Acorn International Privacy Policy

Issuance Date: March 1st, 2020

Privacy Policy

Reminder

Your trust is very important to us. We are well aware of the importance of Personal Information to you, so we will take protective measures in accordance with laws and regulations to ensure that your personal information is safe and controllable. In view of this, Acorn International (or “we”, “us”, or “our’) has formulated this Acorn International Privacy Policy (the “Policy” or “Privacy Policy” hereinafter) and reminds you:

This Policy applies to all products and services provided by Acorn International and its Affiliates. If we and our Affiliates (please refer to the applicable section in this Policy for details) have separate privacy policy for the products and services provided to you, the corresponding privacy policy shall be applied for such products and services.

This Policy sets out the basic content of any Personal Information we collect from you or you provide to us that will be processed by us, including our perspectives and practice of the collection of your Personal Information and privacy protection. You shall carefully read and thoroughly understand this Policy, especially focus on the clauses marked in bold/bold underline, and confirm that you have fully understood and agreed to this Policy before using any products or services of Acorn International and its Affiliates.  You shall use our products and services after fully understanding and consent to this Policy.

If you have any questions, comments, or suggestions regarding the content of this Policy, please contact us through the contact methods set forth in this Policy.

Part I     Application

This Policy shall apply to all the websites, application programs, online games/lucky draws, products and services of Acorn International and its Affiliates, as well as other online or offline activities involving the collection and the processing of Personal Information initiated or sponsored by Acorn International and its Affiliates.

Affiliates: refers to the affiliates disclosed by Acorn International, Inc. in its latest annual report (https://www.acorninternationalgroup.com/financial-and-stock-information/sec-filings/).

For more information, please visit www.acorninternationalgroup.com.

Note that this Policy does not apply to the services that third parties provide to you, nor does it apply to any other third-party websites, including the websites that our platform may mention or can be visited through the links on our platform.

 

Part II   Definition

Personal Information: refers to all kinds of information, recorded electronically or otherwise, which can be used, independently or in combination with other information, to identify a specific natural person or reflect the activities of a specific natural person.

Personal Sensitive Information: includes personal information such as identity certificate number, personal biometric identification information, bank account number, property information, whereabouts, transaction information, information of children aged 14 years or below. (We will highlight the specific personal sensitive information in bold in this Privacy Policy).

Personal Information Deletion: refers to the act of removing personal information from the systems involved in daily business operations so as to keep such information irretrievable and inaccessible.

Children: refers to any minor under the age of 14.

 

Part III Privacy Policy

This part will help you understand the followings:

1. Collection of Your Personal Information

When you purchase our products or use our services, we need or may need to collect and use your Personal Information, provide to us by filling the membership forms, uploading online contents, subscribing online service (e.g.: application programs and social networking pages) or through email. The types of the Personal Information involved are (including but not limited to):

Name, email address, gender, phone number, shipping address/contacting address, age/birth date, your suggestion to our products, payment details (e-commerce platform), your purchase history (e-commerce platform), any special requirement when contacting us (for the purpose of record) and the pictures, audios or videos which you are happy to share.

We may ask you to accomplish our survey for the research and statistical analysis.

We may obtain the above Personal Information of yours from a third party which you gave your consent to share your above Personal Information or authorize a third party to share the above Personal Information of yours to accomplish or improve the quality of our products and services.  Our service may enable you to order products or services for others.  Your information may be also shared to other users of our services, including Personal Information, especially when using the services that are specifically designed to share the information among the users.  Unless otherwise claimed by the owner who has the right of the information, such information shall be treated as your Personal Information in accordance with this Policy.  Therefore, please carefully consider the aforementioned sharing information with others.  If you volunteer to share the aforementioned information with us, we will be deemed to have obtained the authorization.

In order to offer a better product and service experience to you, we are constantly striving to improve our technologies, and we may introduce new or optimized functions from time to time, so we may need to collect and use new Personal Information or change the purpose or method of use of Personal Information.  Therefore, we will separately explain to you the purpose, scope, and method of the corresponding information collection and use through updates to this Policy, pop-up windows, prompts on webpages, or otherwise, and provide options for you to make your own choice, and collect and use your information after obtaining explicit consent from you. In this process, if you have any questions, comments, or suggestions, feel free to contact us, and we will answer your questions as soon as possible.

If the information you provide contains Personal Information of other users, you must ensure that you have obtained legal authorization before providing such Personal Information to Acorn International. If children’s Personal Information is involved, you must ensure that you have obtained the consent from the children’s guardian before publishing. The guardian has the right to contact us through the method set forth in this Policy to request the correction or deletion of the contents involving the children’s Personal Information.

If we obtain your information indirectly from a third party, we will explicitly request in writing that the third party collect Personal Information after legally obtaining your consent, inform you of the shared information and, in case of any sensitive information involved, obtain your explicit confirmation before providing such information to us, and that the third party warrant the legality and compliance of the sources of such Personal Information. If the third party commits any violation, we will explicitly request the third party to undertake relevant legal liabilities.

You fully understand and agree that we may collect and use your Personal Information without your authorization or consent under the following circumstances, and we may not respond to your request for corrections/modifications, deletions:

  • (1) Related to national security and national defense security;
  • (2) Related to public security, public health, or major public interests;
  • (3) Related to criminal investigation, prosecution, trial, enforcement of the judgement, or other judicial or administrative enforcements;
  • (4) For the purpose of protecting life, property, and other major legal rights and interests of yours or any other individuals’, where it is difficult to obtain your consent;
  • (5) The Personal Information that you voluntarily disclose to the public;
  • (6) Personal information collected from the information disclosed through public channels that are legal, such as lawful news reports or information disclosure by the governments;
  • (7) It is necessary according to the agreements or other written documents entered into with you, and the implementation thereof;
  • (8) It is necessary to maintain the safe and stable operation of the products and/or services provided, for example, to detect and correct the defects in the products or services;
  • (9) It is necessary for legitimate news reports;
  • (10) It is necessary for statistical or academic research conducted by academic research institutions based on public interest, where the personal information contained in the results has been de-identified when academic research or descriptions are provided externally;
  • (11) Other circumstances as stipulated by the laws and regulations.

 

2. Use of Your Personal Information

We will collect and use your Personal Information only for the following purpose:

We mainly use your Personal Information for the purpose of managing clients/relationship perspective, especially replying to your request or sending you the news and information of the products we sell (including but not limited to the products you purchased), the brands we sell or provide services to (including but not limited to the brand of the specific product you purchased), and relevant privileges and special offers, our initiatives, as well as other news and information on our platform that you may be interested in.

We also will use your Personal Information to improve your digital experience on our platform, i.e. knowing the content on the platform that you may be interested in. According to your order, we will manage your online account, verify your registration information for participation of our activities, process your payment, manage and complete/withdraw your transaction to ensure our platform can provide you with effective services.

If you do not wish to receive commercial advertisement and relevant information from us, you may choose to unsubscribe or close such messages by replying text message in accordance with the instruction contained in the text message or other means provided by us.

If we use the information for any purpose other than those stated in this Policy, or if we use the information collected for a specific purpose for any other purpose, we will obtain your consent in advance.

Please be reminded that, in accordance with the applicable laws, if we process Personal Information with technical measures and other necessary measures so that the data recipient cannot re-identify a specific individual or restore the data, or if we use the information we collect for de-identified research, statistical analysis and forecasting and improving our products and services, we may use such processed data without separately notifying you and obtaining your consent.

3. Collection of Your IP Address, Use of Cookies

For the purpose of system management and/or statistics, we will collect your IP addresses and the types of your browser without any action of identifying Personal Information.

In certain circumstances, we will use Cookies, small files consisting of characters and numbers which are downloaded and stored in your device when you visit our platform.  When you visit our platform again, it shall identify you and provide you the content matching your interest.

The default setting of a web browser is usually set to receive Cookies, but you can easily change it by modifying your browser settings. However, please note that if you choose to turn off receiving Cookies, you may not be able to access part of the content on the platform.

In addition to Cookies, we also use other similar technologies. For example, the email that we send to you might contain an address link to the content of our website. If you click the link, we will track it. This helps us understand your product or service preferences, so that we can proactively improve the customer service experience. If you do not want your activities to be tracked in this way, you may unsubscribe from our mailing list at any time.

4. Sharing or Public Disclosure of Your Personal Information

We may share your Personal Information with Acorn International and its Affiliates.

We may also share your Personal Information to reliable third parties. We may entrust reliable third parties to perform certain functions on our behalf.

Reliable third parties may only have access to the information necessary to perform their responsibilities and will not use such information for any other purposes. We shall urge the third parties to take necessary measures to protect the safety of your Personal Information with our best effort.

We may share your Personal Information to:

  • Agencies of advertising, marketing, digital and social media, which shall help provide advertisement, marketing and promotion, analysis of the effectiveness and manage your contact detail and requests;
  • The third parties that delivery you the products on request, such as postal/courier service agency;
  • Analytics and search engine vendors which help us to improve and optimize our platform; and

We may disclose your Personal Information to third parties under the following circumstances:

  • We may disclose your Personal Information to the potential seller or buyer in case we sell or purchase any business or assets. Your Personal Information as the asset we owned regarding our clients, may be a part of the assets to be transferred in case all or parts of our assets are acquired by third parties.  The company, organization or individuals, as the new holder of your Personal Information, shall continue to be bound by this Policy, otherwise we shall request such company, organization and individuals to obtain your consent./li>
  • We may share your personal information externally in accordance with provisions of laws and regulations, litigation and disputes resolution needs, or requirements of administrative or judicial authorities in accordance with the law;
  • We may disclose or share your Personal Information to i) perform our obligation in accordance with the laws; ii) perform or apply our terms of use or other agreements; iii) protect our rights, assets or safety or the safety of our clients or others; including exchanging your Personal Information with other companies and organization for the sake of anti-fraud protection; and
  • When you give your consent or when it is allowed by the laws and regulations.
5. Storage of Your Personal Information

Your Personal Information shall be stored in the database of ours or our service providers’.

The Personal Information collected and generated within the territory of the People’s Republic of China (the “PRC”) shall be stored within the territory of PRC, with the following exceptions:

  • when explicitly stipulated by the applicable laws;
  • when your explicit authorization is obtained;
  • your personal initiatives, such as the cross-border transactions through internet.

In terms of the abovementioned circumstances, we will ensure the sufficient protection of your Personal Information in accordance with this Policy.

6. Safety Storage of Your Information

To save your Personal Information in the most reliable and secure way at all time, we only process it when necessary.  We will take appropriate security, technical and management measures to protect your information against any modification, loss or unauthorized access.

7. Protection of the Privacy of Minors

In e-commerce activities, we presume that you have the corresponding capacity for civil conducts.

If you are a minor under the age of 18, you must request your parent or guardian to carefully read this Privacy Policy, and you must not use our services or provide information to us without the consent of your parent or guardian, nor can you establish your own account.

We will delete the information of minors where we found we collected such information without the consent of parent or legal guardian that can be verified.

8. Updates to this Privacy Policy

We may change our Privacy Policy. Please pay attention to our updates to this Policy. The updates will be published here.

Without your explicit consent, we shall not constrain your right set forth in this Policy.

9. Contact Methods

If you have any questions, comments or suggestions regarding this Policy, want to change the scope of your authorization for us to collect, use Personal Information, or terminate your authorization, please contact our customer service center through xiamin@chinadrtv.com.