Coscos Privacy Policy
Last update: April 9, 2024
Effective: April 9, 2024
Reminders
Coscos,
a social software featuring for its real-time translation service. We
are committed to protecting and respecting your privacy. This Privacy shows how
Coscos collects, uses and stores your personal information and the rights you
enjoy. At the same time, we will take appropriate security protection measures
to protect your privacy according to the mature security solutions in the
industry.
This Policy
applies to Coscos products and services!
It is important
to note that this Privacy Policy does not apply to services provided to you by
other third parties, nor does it apply to products or services that have separate
privacy policies.
Before using
Coscos products or services, it is your responsibility to read and accept the
terms and conditions of this Privacy Policy. By using Coscos, youre confirming
that youve fully understood and agreed with this Policy. If you have any
questions, comments, or suggestions of this Privacy Policy, you can contact us
through the contact information provided by Coscos.
This Policy describes:
1. How We Collect & Use Your Personal Information
2. Cookies & Similar Technologies
3. How We Share, Transfer, and Disclose Your Personal
Information
4. How We Protect Your Information
5. International Transfers of Your Personal Information
6. Services & Rights You Enjoy
7. Third-Party Services
8. How We Process Childrens Personal Information
9. Others
10. Contact Us
1. How We Collect & Use Your Personal Information
Personal Information refers to any data recorded in
electronic or other ways that, either on its own or jointly with other data,
can be used to identify a natural person or reflect the activities of a
specific natural person, including name, date of birth, identification card, biometric
data, address, contact information, communication records and contents, account
and password, property information, credit information, whereabouts,
accommodation information, physiological information and transaction
information, etc.
Sensitive personal data refers to personal data
that, if leaked, illegally provided or abused, may endanger personal safety and
property safety, may easily damage personal reputation, physical and mental
health, or may cause discriminatory treatment, including ID number, biometric data,
bank account, communication records and contents, property information, credit
information, whereabouts, accommodation information, physiological information,
transaction information, personal data of children who are 14 years of age or
younger, etc. (specific sensitive personal data are displayed in bold in this
Privacy Policy.)
The content of personal data and sensitive personal
data are from the Personal Information Security
Specification (GB/T35273).
You understand and agree:
We are committed to providing a variety of products
and services to meet your needs. There are differences in the types and scopes
of personal data collected and used due to users different choices among the
various products and services we provide. Please refer to specific product/
service features;
To bring you better products and service experience,
we are working hard to improve our technologies. As we may introduce new or
optimized features from time to time, we probably need to collect and use new
personal data or change the purposes or ways of using personal data. In this
regard, we will further explain to you the purpose, scope, and use of the
corresponding information by the ways like updating this Privacy Policy,
pop-ups, page prompts, etc., and provide you the option to agree, as well as only
collect and use the information with your explicit consent. If you have any
questions, comments or suggestions during this process, you can contact us
through the various contact information we provide, and we will answer your
questions as soon as possible.
The types of personal data we collect through the
products and services, and the principles for collecting and using personal data
(such as the purposes and methods of collecting and using personal data) are as
follows:
l
When
you register on Coscos, we will collect your information( such as nickname,
avatar, gender, date of birth, phone number, nationality, email, intended
username, and password) to create an account. If you agree and allow us to
authorize your account information (avatar, nickname, and information prompted
on other pages) to a third party so that you can easily register or log in to a
third-party account, we will share your authorized account information to the third
party. And, we may acquire your third-party account information from the third
party with your authorization, and bind the third-party account to your Coscos
account so that you can log in and use our products and/or services directly
through the third-party account. We will use your relevant information under
your authentication or consent. During registration and use of services, if you
provide additional information(such as your hobbies, occupation, height,
education, photo of yourself as your profile photo）to complete your profile, it will help us to provide
better services and experience to you. But, if you dont provide such
information, it will not affect your use of Coscos products and services. The
above information you provide will continue to be authorized for our usage
during your use of our services. When you cancel your account on your own, we
will make it anonymous and delete your personal information as soon as possible
under the requirements of applicable laws and regulations.
l
When
you start to use services provided by Coscos, we will collect data about the
services you use, how you use them, and correlate these information to ensure
your normal use of our services, to maintain and optimize our service
experience, and to keep your account safe. The above-mentioned information
includes：
(1)
Device
information. we will receive and record information about the device
you
use based on the specific permissions you grant in software installation
and
use. Such as device model, operation system version, setting parameters,
device
configuration, device identification, device network information,Mobile
device identification code (OAID, AndroidID), get application
installation list, GET_TASK to retrieve applications, device
environment, and other software and hardware characteristics
information.
(2) Service log
information. when you use products or services provided by our website or
client, we will automatically collect your detailed usage of our services and
save them as relevant service logs. Such as your browsing, click-to-view content
and search query content, following and sharing information, post information
as well as IP address, browser type, operator information, language used,
access date and time.
Please note that
separate device information or log information cannot identify a specific
natural person. If we use these kinds of information in combination with other
information to identify a specific natural person or use it with personal
information, then these information will be considered as personal information
during the combined use with other information, and besides obtaining your
authorization or otherwise provided by laws and regulations, we will anonymize
and de-identify such personal information.
l
When
you use the Feeds square, chat window, and other publishing functions to
publicly release information, including graphics / mini-videos / voices,
posting comments and text content, you need to open the permissions of your
album, camera, microphone to take photos or make videos or use voice
interaction function. Please note that the information you post publicly may
involve personal information of yourself or others, such as pictures you upload
when your release updates may contain personal information. Please consider
more carefully whether to share or publicly share relevant information when
using our services. Your uploaded photos, short videos, comments, Likes and
other data will be stored on our server because the storage of these data is
necessary to achieve the relevant uploading function. We will store these
information encrypted, and you can delete them at any time. We will not provide
the above information or use it for other purposes beyond its function unless
with your permission or under the relevant laws and regulations.
l
When
you choose to establish a Following relationship with someone you are
interested in or share information with other third parties through the
functional components we provide, we will collect service log information
including your Following relationship and Sharing history to implement the relevant
functions and other purposes that we explicitly notified to you.
l
When
you enjoy game services, we will collect and use your account information,
device information, game log information and transaction information to provide
you with better game services, game experience, ensure your normal use of our
services, maintain the normal operation of the basic functions of the game,
optimize the performance of game products, and ensure the security of your
account. If you interact with other players through text, pictures, voice, video
and other methods in the game, we will access your microphone, photo album,
camera, geographic location information after your authorization or consent, to
provide you with voice chat, video interaction with other game players. We may
collect and save the above-mentioned information you send to filter
inappropriate content such as pornography, violence, politics, abuse, malicious
advertisements to purify the game environment and maintain a healthy online
environment.
l
When
you purchase and pay for Gold Coins on Coscos, we will collect account
information provide and your ID.
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When
you contact us or file a dispute settlement application, we may need you to
provide the necessary personal data to verify your user identity to ensure your
account and the system security. To contact you, help you solve problems, or
record related solutions and results of the problems, we may keep the history
and content of your communication/call ( including account information, other
information you provide to prove relevant facts, or contact information you left).
To provide services and reasonable needs of improving service quality, we may
also need to use other information about you, including the relevant information
you provide when you contact customer service, and the information you sent to
us when you participated in the questionnaire we send to you.
l
When
you use the function of viewing your phone contacts, you need to open your
address book permission. We will irreversibly encrypt your address book data
and only collect the encrypted information. The above-mentioned information
belongs to sensitive information, and you will unable to the relevant functions if you refuse to provide the corresponding
information.
l
To
improve the security of the services provided to you by us and our affiliated
companies and partners, better protect the personal and property of you or other
users or the public from infringement, phishing websites, fraud, network
vulnerabilities, computer viruses, cyberattacks, network intrusion, and other
security risks, and more accurately identify violations of laws and regulations
or Coscos related agreement rules, we may use or integrate your user
information, transaction information, device information, related weblogs, and the
information our affiliates and partners shared with us after obtained your authorization
or under the law to comprehensively judge your account and transaction risks,
conduct identity verification, detect and prevent security incidents, and take
necessary recording, auditing, analysis, and disposal measures by law.
l
You
can use the products and services provided by our affiliated companies at the
link entrance provided by logging into your Coscos account. For the convenience
of our better providing you with one-stop service based on the associated
accounts, as well as bring convenience to your unified management, we will
display your information in Coscos or recommend the information you are
interested in, including information from malls, games, and education. You can
access the above-mentioned services on features like Discover on the Coscos
homepage.
l
You
understand and agree that the services we provide may require you to open the access permissions to your camera, album
(picture gallery), microphone (voice), and address book in your device to
collect and use the information involved in these permissions. When you use
related services, we will pop up a window to prompt you whether you want to
enable the corresponding permissions. You can also check the states of the these
permissions item by item in your device settings "Settings-Privacy-System
Permissions", you can also decide to open or close these permissions at
any time. Please note that when you open any permission, you authorize us to
collect and use relevant personal data to provide you with corresponding
services; once you close any permission, you cancel the authorization on our
behalf and we cant continue to collect and use the related personal data based
on the corresponding permission, so we cannot provide you with the related
services either. Its also important to note that your decision to close
permissions will not affect the previous collection and use of information
based on your prior authorization.
l
If
the information you provide contains other users personal information, you
shall ensure that you have obtained a legal authorization before providing such
information to Coscos.
l
If
we use your information for other purposes not specified in this policy or beyond
the specified purposes, or we take the initiative to obtain your information
from a third party, we will obtain your consent in advance.
l
If
we obtain your information indirectly from a third party, we will ask the third
party in a written form to collect your personal information after your consent
and inform you the shared content. If the data involves sensitive information, the
third party need to obtain your clear confirmation before providing it to us
for using and need to commit the legality and compliance of the source of personal data. We will ask the third party to
bear corresponding legal liability if it has any violation. At the same time,
our professional security team will protect your personal information
(including the classification of sensitive data, access control for the use of
sensitive data, encrypted storage of sensitive data, etc.).We will protect the
indirectly obtained personal data the same as we do for our own users personal
information except for the information you authorized to other third parties.
You fully understand and agree that we may not agree
with your requests about correction/modification, delete, cancel, withdraw
consent or ask for some information, and we do not need your authorization to
collect and use personal data in the
following situations:
l
Related
to national security and national defense security;
l
Related
to public safety, public health, and other major public interests;
l
Related
to crime investigation, prosecution, trial, judgment enforcement, etc.;
l
To
protect the life and property of the subject of personal data or other
individuals, and it is difficult to obtain your consent;
l
The
information you disclosed to the public by yourself;
l
The
information that is collected from legally and publicly disclosed channels,
such as legal news reports, government information disclosure.
l
Necessary
for signing a contract at your request;
l
Necessary
for maintaining a stable and safe operation of the products or services
provided to you, such as discovering and handling failures of the products or
services;
l
Necessary
for legal news reporting;
l
Necessary
for an academic research institution to conduct statistics or academic research
based on public interest. When they provide the description or results of
academic research to the outside, they will de-identify the personal
information contained in the results;
l
Other
circumstances required by laws and regulations.
Please note that the use of the following-mentioned processed
data, under the law, does not require to inform you or obtain your consent: if we
take technical and other necessary measures to personal data that cause the
data receivers cant re-identify or recover a specific individual data; we may
conduct de-identification research on the collected information, statistical
analysis, and prediction to improve the content and layout of Coscos, provide
product or service support for business decisions, and optimize our products
and services (including machine learning or model algorithm training using
anonymous data).
If we stop running Coscos products or services, we
will cease the collection of personal data in time, notify the suspension of
operations to you one-by-one or inform you with announcement, and delete or
anonymize the personal data we held.
2. Cookies & Similar Technologies
2.1. Cookie
To ensure that the website works properly, provide
you a relaxer visit experience of our platform, and recommend some content that
you may interested in, we store a small data file called Cookie on your
computer or mobile device. Cookie usually contains an identifier, a site name, and
some numbers and characters. By using Cookie, it is easier for the website to
store the data about your preferences, etc..
2.2. Web beacons and
Pixel tags
Apart from cookie, we use other similar technologies
such as web beacons and pixel tags on our websites. For example, the email we
send you may contain an address link to the content of our website, and if you
click on that link, we will track the click to help us understand your preferences
about products or services so that we can proactively improve the customer
service experience. Web beacons are images (often transparent) that are part of web pages
and emails. With the help of the pixel tags in the email, we can know if the
email was opened. If you do not want your activity to be tracked in this way,
you can unsubscribe from our mailing list at any time.
3. How We Share, Transfer, and Disclose Your Personal
Information
As we know the corresponding legal responsibilities
for sharing, transferring, and publicly disclosing personal information to the
outside world, we will only carry these operations to the extent agreed within
this Privacy Policy.
3.1. Share
We will not share your personal information with
companies, organizations, and individuals other than Coscos service providers,
unless:
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Sharing
with explicit consent. After obtaining your clear consent, we will share your
personal information with other parties.
l
Sharing
under legal situations. We may share your personal information externally under
the laws and regulations, the need for litigation and dispute resolution, or the
requirements by administrative and judicial authorities under the law.
l
To facilitate to provide services to you, recommend
information that may be of interest to you, identify abnormal account numbers
or protect the personal and property safety. or other users or the
public from the infringement, your personal information may be shared within
the company. We will only share the necessary personal information (such as we
will share the necessary account information within the company to make it
easier for you to login your Coscos account and enjoy the products or services
of. ), and will be subject to the purposes stated in this Privacy
Policy. If we share your personal sensitive information or the affiliates
change the purpose of using and processing your personal information, we will
once again seek your authorization.
l
Sharing
with authorized partners. After you agree to this Privacy Policy, we may
entrust authorized partners to provide you with certain services or perform
functions on our behalf to better serve you. We will only share your
information for the legitimate, necessary, specific, and clear purposes stated
in this privacy policy. Authorized partners can only access the information
they need to perform their duties and shall not use this information for any
other purposes.
At present, our authorized partners
include the following types:
（1）Authorized partners in advertising and
analysis services. Unless we have your permission, we will not share your
personally identifiable information with partners who provide advertising and
analysis services. We will entrust the partners to process information related
to advertising coverage and effectiveness, but we will not provide your
personally identifiable information, or we will de-identify the information so
that it does not identify you personally. Such partners may combine the above-mentioned
data with other data that they legally obtained to perform advertising services
or decision recommendations that we commission.
（2）Suppliers, service providers, and other
partners. We send information (your private information will not be included)
to suppliers, service providers, and other partners who support our business.
The support from them includes the provision of technology infrastructure
services, analysis of how our services are used, measuring the effectiveness of
advertising and services, providing customer service and payment convenience,
or conducting academic research and surveys.
We will conduct strict security check on application
program interfaces(APIs) and software tool development kits (SDKs) the
authorized partners obtained relevant information from and agree on strict data
protection measures with these parties to ensure that they comply with our
entrusted purposes, service description, this Privacy Policy, and any other
relevant confidentiality and security measures to process personal data.
3.2. Transfer
We will not transfer your personal information to
any company, organization, or individual, unless:
l
With
your clear consent, we will share your personal information with other parties;
l
In
situations involving mergers, acquisitions, bankruptcy liquidation, or other
situations related to mergers, acquisitions, or bankruptcy liquidation, we will
require new companies and organizations that hold your personal information to
continue to be bound by this Policy if personal information transfer is
involved. Otherwise, we will require the company, organization, and individual
to seek your authorization again.
3.3. Disclose
We will only disclose your personal information
publicly in the following cases:
l
With
your explicit consent or based on your own choices, we may disclose your
personal information publicly;
l
If
we confirm that you have violated laws and regulations or severely violated the
rules of Coscos related agreements, to protect the personal and property of
users of Coscos and its affiliates or the public from the infringement, we may
disclose your personal information including related violations and the
measures the platform has taken against you, under the laws and regulations or
Coscos related agreement rules.
3.4. Exceptions of no need for obtaining prior
consent when sharing, transferring or publicly disclosing personal information
Sharing, transferring, and publicly disclosing your
personal information does not require your prior consent in the following
situations:
l
Related
to national security and national defense security;
l
Related
to public safety, public health, and major public interests;
l
Related
to crime investigation, prosecution, trial, judgment enforcement, etc.;
l
To
protect the life and property of the subject of personal data or other
individuals, and it is difficult to obtain your consent;
l
Personal
information that you disclose to the public;
According to the law, if we take technical measures
and other necessary measures to process personal information so that the data
receiver cannot re-identify a specific individual and the data cannot be restored,
the sharing, transfer and public disclosure of such processed data shall not
need to notify you further and get your consent.
4. How We Protect Your Information
We work hard to protect the user's personal
information to prevent it from illegal using, unauthorized accessing,
disclosing, leaking, damaging and losing. We will use a variety of security
measures to ensure the safety of information within a reasonable level of
information protection. For example, we will use encrypted technologies(such as
SSL), anonymous processing, encrypted storage, etc, to protect your personal
information; build a reliable protection mechanism to protect your personal information
from malicious attacks; establish a access control mechanism and follow the
principle of least privilege to ensure that only authorized personnel have
access to the information; develop training courses about security and personal
information protection to strengthen staff's understanding of personal
information protection.
At present, Coscos has passed the filing and
evaluation of national cybersecurity level protection (level 3), to ensure that
personal data security meet the relevant national requirements.
We have an advanced data security management system
around the data life cycle with the core of data to improve the security of the
whole system from the aspects of management, organization, system, product
technology, etc.. We set a specific management system, process, and
organization to protect personal data.
For instance, we strictly limit the scope of personnel to access information,
require them to follow the secrecy obligation and conduct audit work. In case
of personal data leakage and other security incidents, we will launch contingency
planning to prevent security incidents from spreading and will notify you by
push notifications and announcements.
We will take reasonable and applicable measures, and
try to avoid collecting irrelevant personal information.
Given that the Internet is not a completely safe
environment, we strongly advise you that dont send your personal information
through other communication ways apart from Coscos recommended. You can connect
and share through our services. When you create communication, transaction, or
sharing information through our services, you can choose who you want to
communicate, transact or share with, and the third parties who can see your
transaction content, contact information, exchange information or sharing
related information.
If you find that your personal information,
especially your account and password has been leaked, please contact our
customer service as soon as possible so that we can take appropriate measures
according to your application.
Please note that the information you share or even
share publicly when using our services may involve personal information or
personal sensitive information of yourself or others. For example, the pictures
you posted in Feeds square, IM, or other public areas contain personal
information. So please consider carefully whether to share or share publicly
about the relevant information when using our services.
Please use a complex password to help us keep your
account secure. We will strive to ensure the security of any information you
send to us.
Meanwhile, we will also report the handling of
personal information security incidents under the requirements of regulatory
authorities.
5. International Transfers of Your Personal Information
The personal information we collect from users
during our operations in the People's Republic of China is stored in China,
unless:
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The
applicable law has clear rules;
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Obtaining
your clear authorization;
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Your
proactive behaviors, such as cross-border intersections through the internet.
To the above-mentioned circumstances, we assure you
that we will provide enough protection to your personal information under the
Privacy Policy.
6. Services / Rights You Enjoy
We take your management of personal data seriously
and work hard to protect your rights about the access, modification(updates or
correction), delete, withdraw, authorize and consent, to ensure that you can
protect your privacy and maintain the security of your personal information.
6.1 Access and correct your personal information
You can manage your personal information in the
following ways:
(1) Access to personal information
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After
logging into Coscos, click the "Me button
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Click
your avatar or nickname
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Access
your personal information
(2) Visit or delete personal updates
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After
logging into Coscos, click the "Me button
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Visit
My feeds
(3) Check and modify your personal bound accounts
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After
logging into Coscos, click the " Me button
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Click
the Bind account button
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Bind
third-party platform accounts or modify the bound third-party accounts
6.2 Manage/withdraw the information authorized to you
You have the right to access your personal
information, besides some exceptions under toe laws and regulations. You can
edit your personal information in your account by following ways:
Log in your account - click the Me button -
click the icon,then you can edit the following
information: avatar, personal signature, nickname, nationality, vocation, age,
height, weight, hobby;
log in your account - click the Me button -
click the Sets button - click Password setting, then you can modify your
password;
log in your account - click the Me button -
click Privacy setting, then you can decide on whether to open your profile,
whether to allow anyone to add you as a friend, whether to disclose your Likes,
and whether to disclose your comments.
Bind account: if you want to bind or modify a third
party account, you can perform such operations by logging in your account, then
clicking the Me button and Bind account.
If you cant manage/ withdraw your personal
information through the above-mentioned ways, you can contact Coscos customer
service at any time. We will respond to your access request within 15 days.
6.3 Select and control personalized recommendation
information on your own
Our related information recommendation function may
be made from non-manual automatic decision-making mechanism including
information systems, algorithms, etc. If you are not interested in the
information we pushed to you, or you want to reduce some information
recommendations, you can contact our customer service to perform precise
shielding of the information to help you to control and make autonomous
decisions on the push information.
6.4 Cancel your account
You can apply to cancel your account in our product
according to the relevant provisions of the Coscos User Agreement.
You can also log out of your account through "Me" - "Settings" - "Account Management" - "Delete this account".
You know and understand that it is an
irreversible action once you delete your account. After your account
cancellation, we will delete all the information related to your account or
anonymize the relevant information, apart from some exceptions followed by laws
and regulations.
6.5 Complaints reporting
You can make a complaint or report following our
publicity system. If you think that your right of personal information may be
infringed, or you find clues that your right of personal information was
violated, you can contact us through the feedback interface. We will feedback
your complaints and reports within 15 working days after verification.
6.6 Access Privacy Policy
You can view all the content of this Privacy Policy
on the registration page or click the Me button - Sets button - About
Coscos if you finished registration and logging into your
account. You can also access the Privacy Policy by clicking the Me
button - Sets button - Privacy Setting.
6.7 The right of notifying you if we stop operation
If we cease running the platform, we will stop
collecting your personal information in
time, notify you the cessation of running the platform through notification or announcement,
and delete or anonymize your personal information.
6.8 Related restrictions
By the laws and regulations, we cant respond to
your request in the following situations:
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Related
to national security and national defense security;
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Related
to public safety, public health, and other major public interests;
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Related
to crime investigation, prosecution, trial, judgment enforcement, etc.;
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When
there is sufficient evidence to show that the subject of personal data is
subjective malicious or abuses rights;
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To
respond to your request will cause serious damage to the legitimate rights and
interests of you or other individuals or other organizations;
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Involving
trade secrets;
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Bring
risks to the legal rights of others, or the requests are unrealistic.
7. Third-Party Services
We may use some of your information to send you
commercial advertisements or third-party services on relevant websites,
applications, and other channels. If you dont want to receive the commercial
advertisements we send to you, you can cancel or close them by the related product
unsubscribe function.
8. How We Process Childrens Personal Information
Minors under the age of 18 can't create their user
accounts / or use our services.
We will only use or disclose the personal data of
minors under the laws and regulations, with the explicit consent of their
parents or guardians, or under the necessary circumstances of protecting the
minors.
If we are aware that personal data of minors was
collected without acquiring valid consent from their parents, we will delete
the relevant information as soon as possible.
If you are the guardian of a minor, and you have
questions about the personal information of the minor under your guardianship,
please contact us through the contact information displayed in this Privacy
Policy.
9. Others
The Privacy Policy may have changes or updates.
Without your explicit consent, we will not limit
your rights under this Privacy Policy. If major changes are made to the Privacy
Policy, we may provide you a prominent notice (including notifying you through
channels like Coscos announcement or pop-up prompts).
Major changes referred to in this Privacy Policy
include, but are not limited to:
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Significant
changes in our service model. Such as the purpose of processing personal
information, the type of personal information processed, the way of personal
information used;
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Significant
changes in terms of control and others. Such as the change of ownership caused
by mergers and acquisitions;
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Changes
in the main objects of personal information sharing, transfer or public disclosure;
l
Significant
changes in your right to participate in the processing of personal information
and how you exercise it;
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Changes
of our responsible department for handling personal information security,
contacts information, and complaints channels;
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When
the personal information security impact assessment report indicates high risk.
We will also archive older versions of the Privacy
Policy for your reference.
10. Contact Us
We will respond to your request within 15 working
days, and you can contact us in the following ways:
coscos@gmail.com