WanDianDuoDuo Privacy Policy
Release date: October 17, 2023
Effective date: October 17, 2023
PT. indo bali tour &travel and its affiliated companies ("we") attach great importance to the protection of user information and will diligently and prudently protect the security of user information. When you register, log in, and use (hereinafter collectively referred to as "use") Wandianduoduo content marketing platform (hereinafter collectively referred to as "CMP") products and the clients and applications we provide (the aforementioned websites, clients and applications are collectively referred to as the "official website") and related products, services, solutions ("Services"), the information we collect that you actively provide, and the information we collect through automated means generated during your use of the official website and related services, are called "User Information". Including but not limited to personal information provided by users to the official website. We will collect, use, store, transfer and protect your personal information in accordance with the relevant provisions of this Privacy Policy. We hope to introduce you to our handling of your personal information through this Privacy Policy, so we recommend that you carefully read and understand all the contents of this Privacy Policy. Among them, the clauses that limit or exclude liability are in bold form to remind you to pay attention, so please read them carefully.
If you do not agree to this privacy policy, we cannot provide you with complete services, and you should immediately stop using the official website and related services. When you choose to use the official website and related services, it will be deemed that you accept and acknowledge that we will process your relevant information in accordance with this privacy policy.
This privacy policy will help you understand:
1. How we collect and use personal information
2. Use of cookies and similar technologies
3. How we store personal information
4. Partners involved in data use and transfer and disclosure of personal information
5. How do we protect the security of user information?
6. Management of personal information
7. Privacy Policy Revisions and Notices
8. Scope of application
9. How to contact us
1. How we collect and use personal information
1. Personal information we directly collect and use
We will collect user information that you actively provide when using the official website and related services in the following scenarios and business activities, and we will collect user information generated during your use of the official website and related services through automated means,including but not limited to personal information provided by users to the official website.In particular, you are reminded that if the information cannot identify you individually or in combination with other information and has nothing to do with you, it does not constitute your personal information in the legal sense;When your information can personally identify or relate to you, either alone or in combination with other information, or when we combine data that cannot be linked to any specific personal information with other personal information about you, then during the combined use period , this information will be treated and protected as your personal information in accordance with this privacy policy. It should be clarified that personal information does not include information that has been anonymized.
1.1 When you register and log in to the official website account
1.1.1 To use official website services, you need to log in to a registered official website account. When you register an account on the official website, you can create an account through your mobile phone number, set user name, and password. We will verify whether your identity is valid by sending a SMS verification code. This information is collected to help you complete registration and login.
1.1.2 If you use an account on another platform to log in to the CMP official website or use another platform account to associate or bind your CMP account, it means that you authorize us to obtain relevant information about your other platform account,for example, the account/account information of the Zhishen platform (including but not limited to company name, login name, name, phone number, department, role and other information authorized by you).
1.2 When you use the official website and related services
(1) We are committed to providing you with safe and trustworthy products and usage environments. Providing high-quality and reliable services and information is our core goal. In order to maintain the normal operation of our services and protect the legitimate interests of you or other users or the public from losses, we will collect necessary information to maintain the safe and stable operation of our products or services.
(2) When you browse or use the official website, in order to ensure the normal operation and operational security of the website and services, prevent network attacks and intrusion risks, and more accurately identify violations of laws and regulations or CMP-related agreements and service rules,we will collect device information such as your device hardware model, operating system type and operating system version number, network device hardware address (MAC), IP address, software version number, browser type and browser version, resolution, time zone and language, network access method and type information, web browsing records. Please understand that this information is the basic information we must collect to provide services and ensure the normal operation of services and network security.
(3) In order to allow you to experience better services and ensure your safety, we may record network log information, as well as the frequency of using the official website and related services, crash data, usage and related performance data.
(4) When you publish or submit text, pictures, messages, comments or any other content ("posted content") through the official website, the official website will retain your name and published content.
(5) When you participate in the official website survey, the official website may retain information such as your account ID, name, address, mobile phone number, job identity, product and service usage, etc,in order to contact you later, verify your identity information, and provide you with rewards (if any) in accordance with the relevant activity rules. If the specific survey and other activity rules are inconsistent with this Agreement, the activity rules shall prevail.
(6) When you actively provide your name, phone number, and company name by filling in the official website investment page, the official website will retain the above information to contact you in the future to introduce and recommend CMP products and services to you.
(7) We may collect user consultation records, troubleshooting records and troubleshooting processes for user failures (such as communication or call records) generated by your use of the official website and related services,we will record and analyze this information to respond to your request for help in a more timely manner and to improve our services.
(8) Contract information. If you need to apply for offline delivery or conduct product testing, etc., you should provide contact person, contact information, address, invoicing information, order and other necessary information necessary to perform the contract.
(9) You understand and agree that for your contact information (i.e. contact number and email address) provided by you during the use of products and/or services,we may send notifications to one or more of them during operations for user message notification, identity verification, security verification, user experience research, etc.;In addition, we may also use the mobile phone number collected in the aforementioned process to provide you with commercial information such as services, functions or activities that may be of interest to you through text messages and phone calls.But please rest assured that if you do not want to accept this information, you can unsubscribe through the unsubscribe method provided in the mobile phone text message or email, or you can contact us directly to unsubscribe.When we use information for other purposes not specified in this policy, or when we use information collected for a specific purpose for other purposes, we will ask for your consent in advance.
2. Personal information we may obtain from third parties
In order to provide you with better, better and more personalized services, or to jointly provide you with services, or for the purpose of preventing Internet fraud,our affiliates and partners will share your personal information with us in accordance with legal provisions or agreement with you or with your consent. We will use industry-wide methods and use our best commercial efforts to protect the security of your personal information in accordance with relevant laws and regulations and/or as necessary for this identity authentication function.
3. Processing of changes in the purpose of collecting and using personal information
Please understand that as our business develops, the functions or services we provide may be adjusted and changed. In principle, when new features or services are related to features or services we currently provide, the personal information collected and used will be directly or reasonably related to the original processing purpose. In scenarios that are not directly or reasonably related to the original purpose of processing, when we collect and use your personal information, we will again provide you with additional instructions in the form of page prompts, interactive processes, and agreement confirmations in accordance with the requirements of laws, regulations, and national standards and obtain your consent.
4. Business and Customer Data
Please understand that your business and customer data are different from personal information, and the official website will process it as follows:
4.1 The data you process, store, upload, download, distribute and otherwise process ("process") through the services provided by the official website (excluding third-party services) are all your business and customer data,you own your business and customer data completely. As a neutral technical service provider, we will only process your business and customer data strictly in accordance with your instructions,unless otherwise stipulated by laws and regulations, otherwise agreed in accordance with specific product rules, or based on your request to provide you with technical assistance for troubleshooting or solving technical problems,we will not access your business and customer data or make any unauthorized use or disclosure of your business and customer data.
4.2 You are responsible for the source and content of your business and customer data. We remind you to carefully judge the legality of the data source and content. You should ensure that you use the official website and services to process such data, and that the aforementioned processing activities comply with the requirements of relevant laws and regulations, and there are no violations of laws, regulations, infringements, or violations of contracts with third parties,nor will the data be used for illegal purposes.you are solely responsible for all consequences and responsibilities caused by your business and customer data content and your data processing behavior violating laws, regulations, departmental regulations, national policies, or contractual agreements with third parties.
4.3 Subject to the provisions of the preceding paragraph, for personal information in any data obtained by the official website from users, including business and customer data,you shall fulfill your obligation to notify relevant personal information subjects in advance in accordance with the law, obtain separate consent from relevant personal information subjects, and guarantee:
(1) Provide written explanation and confirmation of the source of personal information and its legality in the manner requested by us;
(2) When we request, provide the scope of authorization and consent for personal information processing, including the purpose of use, and the personal information subject agrees that you use the official website to process his or her personal information;
(3) If the personal information processing activities required for your use of the official website and related services exceed the scope of authorization and consent of such personal information,it shall be your responsibility to obtain the express consent of the subject of the personal information within a reasonable period after providing the personal information or before we process the personal information and to provide us with written evidence when we request it.You understand and agree that you shall not provide us with business and customer data containing personal information unless you meet the above conditions and other obligations required by laws and regulations. If you violate the above obligations, or fail to provide us with reasonably satisfactory proof as required, or we receive reports or complaints from personal information subjects,We have the right to unilaterally decide to refuse to transmit your relevant data (according to actual circumstances, including by restricting relevant service functions, freezing, canceling or withdrawing accounts, etc.), or refuse to process relevant personal information and related data in accordance with your instructions,all liability arising therefrom rests solely with you.
4.4 You understand and agree that you should store your business and customer data yourself according to your own needs. We only provide data storage services in accordance with relevant laws and regulations or specific service rules.(For example, for data storage business, store your business and customer data in the material library, finished product library, template library, and task list in the CMP account). However, you understand and agree that, unless otherwise provided by laws and regulations or agreed in accordance with the service rules, we have no obligation to store your data or information, nor do we assume any responsibility for your data storage work or results.
2. Use of cookies and similar technologies
Cookies and similar technologies are commonly used technologies on the Internet. When you use the official website, we may use related technologies to send one or more cookies or anonymous identifiers to your device to collect and store your account information, search history information, and login status information. Cookies and similar technologies can help you save the steps and processes of repeatedly filling in account information and entering search content. It can also help us improve service efficiency, login and response speed.
You can refuse or manage cookies through your browser settings. However, please note that if you disable cookies, you may not be able to enjoy the best service experience, and the availability of certain functions may be affected. We promise that we will not use your personal information collected through cookies or similar technologies for any other purpose other than those stated in this privacy policy.
3. How we store personal information
1. Where information is stored
For professional service considerations, we may entrust affiliated companies or other legal entities to provide you with one or more specific services on the CMP website:
If you choose to use services in mainland China, we will store the personal information collected and generated during the operation of this website and related services within the territory of the People's Republic of China in accordance with laws and regulations.
2. Storage period
2.1 We will only retain your personal information for the period necessary for the purpose of providing the official website and related services, but you understand and acknowledge that the necessary storage period may be different based on different services and their functional requirements. The criteria we use to determine storage periods include:
(1) The time required to retain personal information to complete the business purpose, including providing services, maintaining corresponding transaction and business records in accordance with legal requirements, ensuring the security of systems and services, responding to possible user inquiries or complaints, problem location, etc.;
(2) A longer retention period agreed to by the user;
(3) Special requirements for retaining personal information due to laws, contracts, etc.
2.2 We will retain relevant information until you withdraw your authorization, delete or cancel your account. After the necessary period has passed, we will delete or anonymize your information, unless otherwise provided by laws and regulations.
4. Partners involved in data use and transfer and disclosure of personal information
1. Partners involved in data use
1.1 Principles
(1) Legality principle: Any data usage activities involved in cooperation with partners must have a legitimate purpose and comply with the legal basis of legality. If the partner's use of information no longer complies with legal principles, it should no longer use your personal information or use it after obtaining the corresponding basis for cooperation.
(2) Principle of legitimacy and minimum necessity: Data use must have legitimate purposes and should be limited to what is necessary to achieve the purpose.
(3) Security and Prudence Principle: We will carefully evaluate the purpose of data use by partners, conduct a comprehensive assessment of the security capabilities of these partners, and require them to comply with legal cooperation agreements. We will conduct strict security monitoring on the software tool development kit (SDK) and application program interface (API) used by partners to obtain information to protect data security.
1.2 Entrusted processing
For scenarios where personal information is entrusted to be processed, we will sign relevant processing agreements with the entrusted partners in accordance with legal provisions and supervise their personal information use activities.
1.3 Joint processing
For scenarios where we jointly process personal information, we will sign relevant agreements with our partners in accordance with legal provisions and stipulate their respective rights and obligations to ensure that we comply with relevant legal provisions and protect data security in the process of using relevant personal information.
1.4 Scope of partners
If specific functions and scenarios involve services provided by our affiliates or third parties, the scope of partners includes our affiliates and third parties.
2. Situations of joint data processing or entrusted data processing of personal information
2.1 Some specific modules or functions in the official website and related service functions are provided by partners. You understand and agree to this,if we cooperate with any partner, we will only provide your personal information to them to the extent necessary to provide services based on the principles of legality, legitimacy and necessity,and we will work hard to ensure that our partners comply with this Privacy Policy and other appropriate confidentiality and security measures we require them to comply with when using your information, and promise not to use your information for any other purpose.
2.2 Some of CMP’s products and services may be provided by third-party service providers or partner products and services (“actual service providers”).
When you purchase related products and services, in order to fulfill the subscription contract to which you are a party, the actual service provider may collect necessary transaction information and personal information (such as account ID, transaction ID information, contact information, transaction amount data,product detailed data, etc.) on its own or by entrusting us to provide you with goods, after-sales service, customer service, marketing or other necessary matters. You understand and know that the actual service provider has the right to contact you for the purpose of performing the above matters.
2.3 In order to provide better services, we may entrust partners to provide services to you, including but not limited to customer service, payment functions, technical services, etc.therefore, we will provide certain information about you to our partners as necessary to provide you with services. For example:
(1) The payment function is provided to you by a third-party payment institution that cooperates with us. Third-party payment institutions will use your name, bank card type and number, validity period, ID number and mobile phone number to provide functions.
(2) In order to handle your complaints, suggestions and other demands in a timely manner, the customer service provider needs to use your account and relevant information about the events involved to understand, handle and respond to related issues in a timely manner.
2.4 Use of data to ensure service security and analyze statistics
(1) Ensure safe use: We attach great importance to account and service security.in order to protect the security of your and other users' accounts and property, and to protect your and our legitimate rights and interests from illegal infringement, we and our partners need to use necessary equipment, accounts and log information.
(2) Analyze service usage: In order to analyze the usage of our services and improve user experience,we and our partners need to use statistical data about your service usage (crashes, crashes) that are difficult to combine with other information to identify you or to be associated with your identity.
3. Transfer of personal information
We will not transfer your personal information to any other third party, except in the following circumstances:
3.1 Based on your written request and meeting the conditions stipulated by the national cyberspace department, we will provide you with a transfer method.
3.2 After obtaining your explicit consent, we will transfer your personal information to other third parties.
3.3 When it comes to the change, merger, acquisition or bankruptcy liquidation of the official website operating entity, if personal information is transferred, we will inform you of the relevant situation in accordance with the law，and require new companies and organizations that hold your information to continue to be bound by this privacy policy or to continue to protect your information in accordance with security standards no less than those required by this privacy policy,otherwise we will require the company or organization to seek authorization from you again. If bankruptcy occurs and there is no data receiver, we will delete your information.
4. Public disclosure of personal information
4.1 In principle, we will not publicly disclose your personal information unless we obtain your explicit consent or comply with the disclosure requirements of national laws and regulations.
(1) We may publicly disclose your personal information with your explicit consent or based on your active choice;
(2) In order to protect the personal and property safety of CMP users or the public from infringement, we may disclose your personal information in accordance with applicable laws or CMP-related agreements and rules.
4.2 Exceptions to obtaining authorized consent
Please understand that in the following circumstances, in accordance with laws, regulations and relevant national standards, we do not need to obtain your authorization and consent in advance to collect and use your personal information:
(1) Relevant to our performance of obligations stipulated in laws and regulations;
(2) Directly related to national security and national defense security;
(3) Directly related to public safety, public health, and major public interests;
(4) Directly related to criminal investigation, prosecution, trial and execution of judgment;
(5) To protect your or others’ life, property and other major legitimate rights and interests but it is difficult to obtain my authorization and consent;
(6) Personal information that you disclose to the public on your own;
(7) Necessary to conclude and perform a contract at the request of the personal information subject;
(8) Your personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
(9) Necessary to maintain the safe and stable operation of software and related services, such as discovering and handling faults in software and related services;
(10) Necessary for legitimate news reporting;
(11) For an academic research institution, it is necessary to conduct statistical or academic research based on public interests, and when providing the results of academic research or description to the outside world, the personal information contained in the results will be de-identified;
(12) Other situations stipulated by laws and regulations.
Please note that if the information cannot identify you individually or in combination with other information, it does not constitute your personal information in the legal sense;
When your information can be used to identify you personally or when we combine data that cannot be linked to any specific personal information with other personal information about you.
During the period of combined use, this information will be treated and protected as your personal information in accordance with this Privacy Policy.
5. How do we protect the security of user information?
1. We attach great importance to the security of user information and will strive to take reasonable security measures (including technical and management aspects) to protect your information,prevent the information you provide from improper use or unauthorized access, public disclosure, use, modification, damage, loss or leakage.
2. We will use reasonable and feasible means such as encryption technology and anonymization that are no less than industry-wide to protect your information, and use security protection mechanisms to reduce the possibility of malicious attacks on your information as much as possible.
3. We will establish a dedicated security department, security management system, and data security process to ensure the security of your information. We adopt a strict data use and access system to ensure that only authorized personnel can access your information, and conduct timely security audits of data and technology in accordance with the company's relevant internal management systems.
4. Although the above reasonable and effective measures have been taken and the standards required by relevant legal regulations have been complied with,however, please understand that due to technical limitations and various possible malicious means, in the Internet industry, even if we do our best to strengthen security measures, it is impossible to always guarantee 100% security of information,we will do our best to ensure the security of the information you provide us. You know and understand that the systems and communication networks you use to access our services may have problems due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of user information, including but not limited to using complex passwords, changing passwords regularly, and not disclosing your account password and other information to others.
5. We will formulate an emergency response plan and immediately activate the emergency plan when a user information security incident occurs, and strive to prevent the impact and consequences of such security incidents from expanding. Once a user information security incident (leakage, loss, etc.) occurs, we will promptly notify you in accordance with the requirements of laws and regulations:The basic situation and possible impact of the security incident, the handling measures we have taken or will take, suggestions for you to prevent and reduce risks on your own, remedial measures for you, etc. We will promptly notify you of event-related information in the form of push notifications, emails, letters or text messages. When it is difficult to inform you one by one, we will issue announcements in a reasonable and effective manner. At the same time, we will also report the handling of user information security incidents in accordance with the requirements of relevant regulatory authorities.
6. We would like to remind you that the user information protection measures provided in this privacy policy only apply to the official website and related services. Once you leave the official website and related services and browse or use other websites, products, services and content resources,we have no ability or obligation to protect any information you submit through software and websites other than the official website and related services, regardless of whether you log in, browse or use the above software or websites based on links or guidance from the official website.
6. Management of personal information
We attach great importance to the management of personal information and protect your rights to access, copy, correct, supplement, delete, withdraw authorization and consent, cancel your account, complain and report your information in accordance with the law to enable you to protect your privacy and information security.
1. Your rights in personal information processing activities
1.1 After you complete the account registration, login and reasonable use of the official website, you can copy and modify the personal information you submitted to the official website and related services through "CMP Platform-Enterprise Settings-Account Management."
1.2 Under normal circumstances, you can review, copy, modify, supplement, access, modify, and delete the personal information you actively provide. For security and identification reasons, you may not be able to correct some of the initial registration information (such as account name, etc.) submitted during registration;If you really need to correct this type of information, please contact us through "Official Website - WeChat Consulting" or "CMP Backstage - WeChat Consulting". We will review the issues involved as soon as possible and have a dedicated person verify your user identity and respond promptly.
1.3 You can make a request to us to delete personal information under the following circumstances:
(1) If the purpose of processing has been achieved, cannot be achieved or is no longer necessary to achieve the purpose of processing;
(2) If our processing of personal information violates laws and regulations;
(3) If we collect and use your personal information without your consent;
(4) If our processing of personal information violates our agreement with you;
(5) If we stop providing products or services, or the retention period of personal information has expired;
(6) if you withdraw your consent;
(7) If we no longer provide services to you;
(8) Other situations stipulated by laws and administrative regulations.
2. Constraint information system automatic decision-making
In some business functions, we may make decisions based only on non-human automated decision-making mechanisms including information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you have the right to contact us for explanation through "Official Website-WeChat Consulting" or "CMP Backstage-WeChat Consulting",we will also provide you with modifications depending on the actual situation, such as manually reviewing the independent decision-making results or terminating the use of the automatic decision-making mechanism to make relevant decisions.
6. Complaints and reports
You can make complaints or reports according to our publicized system. If you think your information rights may have been infringed, or find clues that your information rights have been infringed, you can contact us by submitting relevant information and rights certification materials through "Official Website - WeChat Consulting" or "CMP Backstage - WeChat Consulting". We will promptly feedback your complaints and reports after verification.
7. Respond to your above request
For security reasons, you may be required to provide a written request and otherwise prove your identity. We may first ask you to verify your identity in accordance with the "Wandianduoduo Terms of Service" and related rules before processing your request. If you are not satisfied with the response, you can also file a complaint through the above channels.
In principle, we do not charge fees for your reasonable requests. However, for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the specific circumstances. Requests that are unnecessarily repetitive, require excessive technical means (for example, require the development of new systems or fundamentally change existing practices), pose a risk to the legitimate rights and interests of others, or are impractical (for example, involving information stored on backup tapes) , we may reject it.
You understand and acknowledge that we will not be able to respond to your request under the following circumstances:
(1) Related to our performance of obligations stipulated in laws and regulations
(2) Directly related to national security and national defense security;
(3) Directly related to public safety, public health, and major public interests;
(4) Directly related to criminal investigation, prosecution, trial and execution of judgments;
(5) We have sufficient evidence that the personal information subject has subjective malice or abused his rights;
(6) To protect the life, property and other major legitimate rights and interests of the personal information subject or other individuals but it is difficult to obtain the consent of the individual;
(7) Responding to the request of the personal information subject will cause serious damage to the legitimate rights and interests of the personal information subject or other individuals or organizations;
(8) Involving trade secrets.
8. Notify you of cessation of operations
If we cease operations, we will stop collecting your personal information and notify you of the cessation of operations in a commercially feasible form such as one-to-one delivery or announcements,and delete or anonymize your personal information held by us.
7. Privacy Policy Revisions and Notices
1. In order to provide you with better services, the official website and related services will be updated and changed from time to time. We will revise this Privacy Policy from time to time. Such revisions form part of this Privacy Policy and have the same effect as this Privacy Policy. However, we will not reduce your rights under the currently effective Privacy Policy without your explicit consent.
2. After this Privacy Policy is updated, we will publish the updated version on the official website, and remind you of the updated content through official website announcements or other appropriate means before the updated terms take effect, so that you can keep abreast of the latest version of this Privacy Policy. If you continue to use the official website and related services, you will be deemed to agree to accept the entire contents of this revised Privacy Policy.
3. For major changes, we will also provide more prominent notices (including but not limited to emails, text messages, system messages or special reminders on the browsing page) to explain to you the specific changes to this privacy policy.
4. Major changes referred to in this privacy policy include but are not limited to:
(1) Significant changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;
(2) We undergo significant changes in ownership structure, organizational structure, etc. Such as all changes caused by business adjustments, bankruptcy and mergers and acquisitions, etc.;
(3) The main recipients of personal information transmission, transfer or public disclosure change;
(4) There are significant changes in your rights to participate in the processing of personal information and how you exercise them;
(5) When our contact information and complaint channels change.
9. Scope of application
1. This privacy policy applies to the products, services, and solutions provided by the official website, as well as other products, services, or solutions that the company may subsequently launch from time to time and are included in the service scope.
2. This Privacy Policy does not apply to products or services provided to you through the official website by third parties that have separate privacy policies and are not incorporated into this Privacy Policy ("Third Party Services"). Your use of these third-party services (including any information containing personal information you provide to these third parties) will be governed by the terms of service and privacy policies of these third parties (not this Privacy Policy) and make relevant requests, complaints and reports through the personal information subject request and complaint mechanism established by it. Please read the third party's terms carefully for specific provisions. Please protect your personal information properly and provide it to third parties only when necessary.
3. It should be noted that as a user of the official website, if you use the technical services of the official website to provide services to your users,because your business and customer data belong to you, you should agree on a privacy policy with your users. This privacy policy does not serve as a replacement for the privacy policy between you and your users.
4. If the products or services you actually order are beyond the scope of this privacy policy, the purpose and method of collecting and processing this information will be informed on the product or service description interface and consent will be obtained.
10. How to contact us
If you have any questions, comments or suggestions about the content of this privacy policy, you can contact us by logging into our "Official Website - WeChat Consultation" or "CMP Backstage - WeChat Consultation". Under normal circumstances, we will respond within 3 days ("Response Period"), but you understand and agree that depending on the complexity of your request, the aforementioned response period may be extended to 30 days,however, we will inform you in writing of the reason for the delay before the expiration of the response period.