time data via Bluetooth, including the transmission of the scanner device information obtained directly through the scanner. If you refuse to provide this information, you will not be able to use the file transfer service, but it will not affect your ability to connect the scanner. The rules for the processing of your personal information by the scanner product shall be subject to the separate privacy policy accompanying the scanner, and if there is no separate privacy policy, please refer to this policy for the processing rules.
(2) The scope of the call
When you connect the Bebo Smart Scanner for the first time, we need to call your Bluetooth permissions, storage permissions and other permissions. Bluetooth permission is the necessary permission for the connection and communication between the Bebo scanner pen and the mobile phone, the storage permission is the binding code for the security verification of the cache scanner pen and the storage of call records and upgrade package files, so as to facilitate the normal operation of related functions, and the positioning permission is to start the ultra-low power Bluetooth protocol, which is used to identify the device and establish the necessary permission for the Bluetooth component to identify the device and establish a connection in the area when it is running. The above permissions are all necessary for the normal use of the device to connect the Bebo scanner to the mobile phone, if you refuse, you will not be able to use the corresponding functions.
2.2 Troubleshooting and Security Maintenance:
When you use VTransPen products and/or services, we will receive and record your relevant device information according to your specific permissions during software installation and use, including silent state and/or background running, for installation conflict detection, troubleshooting and location, and to ensure the security of your account and use. Software installation list, IMEI, DFV (iOS), CCID (Android), IMSI (Android), sensor information, service provider network ID, network access method, type and status of the network, unique device identifier (Android ID/IDFA/OPENUDID/GUID). If you refuse us to collect the above information, we will not be able to monitor the security of the Software, which may affect the security of your account and timely troubleshooting of related issues.
2.3 Operational statistics and analysis
When you use VTransPen products and/or services, we will automatically collect and store your details when using VTransPen products and/or services as network log information, including VTransPen App software version number, input box type, text type entered, search query content, network status, carrier, language used, access date and time, device crash, system activity, browsing history, download history and click history. In order for us to collect statistics on the use of VTransPen products and/or services, troubleshoot problems, ensure service stability and network security, and conduct operational analysis, improve and optimize product interaction experience through data statistics. If you refuse us to collect the above information, we will not be able to troubleshoot and conduct statistics for VTransPen App, which may affect your safety and experience.
2.4 Other Notes
• In order to ensure that the application can normally receive the information pushed by the client when it is closed or running in the background, the application must use the (auto-start) ability, and there will be a certain frequency of the system to send a broadcast to wake up the application to start automatically or associately start the application, which is necessary to realize the functions and services.
• When you open a content-based push message, you will be redirected to open the relevant content after obtaining your explicit consent. Without your consent, there will be no self-starting or associated activation.
• When you open a file downloaded from the App, the third-party App will be launched.
3. How we entrust the processing, sharing, transfer, and public disclosure of your personal information
3.1 Entrusted Processing
In order to provide you with better and better products and services, we will entrust third parties (including companies, organizations and individuals) to process some of your personal information. We will sign a strict data processing agreement with the third party that we entrust to process your personal information, clearly stipulating the purpose, period, processing method, type of personal information, protection measures, and the rights and obligations of both parties, and supervise the personal information processing activities of the third party, requiring the third party to only process your personal information in accordance with our requirements, the provisions of this Policy and any other relevant confidentiality and security measures, and shall not process personal information beyond the agreed processing purpose and processing method. If you refuse to allow our third party to collect personal information necessary for the provision of services in the course of providing services, you will not be able to enjoy the services provided by that third party during your use of VTransPen products and/or services.
3.2 Sharing
We will not share your personal information with third parties (including companies, organizations and individuals), except in the following circumstances:
(1) Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with third parties.
(2) Sharing under statutory circumstances: We will share your personal information with third parties in accordance with the provisions of laws and regulations, the needs of litigation and dispute resolution, or the requirements of administrative and judicial authorities in accordance with the law.
(3) Sharing with affiliates: Your information will be shared within our affiliates in order to be associated with our other products or services, to provide you with better services, or to protect the personal and property safety of our affiliates, other users or the public from infringement. We will only share your personal information among our affiliates for the specific, explicit and legitimate purposes stated in this Policy, and will only share the information necessary to provide services. For information shared with affiliates, we will require affiliates to take no less protective measures than those stated in this Policy for your information, and strictly comply with relevant laws, regulations and regulatory requirements. If the Affiliate Company wants to change the purpose of processing personal information, it will need to ask for your authorization and consent again.
(4) Sharing with authorized partners: For the purpose stated in this Policy, some of our services will be jointly provided by us and our authorized partners. We share your personal information with our partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and will only share the personal information necessary to provide services. Our partners are not authorized to use the shared personal information for any other purpose.
We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, requiring them to process personal information in accordance with our instructions, this Policy and any other relevant confidentiality and security measures, and shall not process personal information beyond the agreed processing purpose and processing methods, and require them to not People's Republic of China violate laws, regulations, national standards and other normative documents related to personal information protection and data security. In principle, the companies, organizations, and individuals with whom we share personal information do not have the right to use the personal information we share for any other purpose other than this policy.
3.3 Assignment
We will not transfer your personal information to any third party (including companies, organizations and individuals), except in the following circumstances:
(1) transfer with explicit consent;
(2) the transfer is necessary in accordance with applicable laws and regulations, legal process requirements, mandatory administrative or judicial requirements;
(3) In the event of a merger, acquisition or bankruptcy liquidation of the product and service provider, or other circumstances involving a merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved, we will inform you of the name or name and contact information of the recipient, and require the new recipient to continue to be bound by this Policy.
3.4 Public Disclosure
We will only publicly disclose your personal information in the following circumstances:
(1) With your separate consent or based on your active choice, we will publicly disclose your personal information;
(2) We will publicly disclose your personal information under the mandatory requirements of laws, legal procedures, litigation or government authorities.
(3) If we determine that you have violated laws and regulations or seriously violated the relevant agreement rules of this product, or in order to protect the personal and property safety of users or the public of this product and its affiliates from infringement, we will disclose your personal information in accordance with laws and regulations or relevant agreement rules of this product, including relevant violations and the measures that this product has taken against you.
3.5 Exceptions to obtaining prior authorization and consent when entrusting, sharing, transferring, or publicly disclosing personal information
In the following circumstances, entrusting the processing, sharing, transfer, and public disclosure of your personal information does not require your prior authorization and consent.
(1) When it is related to our performance of our obligations under laws and regulations;
(2) Directly related to national security and national defense security;
(3) directly related to public safety, public health, or major public interests;
(4) Directly related to criminal investigation, prosecution, trial and judgment enforcement;
(5) For the purpose of protecting the life, property and other major legitimate rights and interests of you or other individuals, but it is difficult to obtain the consent of the individual;
(6) Personal information that you disclose to the public;
(7) Personal information is collected from legally and publicly disclosed information, such as lawful news reports, government information disclosure, and other channels.
Please be aware that, in accordance with the law, the entrusted processing, sharing, transfer and public disclosure of anonymized personal information is not an external entrustment, sharing, transfer and public disclosure of personal information, and the storage and processing of such data will not require further notice to you and your consent.
4. How We Protect Your Personal Information
4.1 We attach great importance to the privacy and protection of personal information of users, and will take reasonable measures to protect users' personal information. Except as otherwise provided by laws and regulations or otherwise agreed in this Policy, we will use various security technologies and procedures to establish a sound management system to protect your personal information from unauthorized access, use or disclosure. We will not disclose or disclose the user's personal information to a third party without the user's permission, and we will use professional encrypted storage and transmission methods for the relevant information to ensure the security of the user's personal information.
4.2 You understand and agree that on the premise of not disclosing the private information of a single user, we have the right to conduct technical analysis of the entire user database, and only the user data after analysis and collation can be anonymized for commercial use.
4.3 Data Security Measures
(1) We have adopted security protection measures that meet industry standards, including the establishment of reasonable systems, norms and security technologies to prevent your personal information from being accessed, used and modified without authorization, and to avoid data damage or loss. For example, our network services adopt encryption technologies such as transport layer security protocols, and provide browsing services through HTTPS and other methods to ensure the security of user data during transmission. We use encryption technology (TLS, SSL), anonymization or de-identification processing and protection mechanisms to encrypt and store users' personal information, and isolate it through isolation technology; We manage and standardize the storage and use of personal information by establishing a data classification and grading system, data security management specifications, and data security development specifications; We only allow employees and partners of us and our affiliates who need to know such information to access personal information through information contact confidentiality agreements and other means, and have set up strict access control and monitoring mechanisms for this purpose, and require all personnel who have access to your personal information to fulfill corresponding confidentiality obligations. Failure to comply with these obligations may result in legal liability or termination of the relationship with us; We have held security and privacy training courses to raise employees' awareness of the importance of protecting personal information; We have formulated and organized the implementation of emergency plans for personal information security incidents.
(2) We will take all reasonable and practicable measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for as long as necessary to achieve the purposes stated in this Policy, unless it is necessary to extend the retention period or permitted by law.
(3) The Internet is not a completely secure environment, and e-mail, instant messaging, and communication with other users are not encrypted, and we strongly recommend that you do not send personal information through such means. Please use a complex password to help us keep your account secure.
(4) The Internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legitimate rights and interests, we will bear corresponding legal responsibilities.
(5) In the unfortunate event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the reasons for the occurrence of the security incident, the harm that may be caused, the types of personal information involved, the measures we have taken or will take to deal with it, and the suggestions and measures you can take to prevent and reduce the risks independently. We will promptly inform you of the relevant circumstances of the incident by email, text message, telephone, sending notices, etc., and if it is difficult to inform the personal information subject one by one, we will take reasonable and effective measures to make an announcement. At the same time, we will also take the initiative to report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities. Please be aware that, in accordance with the provisions of applicable laws and regulations, if measures can effectively avoid the harm caused by information leakage, tampering and loss, we will not notify you.
5. How We Protect the Personal Information of Minors
5.1 We attach great importance to the protection of minors' personal information, and we will protect minors' personal information in accordance with relevant national laws and regulations.
5.2 We consider anyone under the age of 18 to be a minor. In accordance with the provisions of relevant laws and regulations, if you are a minor over the age of 14, we will obtain the consent of you or your guardian before collecting your personal information, and if you, your parents or other guardians request us to correct or delete the minor's personal information, we will take measures to correct or delete it in a timely manner, unless otherwise provided by laws and administrative regulations.
5.3 If you are a minor under the age of 14 (hereinafter referred to as a child), we will obtain the consent of your parents or other guardians before collecting your personal information.
6. How Your Personal Information Is Transferred Globally
In principle, the personal information we collect in the territory of the People's Republic of China will be stored in the territory of the People's Republic of China and will not be transmitted across borders. If it is necessary to provide your personal information overseas due to business needs, we will inform you of the name or contact information, processing purpose, processing method, type of personal information, and the methods and procedures for you to exercise your rights under this Law to the overseas recipient, and will transfer your personal information to the overseas jurisdiction of the country/region where you use the products and/or services after obtaining your separate consent and the conditions required for cross-border provision as stipulated by laws and regulations. or to make your personal information accessible from these jurisdictions.
Please be aware that such jurisdictions may have different laws and regulations related to the protection of personal information, and we will comply with the requirements of the relevant laws and regulations in the jurisdiction to ensure that your personal information is adequately protected. If such jurisdictions do not have laws and regulations related to the protection of personal information, we will do our best to ensure that your personal information receives adequate and equal protection within the territory of the People's Republic of China.
7. How We Update this Policy
7.1 In order to provide you with better services, VTransPen products and/or services will be updated and changed from time to time, and we will revise this Policy from time to time, and these revisions will form part of this Policy. However, without your express consent, we will not reduce your rights under this policy.
7.2 After this Policy is updated, we will issue an updated version on VTransPen, and remind you to read the updated Privacy Policy again through the feature announcement of the new version of the App Market or pop-up window, so that you can keep abreast of the latest version of this Policy. If you do not agree to this Policy, or have any objection to the modification or update of this Policy, you can choose to stop using VTransPen products and/or services or cancel your VTransPen account. However, please be aware that your actions and activities before your account is cancelled and before you stop using this service are still subject to this Policy.
7.3 For major changes, we will also provide more prominent notices (we will explain the specific changes to this Policy by means including but not limited to email, text message, or special reminders on the browsing page).
The material changes referred to in this Policy include, but are not limited to:
(1) There has been a significant change in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way in which personal information is used, etc.;
(2) We have undergone significant changes in our ownership structure, organizational structure, etc. Such as all changes caused by business adjustments, bankruptcy mergers and acquisitions, etc.;
(3) Changes in the main objects of personal information sharing, transfer, or public disclosure;
(4) There are significant changes in your rights to participate in the processing of personal information and the way in which they are exercised;
(5) When there is a change in the department responsible for handling personal information security, contact information and complaint channels;
(6) When the personal information security impact assessment report indicates that there is a high risk;
(7) With the promulgation and implementation of policies or laws, changes are made in response to national policies or legal norms.
8. How to Contact Us
In order to better protect your personal information, we have set up a special cyber security and personal information protection department. If you have any questions or suggestions about this Policy or your personal information during your use of VTransPen, please contact us through the following contact information:
Contact number: 0755 27189290
Contact email (person in charge of personal information protection): szbbznai@szbbzn.com
Address: 201, Building F, Yuanfen Industrial Zone, Taoyuan Community, Dalang Street, Longhua District, Shenzhen
If you are not satisfied with our reply, especially if you believe that our personal information processing has harmed your legitimate rights and interests, and we are unable to provide you with a satisfactory reply and refuse to improve after you give us feedback, you can file a complaint and report to the relevant regulatory authority.
9. Miscellaneous
Under certain specific services or functions of VTransPen, we may also inform you of the purpose, method or scope of processing personal information through interactive copywriting, product interface or pop-up windows, etc., and if the content of the separate notice is inconsistent with this guideline, the content of the separate notice shall prevail.