Personal Information Protection and Privacy Policy

Effective Date: September 19, 2019

This Privacy Policy applies to D-Chat products and services. We have developed this Privacy Policy to explain how D-Chat will collect, use, retain, share and protect your personal information. This Privacy Policy mainly covers the following:

  1. According to the specific functions of D-Chat, in this Privacy Policy, we will explain to you the extent of personal information that may be collected for each function, the collection purposes, and the collection methods. We will collect and use your information in strict accordance with the principles of legality, appropriateness, and necessity.
  2. D-Chat may need to seek your permissions to access some of the information in your mobile phone to provide services for you. When you agree with this Privacy Policy, corresponding permissions will not be granted by default. If a specific function requires any important or sensitive permission, we will otherwise pop up a window to seek your consent to grant such permission. When permission is granted, you may deny it through device settings at any time.
  3. We will use or share your personal information solely in the scenarios described herein. If your personal information is used or shared beyond the scope described in this Privacy Policy, we will notify you and obtain your explicit consent in this regard.

The contents of this Privacy Policy are as follows:

1. How We Collect Your Personal Information

2. Device Permissions

3. How We Use Cookies and Similar Technologies

4. How We Use Your Personal Information

5. How We Retain and Protect Your Personal Information

6. Sharing, Transfer, and Public Disclosure of Personal Information

7. Update of Privacy Policy

8. How to Contact Us

1How We Collect Your Personal Information

For the purposes of this Privacy Policy, personal information refers to a variety of information that is recorded by electronic or other means and can be used separately or in combination with other information to identify a natural person. Sensitive personal information refers to the personal information whose divulgence, illegal provision, or misuse may endanger personal and property safety, easily damage personal reputation or physical or psychological wellness, or result in discriminatory treatment.

The personal information we collect may include the information provided by you to us when you use D-Chat, the information related to your use of our service, and the information from other sources such as our business partners and related entities. What information we may collect depends on the product functions you actually use.

1.1 To Create and Maintain Your D-Chat Account

You need to create a D-Chat account before using it. We will collect your profile picture, name (Chinese/English), work email, business unit, position, direct supervisor, and location. You are also free to set your own nickname, based on which we fill in your personal card information and create an account for you.

1.2 To Provide You with Related D-Chat Services

1.2.1 To record your work assignments, D-Chat will record your chating contents when you chat online using the Messaging function of D-Chat. When you make a call via D-Chat, including calls by virtual numbers and voice call, we will record the call.

1.2.2 When you use Discovery or other functions like posting and commenting in other modules, D-Chat will record your posts and comments.

1.2.3 The Mine module of D-Chat includes a number of commonly used tools. When you use such tools, each appropriate tool will collect the information generated when you use it. For example, the process approval tool (including My Approval and HR Self-help Service) will record the process you initiated or approved; the purchase and booking tools (including Food Area, Coffee World, Conference Room, Xiaoju i Design, My Di Welfare Service, and Bonus Points Mall) will collect your purchase and booking order information. To mail the items you purchased, you are also required to provide the information like delivery address, addressee, and phone number. Tools for browsing and downloading purposes only (including Restaurant Menu and Billing Assistant) will collect your browsing and downloading records, etc. Frequently used tools may be updated, added or removed from time to time. The information to be collected and used will be subject to what is provided by you or displayed on the tool page.

1.2.4 Location Information. Before you use D-Chat for the first time, we will prompt you for option of permitting D-Chat to access your location information and the scenarios in which D-Chat may access your location information. You may choose to permit D-Chat to access your location information and the scenarios in which D-Chat may access your location information via the setting of your device at any time in the course of use of D-Chat. With your consent, we will access your location information through IP address, GPS, and other sensors that may provide such information.

1.2.5 Device Information. With the specific permission you have granted during the installation and use of the software, we will receive and record information about the device you use, including device model, operating system version, device settings, unique device identifier and other hardware and software information.

1.2.6 Log Information. When you use our website or client-side products or services, we will automatically collect your detailed usage of our services and retain such information as the relevant web-log. Such information may include your search string, IP address, type of browser, telecommunications operator, language used, date and time of access, records of web pages you browsed, call status information, approval log information, and attendance log information.

1.2.7 When you use third-party payment services, we will collect the information regarding your payment tool and payment status.

1.3 Please understand that we will constantly update and develop the functions and services provided to you. If the foregoing content does not include a certain function or service but your information has been collected for such function or service, we will otherwise describe the content, scope, and purpose of collection of information by page prompt, interactive process, website announcement, execution of agreement, and other means to obtain your consent.

2. Device Permissions

D-Chat may need to seek your permissions to access some of the information in your mobile phone to provide services for you. When you agree to this Privacy Policy, corresponding permissions will not be granted by default. If a specific function requires any important or sensitive permission, we will otherwise pop up a window to seek your consent to grant such permission. When permission is granted, you may deny it through device settings at any time.

3. How We Use Cookies and Similar Technologies

3.1 Cookie is a mechanism to support information storage and retrieval at the client by the server (or script). Cookies and other technologies may be used for our websites and client-side products to provide you with an easier and more secure access and for our relevant data analysis.

3.2 When you use D-Chat, we may use Cookies or other similar technologies to collect and store information to provide you with an easier and more secure access. During such process, we may send one or more Cookies or anonymous identifiers to your device. In doing so, we collect your information to understand your preferences, perform consulting tasks or data analysis, improve products, services, and user experience, and timely identify and safeguard against security risks for providing you with better services. We will not use Cookies for any purpose other than those described in this Privacy Policy. You may save or delete Cookies according to your preferences. You may clear all Cookies saved in the software. When you clear the Cookies manually, your relevant information will be also deleted.

4. How We Use Your Personal Information

4.1 Your personal information will be used in the scenarios as expressly enumerated in the “How We Collect Your Personal Information” section.

4.2 Your personal information may be used in the following scenarios that are directly or reasonably related to the purposes as stated in the “How We Collect Your Personal Information” section:

4.2.1 In order to prevent, identify and investigate any fraud, infringement, violation of laws, or violation of our or our Affiliates’ agreements, systems or rules, and to protect the legitimate rights and interests of you, other users, us and our Affiliates, we may use or integrate your personal information collected by D-Chat and information shared by our Affiliates or partners with your authorization or as required by laws.

4.2.2 We may combine the personal information from certain D-Chat services with the information from other services for feature model and user profiling, so as to provide you with more personalized and convenient services. We undertake that when using user profiling, we will not infringe upon the legitimate rights or interests of any individual citizen, legal person or other organization, or jeopardize the national security, honor or interest.

4.2.3 We may design, develop, and promote brand-new products and services based on the user personal information statistics.

4.2.4 We will keep statistics on the use of our services and may share such statistics with the public or third parties. Such statistics, however, do not contain any of your identification information.

4.2.5 We will send you messages and notifications, including but not limited to verification codes required to complete services, and push notifications required for use of products or services.

4.3 If we use your personal information beyond the extent that is directly or reasonably related to the purposes as stated in the “How We Collect Your Personal Information” section, we will notify you and obtain your explicit consent in this regard.

4.4 In addition, we may collect and use your personal information without your authorization or consent under the following circumstances according to applicable laws and regulations and national standards:

a) Any information directly related to national security and national defense;

b) Any information directly related to public security, public health, and significant public interest;

c) Any information directly related to criminal investigation, prosecution, trial, and execution of judgment;

d) For the sake of safeguarding significant legal rights and interests, such as the life and property, of personal information subjects or other individuals, but it is difficult to obtain their consent;

e) The personal information collected is voluntarily published by personal information subjects before the general public;

f) The personal information is collected from information that has been legally and publicly disclosed, such as legal news reports and information published by the government;

g) Other circumstance prescribed by laws and regulations.

5. How We Retain and Protect Your Personal Information

Retention of Personal Information

5.1 We will retain and use in the Mainland of China your personal information we collect. In case of cross-border transfer of your personal information, we will clearly inform you of the purpose, receiving party, and security measures etc. of such personal information overseas transmission and will otherwise obtain your consent in this regard.

5.2 We will constantly retain your personal information in the course of your use of D-Chat services.

Protection of Information

5.3 We will apply strict security system and security technologies and programs commonly used in the industry to protect your personal information from loss, divulgence, destruction, or unauthorized access or use.

5.4 We will adopt the following security technologies and measures to protect your personal information:

5.4.1 Users’ sensitive personal information will be encrypted and stored in servers by using the data isolation technology.

5.4.2 Encrypted transmission protocol will be adopted in the course of sensitive personal data transmission.

5.4.3 We will strictly control data access privilege and set up a well-established system for request for and approval of access right to sensitive data.

5.4.4 We will set up a data security monitoring and audit system for comprehensive data security control.

5.5 We will adopt other security measures to protect your personal information at the same time:

5.5.1 We will set up a corporate information security committee for unified coordination and management of data security work. A data security team will be set up under the committee to push forward all data security activities.

5.5.2 We will issue and implement the internal norms for data security management to specify the standards and requirements for protection of user’s data (including user’s personal information).

5.5.3 We will conduct risk assessment for data security (including user’s personal information and data) prior to launch of new projects and systems.

5.5.4 We will enter into confidentiality agreement with the entire staff and service contractors and distribute access right in strict accordance with job responsibilities.

5.5.5 We will regularly organize information security education and training for the entire staff and service contractors.

5.6 In order to cope with the possible security risks of divulgence, destruction, and loss of personal information, we have set up a variety of systems, set the standards for classification and grading of security incidents and flaws, and internal handling process (including emergency response process) and remedial measures against such security incidents and flaws.

5.7 Although we will endeavor to protect your personal information using commercially practical methods, we cannot guarantee its absolute security. If any personal information under our control is divulged due to any security incident, we will take reasonable measures to conduct investigations, and if appropriate, notify the subject whose information may be divulged in accordance with applicable laws and regulations. If it is difficult to notify such personal data subjects one by one, we will release warning information via announcement on our platform.

Discontinuation of Operation

5.8 If D-Chat discontinues operation, we will announce such discontinuation on D-Chat platform at least thirty (30) days in advance and timely cease collection of personal information.

5.9 We will cease use of personal information for commercial purposes upon discontinuation and anonymize the personal information collected upon expiry of the minimum data retention period as provided by laws and regulations.

6. Sharing, Transfer, and Public Disclosure of Personal Information

6.1 Sharing refers to the process of providing personal information by us to other personal information controller, and both parties have their respective independent control over such personal information. We will not share your personal information with any other parties, except for the following circumstances:

6.1.1 Sharing with explicit consent: We will share your personal information with your designated third parties to the extent permitted by you with your explicit consent.

6.1.2 Sharing as required by laws: We may share your personal information as required by laws, regulations, litigation dispute resolution, or by administrative or judicial authority in accordance with laws.

6.1.3 Sharing with Affiliates: For the purpose of corporate management, your information may be shared among DiDi’s Affiliates. We will share personal information solely to the extent necessary and for the purposes stated in this Privacy Policy.

6.1.4 Sharing with our business partners: We may share your personal information with our partners or other third parties so as to ensure successful completion of the services provided to you. We will only share your personal information for lawful, proper, necessary, specific and express purposes to the extent required for providing the services. Our partners include

6.1.5 In order to maintain others’ legitimate rights and interests, we may provide the information required for settlement of controversies or disputes over transactions to interested third parties when assisting in settling the disputes in which you are involved.

6.2 We will not transfer your personal information to any other parties, except for the following circumstances:

6.2.1 Transfer with explicit consent: We will transfer your personal information to other parties with your explicit consent.

6.2.2 As our business is continuously growing, we may conduct mergers, acquisitions, asset transfer or other transactions. Under such circumstances, we will advise you of relevant cases, and will continue, or require a new controller to continue, to protect your personal information in accordance with laws and under the standards not less strict than those in this privacy policy.

6.3 We will keep your personal information confidential in abidance with applicable laws and regulations. We will not disclose your personal information unless we obtain your explicit consent or authorization in advance or such disclosure is required by applicable laws.

6.4 In addition, we may share, transfer, and disclose the personal information without the authorization or consent of the personal information subject under the following circumstances as required by applicable laws and regulations and national standards:

a) Any information directly related to national security and national defense;

b) Any information directly related to public security, public health, and significant public interest;

c) Any information directly related to criminal investigation, prosecution, trial, and execution of judgment;

d) For the sake of safeguarding significant legal rights and interests, such as the life and property, of personal information subjects or other individuals, but it is difficult to obtain their consent;

e) The personal information collected is voluntarily published by personal information subjects before the general public;

f) The personal information is collected from information that has been legally and publicly disclosed, such as legal news reports and information published by the government.

7. Update of Privacy Policy

7.1 In case of the following changes to D-Chat, we will update this Privacy Policy accordingly in due time:

7.1.1 Any change to our basic situation, for example, change of ownership due to merger, acquisition, and restructuring;

7.1.2 Any material change to the scope, purposes and rules for collection, storage, and use of personal information;

7.1.3 Any material change to the method of your accessing and managing personal information;

7.1.4 Any material change to the channel and mechanism of user access and complaint filing; and/or

7.1.5 Any other change that may have material impact on your legitimate rights and interests in respect of your personal information.

7.2 After such update, we will notify users of the updated Privacy Policy through push notifications, email/SMS, announcement, or otherwise. At the same time, we suggest you regularly review our Privacy Policy to understand the updates in a timely manner. Your continuous use of D-Chat services after this Privacy Policy is updated shall be deemed that you have fully read, understood, and accepted, and agreed to be bound by the updated Privacy Policy.

8. How to Contact Us

You may contact our customer service team online or service hotline through the “Customer Service” function of mobile device to submit your concerns or complaint.

If you have any question or concern about our Privacy Policy or practice, please contact our personal information protection officer at the following email address. We will verify and address your reported issue as soon as practical.

Email: [email protected]