RED SCARF LIMITED PRIVACY NOTICE

隐私权政策

本政策仅适用于深圳市瑞德斯佳网络科技有限公司提供的Red Scarf产品或服务，主营业务为网上导购包括Red Scarf各端口App，Red Scarf Web网站服务：https://www.honglingjin.co.uk/。

最近更新日期：2024年10月

如果您有任何疑问，意见或建议，请通过以下联系方式与我们联系：[email protected]

 

本公司非常重视用户的隐私，并尽力确保用户隐私安全。用户在分享下述个人身份信息前，请仔细阅读本条款：

 

1）在下列情况下，Red Scarf将收集用户提供的个人信息：用户注册；用户调查；登录发布通知；注册参与抽奖或领取赠品；向Red Scarf发送电子邮件，或以任何其他方式向Red Scarf发送用户信息。所收集的信息可能包括用户姓名、性别、电子邮箱、地址、手机号码、密码、第三方登录用户名、唯一ID及头像。用户无需提供个人信息便可使用Red Scarf的部分服务，但一些旨在保护用户信息的功能将无法使用。

 

Red Scarf还会在用户使用Red Scarf的服务时收集用户的非个人信息，如用户的浏览器类型、先前访问网站的URL、ISP、操作系统和IP地址。如果用户通过移动设备或其他设备访问网站或App，为了保障您的账号安全、交易安全以及系统运行安全，满足法律法规和我们协议规则的相关要求，在您使用我们的产品/服务过程中，经您授权， Red Scarf将收集分配给该设备的唯一设备识别码(如IMEI/ Android ID/ Android Advertisement ID/ IDFA/ OPENUDID/ GUID/ OAID、SIM卡IMSI、ICCID信息)或该设备的其他信息(设备序列号，设备信息号、设备MAC地址、软件列表、电信运营商软硬件特征信息)。如果用户收到Red Scarf的电子邮件或提醒信息，不论是否点击其中包含的广告或要约，Red Scarf均视为已将其打开并对相关信息进行跟踪。此外，与绝大部分网站或者App运营商一样，“Red Scarf”记录互联网域名和主机名、互联网协议（IP）地址、浏览器软件和操作系统类型、点击流模式、访问属性、服务的日期和时间，用于分析和报告。

 

为提高您使用我们提供的服务的安全性，更准确地预防钓鱼网站欺诈和木马病毒，我们可能会使用或整合您的个人信息以及我们的关联方、合作伙伴取得您授权或者依法共享的信息，根据您的使用习惯和常用软件信息等来综合判断您的账 号及交易风险，包括验证身份，预防、发现、调查可能存在的欺诈、网络病毒、网络攻击等安全风险以及违反我们或关联方协议、政策或规则等行为，以保护您、其他用户、我们或关联方的合法权益，并记录一些我们认为有风险的链接(“URL”)。

 

如果用户通过Facebook、Google、新浪微博第三方服务供应商访问网站或者App，一分钱将访问授权请求中所述的信息。用户须审查第三方服务提供商的隐私设置，确保只共享想要共享的信息。

 

我们会通过应用程序接口（API）、软件工具开发包（SDK）与第三方进行必要的数据共享，不同版本的第三方SDK 会有所不同，一般包括第三方账号登录类、分享类、第三方支付类、地图导航类、厂商推送类、统计类等，我们会对第三方进行严格的安全检测并约定数据保护措施。

 

Red Scarf收集个人信息明示清单:

 

Red Scarf接入第三方SDK目录如下:

请您知悉，我们仅会出于合法、正当、必要、特定、明确的目的共享您的个人信息，对我们仅为实现本政策中声明的目的与之共享个人信息的公司、组织和个人，我们会与其签署严格的信息保护和保密协定，要求他们遵守协议并采取相关的安全措施来保护您的个人信息。

 

2) 您可以选择授权我们收集和使用个人信息的场景(基于系统权限的附加服务)

为向您有效地提供服务，我们在向您提供的以下附加服务中可能会通过开启系统权限以收集和使用您的部分个人信息。这类信息将在您选择的具体功能和业务场景中进行收集,如果您不同意开启相关权限,不会影响您使用Red Scarf的基本功能。

 

您可以在您的设备设置或我们的相关客户端“设置-隐私-系统权限”中逐项查看上述权限的状态, 并可自行决定这些权限随时的开启或关闭。

 

请您注意, 您开启任一权限即代表您授权, 我们可以收集和使用相关个人信息来为您提供对应服务, 您一旦关闭任一权限即代表您取消了授权, 我们将不再基于对应权限继续收集和使用相关个人信息, 也无法为您提供该权限所对应的服务。但是, 您关闭权限的决定不会影响此前基于您的授权所进行的信息收集和使用。

 

以下为应用权限申请与使用的具体情况说明:

 

3）Red Scarf可通过以下任何一种方式使用所收集的任何用户信息：

 

• 优化网站或者App（Red Scarf长期致力于基于用户信息和反馈不断优化网站或者App功能。）
• 改善客户服务（用户信息有助于Red Scarf更有效地应对提高客户服务请求和支持需求。）
• 管理活动、推广、调查或其他网站功能。
• 定期发送电子邮件和提醒信息（用户注册时提供的电子邮箱地址仅用于向用户发送与网站或者App有关的信息和更新以及用户请求的交易信息。选择加入Red Scarf邮件列表的用户将收到包含要约、优惠券、企业新闻、更新信息、相关产品或服务等信息。Red Scarf会在每封邮件的下方提供详细的退订说明。用户可随时取消接受消息。）
• 执行相关政策和本协议的条款和条件。

 

4）Red Scarf非常重视用户个人信息安全，您的个人隐私信息将存储于中华人民共和国境内。当您成功申请注销Red Scarf账户后，我们将在您提出申请的48小时内完成对您的账户注销审核，审核通过后，我们将对您的个人信息进行删除或匿名化处理。如果我们终止服务或运营，我们会至少提前三十日向您通知，并在终止服务或运营后对您的个人信息进行删除或匿名化处理。注销功能路径为：主页面点击右下角‘我‘tab页面-右上角设置按钮（图标为齿轮状）-账号与安全-账号注销，之后根据弹框提示完成注销功能即可。

 

5）Red Scarf利用cookies了解和保存用户访问偏好（声明：本产品目前并无根据用户偏好进行定向推送或个性化信息提供的服务，此处的偏好是根据众多用户使用以及访问的情况及时调整app整体的内容），并对广告进行跟踪，对网站、App的流量和交互数据进行汇总，以便Red Scarf未来为用户提供更好的网站体验和工具。Red Scarf可能会携手第三方服务提供商，以便更好地了解网站和App访问者。第三方服务提供商以Red Scarf名义收集的信息，仅可用于帮助Red Scarf提供和完善服务之目的。

 

第三方供应商Google会使用cookie在我们的网站投放广告。谷歌使用DART cookie向访问我们的网站或互联网上其他网站的用户发送广告。用户可通过访问Google广告和内容网络隐私政策，停止使用DART cookie。

 

6）Red Scarf不出售、交易或以其他方式向除受信任的第三方（协助Red Scarf经营网站和App、开展业务、为用户提供服务）以外的任何其他方转让用户个人信息，受信任的第三方也必须同意对用户的个人信息保密。“Red Scarf“可以出于遵守法律、执行网站/App政策或保护“Red Scarf”或其他方权利、财产或安全等目的而披露用户信息。但是，非个人信息可能会供其他方用于营销、广告或其他正当用途。

 

7）Red Scarf的网站和App包含或提供第三方产品或服务的网络链接。此类第三方网站具有单独和独立的隐私政策。因此，Red Scarf对于这些链接网站的内容和活动不承担任何责任。尽管如此，Red Scarf寻求保护网站和App的完整性，欢迎用户就相关网站提供反馈。部分链接可能由广告商提供，如果点击广告内容，用户将通过关联cookies跳转至广告商网站。

 

8）本在线隐私政策仅适用于通过在线网站和App收集的信息，不适用于离线收集的信息。

 

9) 联系我们

 

当您对本政策有任何疑问，可以通过点击“Red Scarf”平台的“邮箱地址”（Web尾部）或“设置-意见反馈”（APP）进行咨询，同时也可以联系邮箱：[email protected]，我们将及时解决您的问题。

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Introduction

Welcome to the Red Scarf Limited’s (company number 07909979) privacy notice.

Red Scarf Limited (collectively referred to as “Red Scarf”, “we”, “us” or “our” in this privacy notice) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or mobile application (the “Platforms”)(regardless of where you visit it from) and use our services and tells you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Red Scarf collects and processes your personal data through your use of the Platforms and engaging our services, including any data you may provide through the Platforms or by other means.

The Platforms are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements our other notices and policies and is not intended to override them.

Controller

Red Scarf is the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the DPO using the details set out below.

Contact details

Our full details are:
Full name of legal entity: Red Scarf Limited
Contact Person: Media Product Director
Email address: [email protected]
Postal address: Kennington Business Centre 1-3 Brixton Road, London, England, SW9 6DE

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us (our contact details are set out above) in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on the date as shown at the bottom of this privacy notice. Historic versions can be obtained by contacting us (our contact details are set out above).

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our Platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platforms, we encourage you to read the privacy notice of every website you visit.

Affiliate Links

Certain links on our Platforms to third-party websites, plug-ins and applications are affiliate links. We may share your personal data with our affiliate partners and vice versa to track affiliate sales from our Platforms.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Contact Data includes your email or a social media account of yours for registration.

• Identity Data includes your chosen username, gender, your chosen photograph and your location.

• Marketing and Communications Data includes your preferences regarding the marketing materials and information that you receive from us and our third parties and your communication preferences.

• Profile Data includes your interests, preferences (favourite brands and deals), feedback and survey responses.

• Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, heat map, operating system and platform and other technology on the devices you use to access our Platforms.

• Usage Data includes information about how you use our Platforms, products and services.

We also collect, use and share data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your and others’ Profile Data to calculate the percentage of users that have a specific preference. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:

• • subscribe to our service or publications (for example, newsletter and push notifications);
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • make a transaction on our site or our partner’s website;
  • give us some feedback.

• Automated technologies or interactions. As you interact with our Platforms, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy below.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  · Technical Data analytics providers such as Google, Yandex, Baidu and others based outside the EU;
  · Contact Data from providers of technical services.
  · Identity and Contact Data from data brokers or aggregators.
  · Identity and Contact Data from publicly available sources such as Companies House and the Electoral
  · Register based inside the EU.

• Our App. In order to provide you with one-click sharing service, our App has integrated Umeng+ U-Share SDK , which will collect your device identifiable information (such as IMEI/android ID/IDFA, etc.) and public information of social account in order to share information with social account. For your information security, we have made data security confidentiality agreements with Umeng+, who will strictly abide by our data privacy and security requirements. We will not share your personal identifiable information unless authorized by you. For more information, please log in www.umeng.com/policy to learn the privacy policy of Umeng+.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (our contact details are set out above).

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (our contact details are set out above) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). The cookies are used for personalised ads or content.

You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us (our contact details are set out above).

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service experience.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

 

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

 

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

 

 

To deactivate the use of third-party advertising cookies, you may visit the consumer page to manage the use of these types of cookies.

 

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (our contact details are set out above).

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

 

• External Third Parties as set out in the glossary below.
• Specific third parties that will provide you with a good or service.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We have employees based in China, who have access to the personal data.Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it.

7. Data security

We store all data on the server we have with Fasthosts Internet Limited (www.fasthosts.co.uk).

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us (our contact details are set out above).

By law we have to keep basic information about our customers (including Contact and Identity Data) for six years after they cease being customers for tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

 

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (our contact details are set out above).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

Last updated [11/10/2024]