Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.
How we can help you
1 What information is collected by us and how do we use it?
1.1 What information is collected by us
In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. We will only collect the information that is necessary for its specified, concrete, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our products or services or respond to your queries.
Depending on the service you choose, we may collect the following types of information:
1.1.1 Information you provide to us
We may collect any personal information you provide to us, which is necessary for the service you choose. For example, you may provide your name, mobile phone number, email address, delivery address, order, invoicing details, bank account number, account holder name, credit card number, and other information if you use maibenben.cn retailing services; you may provide gender, your security-related information and other information if you create an account.
1.1.2 Information that we collect in your use of services
• Device-related information. For example, MAC address, serial number, system version and type, ROM version, screen display information, device keypad information, device manufacturer details and model name, device activation time, network operator, connection type, basic hardware information, and usage information (such as CPU, storage, battery usage, screen resolution and device temperature, camera lens model).
• Information specific to you that may be assigned by third party service providers and business partners: We may collect and use the information such as your advertising ID assigned by third party service providers and business partners.
• Information related to your application usage, including application basic information, such as application list, application ID information, SDK version, system update settings, application settings (region, language, time zone, font) and application status record (e.g. downloading, installing, updating, deleting).
• Information generated when you use a service, such as your badges, ratings, sign-in information and browsing records in the MAIBENBEN Forum service; your messages on the MAIBENBEN Forum (only visible to both sending and receiving parties); the push content generated when you use push services; your behaviour (such as clicking, browsing, etc.) for advertising services.
• Location information (only for specific services): various types of information on your accurate or approximate location if you use location-related services (navigation software, weather software, and the software with device-locating functionality). For example, region, country code, city code, mobile network code, mobile country code, cell identity, longitude and latitude information, time zone settings, language settings. You can restrict access to location information of each application at any time within the phone settings (Settings – Permissions).
• Log information: information related to your use of certain features, apps, and websites. For example, cookies and other anonymous identifier technologies, IP addresses, network request information, temporary message history, standard system logs, crash information, log information generated by using the services (such as registration time, access time, activity time, etc.).
• Other information: Environmental characteristics value (ECV) (i.e. value generated from MAIBENBEN Account ID, device ID, connected Wi-Fi ID, and location information)
1.1.3 Information from third-party sources
When permitted by law, we will collect information about you from third-party sources. For example,
• for certain services that might include account and financial transactions, with your authorization, we may validate the information provided by you (such as phone number) through legitimate third-party sources for security and fraud prevention purposes;
• we may receive designated identifier symbols to provide advertising services to you;
• we may also obtain certain information such as account IDs and nicknames from third-party social network services (e.g. when you use a social network account to sign in to a MAIBENBEN service);
• information about you that others provided to us (e.g. your delivery address that other users may provide to us when they buy products for you via maibenben.cn services).
1.1.4 Non-personally identifiable information
We may also collect other types of information which are not directly or indirectly linked to an individual and which may not be defined as personal information according to applicable local laws. Such information may include statistical data generated when you use a specific service (e.g. non-identifiable device related information, daily usage events, page access events, page access time events and session events); network monitoring data (e.g. request time, number of request or error request etc.); application crash events. The purpose for such collecting is to improve the services we provide to you. The type and amount of information collected depends on how you use our products and/or services.
We collect information such as unique device identifiers, device models, system version numbers and information about your activities on our websites. We aggregate such information to provide you with more useful information, understand which parts of our websites, products and services you are most interested in. Such aggregated data is not personal information as it cannot be used to identify you. However, if we combine non-personal information with personal information, such information will be treated as personal information.
1.2 How we use the personal information that we collect
The purpose of collecting personal information is to provide you with products and/or services, and to ensure that we comply with applicable laws, regulations and other regulatory requirements. This involves:
• Providing, processing, maintaining, improving and developing our products and/or services to you, such as delivery, activation, verification, after-sales, customer support and advertising.
• Implementing and maintaining security safeguards for the purpose of preventing loss and fraud, such as assisting in identifying users, verifying user identity. We use your information for anti-fraud purposes only when the following two conditions are met: it is necessary; and the data used for evaluation is in accordance with the legitimate interests of MAIBENBEN to protect users and services.
• Handling your equipment, services, questions, or requests, such as answering customer inquiries, sending system and application notifications, managing your activities (e.g. sweepstakes).
• Conducting relevant promotional activities, such as providing marketing and promotional materials and updates. If you no longer wish to receive certain types of promotional materials, you may opt-out by the method provided in the message (such as the unsubscribe link at the bottom of the message) unless otherwise specified under applicable laws.
• Providing personalized services and content. We may recommend personalized products, services and activities, including advertising, based on information you generate when using our products and services, such as purchase history, website browsing history, and geographic location. You have the right to opt-out from receiving personalized advertisements and to object to profiling, including that carried out for direct marketing purposes, at any time. To do so, you can turn it on or off at any time by contacting us at email@example.com.
• Allowing you to post comments on public forums.
• Internal purposes, such as data analysis, research, and development of statistical information related to the use of our products or services to better improve our products or services. For example, machine learning or model algorithm training is performed after de-identification processing.
• Optimizing the performance of your device, such as analyzing the memory usage or the CPU utilization of your application.
• Storing and maintaining information related to you for our business operations (such as business statistics) or for fulfilling our legal obligations.
• Providing services locally on terminal devices that do not require communication with our servers, such as using Notes service on your device.
• Other purposes with your consent.
Here are more detailed examples on how we use your information (which may include personal information):
• Activating and registering your purchased MAIBENBEN products or services for you.
• Creating and maintaining your MAIBENBEN Account. Personal information collected when you create a MAIBENBEN Account on our websites or through mobile devices, is used to create the personal MAIBENBEN Account and profile page for you.
• Processing your purchase order. Information related to e-commerce orders is used for processing the purchase order and related after-sales services, including customer support and re-delivery. In addition, the order number will be used to cross-check the order with the delivery partner as well as to record delivery of the parcel. Recipient information, including name, address, phone number, and postal code will be used for delivery purposes. Your email address is used to send you parcel tracking information. A list of purchased items is used for printing an invoice and enables the customer to see which items are in the parcel.
• Participating in the MAIBENBEN Forum. Personal information related to the MAIBENBEN Forum or other Internet platforms may be used for profile page display, interaction with other users, and participating in the forum.
• Providing location-based services. In the course of using MAIBENBEN services, location information may also be used by us or third party service providers and business partners (for more information see “How we share, transfer, and publicly disclose your personal information” below) to serve you the correct version of the service and provide accurate details about that location for the best possible user experience, e.g. weather details, location access. You may turn off location services in settings or turn off the use of location services of an app at any time.
• Improving user experience. Some opt-in features, such as the User Experience Programme, allow MAIBENBEN to analyse data about how users use the device and services, so as to improve the user experience, such as sending crash reports.
• Allowing you to use Security. Information collected may be used for security and system up-keeping functionalities in the Security app, such as Security scan, Battery saver, Block-list, Cleaner, etc. Some of these functionalities are operated by third party service providers and/or business partners (for more information see “How we share, transfer, and publicly disclose your personal information” below). Information (which is not personal information like virus definition lists) is used for Security scan functions.
• Providing push service. MAIBENBEN Account ID will also be used to provide the MAIBENBEN push service to evaluate advertising performance and send notifications about software updates or new product announcements, including information about sales and promotions. Furthermore, under entrust of selected third parties (who will also be data controllers of your personal information – for more information see “How we share, transfer, and publicly disclose your personal information” below), the MAIBENBEN push service may also evaluate advertising performance or send notifications by using your MAIBENBEN Account ID. We may use your personal information for the purpose of sending you push messages (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties. You may opt-out from receiving marketing from us and third parties at any time through changing your preferences under device Settings, or managing your preferences through the third-party app/website using MAIBENBEN push. Please also see “Your rights” below.
• Verifying user identity. MAIBENBEN uses the ECV value to verify the user identity and avoid unauthorized login.
• Collecting user feedback. The feedback you choose to provide is valuable in helping MAIBENBEN make improvements to our services. In order to follow up on the feedback you have chosen to provide, MAIBENBEN may correspond with you using the personal information that you have provided and keep records of this correspondence for problem solving and service improvement.
• Sending notices. From time to time, we may use your personal information to send important notices, such as notices about purchases and changes to our terms, conditions, and policies. Since such information is critical to your interaction with MAIBENBEN, it is not recommended that you refuse to receive such information.
• Conducting promotional activities. If you enter into a sweepstake, contest, or similar promotion through MAIBENBEN’s social media platforms, we may use the personal information you provide to send you these rewards.
• Conducting device analysis to provide better user experience. MAIBENBEN will conduct the hardware and software analysis to further improve the device experience.
2 Cookies and other technologies
Technologies such as cookies, tags, and scripts are used by MAIBENBEN and our third party service providers and business partners (for more information see “How we share, transfer, and publicly disclose your personal information” below). These technologies are used in analyzing trends, administering the site, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. These technologies help us better understand users’ behaviour, tell us which parts of our websites people have visited, as well as facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non‑personal information, except where Internet Protocol (IP) addresses or similar identifiers are considered personal information by local laws.
• Log files: As true of most websites, we gather certain information and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we gather about you.
• Advertising: We partner with our third party service providers and business partners (for more information see “How we share, transfer, and publicly disclose your personal information” below) to either display advertising on our website or to manage our advertising on other sites. Our third party service providers and business partners may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising service based upon your browsing activities and interests. We will obtain your prior explicit consent and involve a clear affirmative action before providing this advertising service to you. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking “Back”.
• Local storage – HTML5/Flash: We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content and preferences. Third parties with whom we partner to provide certain features on our sites or to display advertising based upon your web browsing activity also use HTML5 or Flash cookies to collect and store information. Various browsers may offer their own management tool for removing HTML5 LSOs.
3 How we share, transfer, and publicly disclose your personal information
We do not sell any personal information to third parties. We may sometimes share your personal information with third parties (as described below) in order to provide or improve our products or services, including offering products or services based on your requirements. If you no longer wish to allow us sharing this information, please contact us at firstname.lastname@example.org.
3.1.1 Sharing that you actively choose or request
With your explicit consent or at your request, we will share your personal information within the scope of your consent/request with specific third parties designated by you. For example, when you use the MAIBENBEN Account to sign in to a third-party website or app.
3.1.2 Sharing information with our group
In order to successfully conduct business operations and to provide you with all the functions of our products or services, we may share your personal information from time to time to other MAIBENBEN affiliates.
3.1.3 Sharing with third party service providers and business partners
To provide performance measurement, analysis, and other business services, we may also share information (non-personal information) with third parties (such as advertisers on our websites) in aggregated form. We use the information we have to help advertisers and other business partners evaluate the effectiveness and coverage of their advertising and services, and understand the types of people who use their services and how people interact with their websites, apps, and services. We may also share general usage trends of our services with them, such as the number of customers in a particular group of people who purchase certain products or engage in certain transactions.
In accordance with legal requirements, legal procedures, litigation and/or requests from public agencies and government agencies, MAIBENBEN may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.
In order to enforce our terms or protect our business, rights, assets or products, or to protect users, or if the disclosure is reasonably necessary for the following purposes (detecting, preventing and resolving fraud, unauthorized use of the product, violations of our terms or policies or other harmful or illegal activities), we may also disclose information about you. (There may be occasions when MAIBENBEN may collect, use or disclose your personal information without your consent if it is and only to the extent it is permitted under applicable data protection laws). This may include providing your personal information to public or government agencies; communicating with third-party partners about the reliability of your account to prevent fraud, violations, and other harmful behaviors.
In addition, we may share your personal information with:
• our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice; and
• investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to an entity in the MAIBENBEN Group; and
• any other third parties, if authorized by you to do so in relation to a specific disclosure.
MAIBENBEN will not transfer your information to any subject except in the following cases:
• Where we have obtained your explicit consent;
• If MAIBENBEN is involved in the merger, acquisition, or sale of all or part of its assets, we will notify you of any changes in the ownership, use, and any choice of your personal information you possibly possess by e-mail and/or by posting a prominent notice on our websites.
3.3 Public disclosure
In addition to releasing the winner’s email address or MAIBENBEN Account ID or user name when publishing the winner list in de-identifiable form, MAIBENBEN will only publicly disclose your personal information under the following circumstances:
• Where we have obtained your explicit consent;
• Public disclosure based on law or reasonable grounds: including laws and regulations, legal procedures, litigation or at the request of the competent government departments.
4 How we store and protect your personal information
4.1 MAIBENBEN’s security safeguards
We are committed to keeping your personal information secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place all legally required physical, electronic and managerial procedures to safeguard and secure the information we collect on your device. We will ensure that we safeguard your personal information in accordance with applicable law.
All your personal information is stored on secure servers, and protected in controlled facilities. We classify your information based on importance and sensitivity, and ensure that your personal information has the required level of security. We have special access controls for cloud-based data storage, and we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.
We conduct due diligence on business partners and third party service providers to make sure that they are able to protect your personal information. We also check that appropriate security standards are maintained by these third parties by putting in place appropriate contractual restrictions, and where necessary, carrying out audits and assessments. In addition, our employees and those of our business partners and third party service providers who access your personal information are subject to enforceable contractual obligations of confidentiality.
We conduct security and privacy protection training courses and tests to enhance our employees’ awareness of the importance of protecting personal information. We will take all practicable and legally required steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information when transferred from you or to you via the Internet.
We handle personal data breaches as required by applicable data protection law which includes, where required, notifying the breach to the relevant data protection supervisory authority and data subjects
4.2 What you can do
You can set a unique password for MAIBENBEN by not disclosing your login password or account information to anybody (unless such person is duly authorized by you) to avoid password leaks to other websites which may harm your account security at MAIBENBEN. Whenever possible, please do not disclose the verification code you received to anyone (including those who claim to be MAIBENBEN customer service). Whenever you sign in as a MAIBENBEN Account user on MAIBENBEN websites, particularly on somebody else’s computer or on public Internet terminals, you should always sign out at the end of your session.
MAIBENBEN cannot be held responsible for lapses in security caused by third party accessing your personal information as a result of your failure to keep your personal information private. Notwithstanding the foregoing, you must notify us immediately if there is any unauthorized use of your account by any other Internet user or any other breach of security. Your assistance will help us protect the privacy of your personal information.
4.3 Accessing other features on your device
Our applications may access certain features on your device such as enabling email to use contacts and Wi-Fi network status, etc. This information is used to allow the applications to run on your device and allow you to interact with the applications. At any time you can revoke your permissions by turning them off at the device level or by contacting us at email@example.com.
4.4 Retention policy
5 Your rights
Controlling your personal information
5.1 Controlling settings
MAIBENBEN recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways MAIBENBEN makes available to you to restrict the collection, use, disclosure, or processing of your personal information and control your privacy settings:
• Toggle on/off for the User Experience Programme and location access functions;
• Sign in or out of the MAIBENBEN Account;
If you have previously agreed to us using your personal information for the aforementioned purposes, you may change your mind at any time by writing or emailing us at firstname.lastname@example.org.
5.2 Your rights to your personal information
Depending on applicable laws and regulations, you have the right to access, rectification, and erasure of any other personal information that we hold about you (hereinafter referred to as the request).
You may also access and update the details relating to the personal information in your MAIBENBEN Account at www.maibenben.cn or by signing in to your account on your device. For additional information, please write to us or contact us at the email address below. Email: email@example.com.
(1) Through MAIBENBEN’s exclusive access of request and for the protection of your information security, your request should be in writing (unless the local law explicitly recognizes the oral request);
(2) Provide sufficient information to enable MAIBENBEN to verify your identity and ensure that the applicant is the subject or legally authorized person of the requested information.
Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request within any time frame set out under your applicable data protection laws.
• Based on the requirements of applicable laws, a copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests for relevant information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.
• If any information we are holding on you is incorrect or incomplete, you are entitled to have your personal information corrected or completed based on the purpose of use.
• Based on the requirements of applicable laws, you have the right to request the deletion or removal of your personal information where there is no compelling reason for us to keep using it. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures. If the right is upheld, we may not be able to immediately remove the information from the backup system due to applicable legal and security technologies. If this is the case, we will securely store your personal information and isolate it from any further processing until the backup can be cleared or be made anonymous.
• You have the right to object to certain types of processing, including processing for direct marketing (including where profiling is used), and under certain circumstances where the legal basis for processing (including profiling) is our legitimate interests.
Particularly under the laws of some jurisdictions:
• You have the right to obtain from us the restriction of processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.
• You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• You have the right to apply for your personal information in a structured, commonly used format and transmit the information to another data controller.
We have the right to refuse to process requests that are not meaningful/entangled, requests that damage others’ right of privacy, extremely unrealistic requests, requests that require disproportionate technical work, and requests not required under local law, information that have been made public, information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, it may also be rejected.
5.3 Withdrawal of consent
You may withdraw your consent previously provided to us for a particular purpose by submitting a request, including collecting, using, and/or disclosing your personal information in our possession or control. Based on the specific service you are using, you can send an email to firstname.lastname@example.org. We will process your request within a reasonable time from when the request was made, and thereafter not collect, use and/or disclose your personal information as per your request.
Depending on the extent of your withdrawal of consent, please note that you may not be able to continue receiving the full benefit of MAIBENBEN’s products and services. The withdrawal of your consent or authorization will not affect the validity of our processing carried out on the basis of the consent up until the point of withdrawal.
5.4 Cancelling a service or account
If you wish to cancel a specific product or service, you can send an email to email@example.com for logout service.
If you wish to cancel the MAIBENBEN Account, please note that the cancellation will prevent you from using the full range of MAIBENBEN products and services. Cancellation may be prevented or delayed in certain circumstances.
6 How your personal information is transferred globally
If we need to transfer personal information outside of your jurisdiction, whether to our affiliates or third-party service providers, we will comply with related applicable laws. We ensure that all such transfers meet the requirements of applicable local data protection laws by implementing uniform safeguards. You can find out about the safeguards that we have in place by contacting us at firstname.lastname@example.org.
If MAIBENBEN shares personal data originating by you in the EEA to a MAIBENBEN Group entity or a third party service provider outside the EEA, we will do so on the basis of EU standard contractual clauses or any other safeguards provided for in the GDPR.
7 Protection of minors
We consider it the responsibility of the parent or guardian to supervise the child’s use of our products or services. However, we do not offer services directly to a child or use personal data of children for the purposes of marketing.
If you are a parent or guardian and you believe that the minor has provided MAIBENBEN with personal information, please contact us at email@example.com to ensure that the personal information is removed immediately and that the minor is unsubscribed from any of the applicable MAIBENBEN services.
8 Do I have to agree to any third party terms and conditions?
The following are the examples of when third party terms and privacy policies may apply when you use the specific products listed above:
10.1 Single sign-on
Depending on your jurisdiction, you may be able to log in to our website using a variety of login provided by OAuth services. These services will authenticate your identity, provide you the option to share certain personal information (such as your name and email address) with us, and to pre-populate our sign-up form. The OAuth services allow you to choose whether or not to post information about your personal activities on this website to your profile page to share with others within your network.
11 Contact us
Guangzhou ZIMAI Technology Co., Ltd. Room 1408, Building H, No. 61, Dalingshan Road, Tianhe District, Guangzhou, Guangdong, China