Privacy Policy

Last Updated: December 15, 2024

Beijing Jinle Huizhi Human Resources Co., Ltd ("we," "our," or "us") operates the Jinle Huizhi HR Management mobile application (the "App") and is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App, website, and related services.

Please read this Privacy Policy carefully. By accessing or using the App, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the App.

1. Information We Collect

1.1 Information You Provide

We may collect information you voluntarily provide when you:

• Create an account or profile
• Submit or upload employee data
• Process payroll information
• Use attendance and time tracking features
• Contact our support team
• Subscribe to newsletters or notifications
• Participate in surveys or promotions

This information may include: name, email address, phone number, company name, job title, employee records, salary information, attendance data, and other HR-related information you choose to provide.

1.2 Information Collected Automatically

When you use our App, we may automatically collect certain information, including:

• Device information (device type, operating system, unique device identifiers)
• App usage data (features accessed, time spent, interactions)
• Log information (crash reports, performance data)
• Location information (with your consent)
• IP address and browser type
• Advertising identifiers (for ad personalization)

1.3 Information from Third Parties

We may receive information from:

• Business partners and service providers
• Advertising and analytics platforms
• Social media platforms (if you choose to link accounts)
• Public databases and data providers

2. How We Use Your Information

We use the information we collect for the following purposes:

• Providing and maintaining our HR management services
• Processing payroll and compensation management
• Managing employee records and attendance
• Generating reports and analytics
• Improving our App and user experience
• Delivering personalized advertising (with your consent)
• Communicating with you about services and updates
• Providing customer support and troubleshooting
• Complying with legal obligations
• Detecting and preventing fraud and abuse
• Research and development purposes

3. Information Sharing and Disclosure

We may share your information with:

• Service Providers: Companies that provide services on our behalf, including cloud hosting, analytics, payment processing, and customer support
• Advertising Partners: Third-party ad networks and advertising platforms (see Section 4 for details)
• Business Transfers: In connection with mergers, acquisitions, or sale of assets
• Legal Requirements: When required by law, court order, or governmental authority
• Protection of Rights: To protect our rights, privacy, safety, or property
• With Your Consent: In other ways with your explicit consent

4. Advertising and Third-Party Ad Networks

4.1 Overview

Our App includes advertising from various third-party ad networks and platforms. These advertising partners collect information about your use of our App to provide personalized and non-personalized advertisements. This section explains how we work with advertising platforms and your choices regarding advertising.

4.2 Integrated Advertising Platforms

We have integrated the following advertising and monetization platforms into our App:

4.3 Data Collection by Advertising Partners

Each advertising partner may collect and process data according to their own privacy policies. This data may include:

• Device identifiers (GAID, IDFA)
• Device type and specifications
• Operating system and version
• App usage and behavior data
• Location data (general and precise, where permitted)
• Advertising engagement data
• Cross-app usage patterns
• Demographic information (age, gender)

4.4 How We Use Advertising Partners

We use advertising partners to:

• Serve advertisements within our App
• Measure the effectiveness of advertisements
• Provide personalized advertising experiences
• Support free or low-cost access to our services
• Generate revenue to maintain and improve our services

5. Advertising Formats and Implementation

5.1 Splash Ads (App Open Ads)

Our App may display splash ads when it launches or returns from background. These full-screen advertisements appear while the App initializes. Splash ads help offset development costs and support free access to our services.

Implementation Details:

• Displayed for a limited duration (typically 5-15 seconds)
• May include close button after initial display period
• Can be skippable or non-skippable depending on ad format
• May be personalized based on your advertising ID
• Frequency limited to prevent excessive interruption

5.2 Interstitial Ads

Interstitial ads are full-screen advertisements that appear at natural transition points in the App, such as between screens or during loading periods.

Implementation Details:

• Displayed at strategic points (e.g., after completing an action)
• May be image, video, or rich media format
• Include close functionality after display duration
• May be personalized based on your interests and behavior
• Frequency controlled to maintain user experience

5.3 Rewarded Video Ads

Rewarded video ads allow you to voluntarily watch a video advertisement in exchange for in-app rewards, such as premium features, virtual currency, or extended functionality.

Implementation Details:

• Optional viewing - you choose whether to watch
• Full video completion typically required for reward
• May include interactive elements
• Rewards clearly disclosed before viewing
• No penalty for choosing not to watch
• May be personalized based on viewing history

5.4 Banner Ads

Banner ads are rectangular advertisements that appear at the top or bottom of the screen while you use the App.

Implementation Details:

• Consistent placement during App usage
• Various sizes (standard, medium, large)
• Auto-refresh at regular intervals
• May be personalized based on your interests
• Minimal impact on main content visibility

5.5 Native Ads

Native ads are advertisements designed to match the visual style and format of the App's content.

Implementation Details:

• Designed to blend with surrounding content
• Clearly labeled as advertisements
• May include sponsored content labels
• Relevant to App content and user interests

5.6 Ad Personalization and Your Choices

You can control ad personalization through the following mechanisms:

• Device Settings: Use "Opt Out of Ads Personalization" (Android) or "Limit Ad Tracking" (iOS) in your device settings
• Within App: Settings menu allows you to toggle personalized advertising
• Industry Tools: Visit industry opt-out platforms like youronlinechoices.com, aboutads.info, or networkadvertising.org
• Specific Partners: Each advertising platform offers individual opt-out options

6. Your Rights and Choices

6.1 General Rights

You have the right to:

• Access your personal information
• Correct inaccurate or incomplete data
• Delete your personal information
• Restrict or object to processing
• Data portability
• Withdraw consent at any time
• Lodge a complaint with a supervisory authority

6.2 Communication Preferences

You can control communications by:

• Managing notification settings in the App
• Unsubscribing from marketing emails
• Contacting us to update preferences

6.3 Advertising Choices

To opt out of personalized advertising:

• iOS: Settings > Privacy > Apple Advertising > Opt Out
• Android: Settings > Privacy > Ads > Opt Out of Ads Personalization
• EU Users: Consent management platform during App launch

7. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

• Encryption of data in transit and at rest
• Access controls and authentication measures
• Regular security assessments and audits
• Employee training on data protection
• Incident response procedures
• Secure cloud infrastructure
• Compliance with ISO 27001 standards

8. International Data Transfers

Your information may be transferred to and processed in countries outside your residence, including but not limited to:

• China (primary data center location)
• United States (AWS, Google Cloud)
• European Union (for EU users)
• Singapore (regional operations)

When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules
• Adequacy decisions
• Explicit consent where required

9. GDPR Compliance (European Union)

9.1 Legal Basis for Processing

For EU users, we process personal data based on:

• Contract: Processing necessary to provide services
• Legitimate Interests: Improving services, fraud prevention
• Consent: Marketing, advertising personalization
• Legal Obligation: Compliance with laws

9.2 Data Subject Rights under GDPR

EU residents have additional rights:

• Right to be informed (this Privacy Policy)
• Right of access (Article 15)
• Right to rectification (Article 16)
• Right to erasure ("Right to be Forgotten") (Article 17)
• Right to restrict processing (Article 18)
• Right to data portability (Article 20)
• Right to object (Article 21)
• Rights related to automated decision-making (Article 22)

9.3 Supervisory Authority

You have the right to lodge a complaint with your local data protection authority. For EU users, contact details for supervisory authorities are available at: EDPB Members

9.4 Representative in the EU

We have appointed a representative in the EU to address GDPR-related matters. Contact our EU representative at the details provided in the Contact section.

9.5 Special Categories of Data

We do not intentionally collect special categories of personal data (racial or ethnic origin, political opinions, religious beliefs, biometric data, health data) unless explicitly required for HR services and with appropriate safeguards.

10. CCPA Compliance (California)

10.1 California Consumer Privacy Rights

California residents have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• Right to Know: Request disclosure of personal information collected, used, disclosed, or sold
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt out of the sale of personal information
• Right to Non-Discrimination: Equal service regardless of exercising privacy rights
• Right to Correct: Request correction of inaccurate personal information
• Right to Limit Use: Limit use of sensitive personal information

10.2 Categories of Information Collected

We collect the following categories of information:

• Identifiers (name, email, device ID, IP address)
• Commercial information (transaction history, service usage)
• Internet activity (browsing, app usage)
• Location data (general and precise)
• Employment-related information (for HR services)
• Inferences (preferences, characteristics)

10.3 "Do Not Sell or Share My Personal Information"

California residents may opt out of the sale or sharing of their personal information. To exercise this right:

• Email us at privacy@jinlehuizhi.com
• Use the in-App privacy settings
• Visit our Web Form: [Privacy Request Form]

10.4 Financial Incentives

We may offer financial incentives for data collection. Details of any current programs will be provided at the time of enrollment.

10.5 Shine the Light Act

California's "Shine the Light" law (Civil Code Section 1798.83) permits California residents to request information about disclosure of personal information to third parties for direct marketing purposes.

11. COPPA Compliance (Children's Privacy)

11.1 Age Restriction

Our App and services are not directed to children under 13 years of age, and we do not knowingly collect personal information from children under 13. If you are under 13, please do not use our App or provide any personal information.

11.2 Parental Rights

Parents and guardians of children under 13 have the right to:

• Review personal information collected from their child
• Request deletion of their child's information
• Refuse further collection or use of their child's information
• Consent to collection without consenting to third-party disclosure

11.3 Verification

Before responding to parental requests, we may verify the requester's identity and relationship to the child through reasonable methods.

11.4 School-Age Children

If our services are used in educational settings with school-age children, we comply with applicable state and federal laws regarding student privacy, including FERPA where applicable.

11.5 Advertising to Children

We do not engage in behavioral advertising targeting children under 13. Our ad partners are instructed not to serve personalized ads based on information from children under 13.

12. Data Retention

We retain your information for the following periods:

• Account Data: Duration of account plus 3 years after closure
• HR Records: As required by applicable employment laws
• Transaction Data: 7 years for financial and tax purposes
• Usage Data: 2 years for analytics and improvement
• Marketing Data: Until consent withdrawal plus 1 year
• Legal Compliance: As required by applicable laws

After retention periods, data is securely deleted or anonymized.

13. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements. We will:

• Post the updated policy with a new "Last Updated" date
• Notify you through the App or email for significant changes
• Obtain consent for material changes where required
• Maintain previous versions for your review

14. Contact Us

For questions about this Privacy Policy, data subject requests, or to exercise your rights, contact us:

Beijing Jinle Huizhi Human Resources Co., Ltd
Room 101, 20 meters north of National Highway 101
Tongjunzhuang Village, Shilibao Town
Miyun District, Beijing, 100000
China

Email:
General: support@jinlehuizhi.com
Privacy Inquiries: privacy@jinlehuizhi.com
Business Development: moguochun@jinlehuizhi.com

EU Representative:
[EU Representative Contact Details]

California Privacy Rights:
To submit verified requests: privacy@jinlehuizhi.com
Response time: Within 45 days

By using our App, you consent to the collection and use of information in accordance with this Privacy Policy. Thank you for trusting Jinle Huizhi with your HR management needs.