Privacy Policy

Last Updated: November 2024

Introduction

CHENGDU XIANGJIANTIAN TECHNOLOGY CO., LTD. ("CTH Network", "we", "us", or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains in detail how we collect, use, disclose, and safeguard your information when you visit our website (www.cthnetwork.top) or use our services.

By accessing our website or using our services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with our policies and practices, please do not use our services.

This policy complies with the Personal Information Protection Law of the People's Republic of China (PIPL) and other applicable data protection regulations.

Scope of This Policy

This Privacy Policy applies to:

  • Information collected through our website and online services
  • Information collected through our professional service engagements
  • Information collected through email, telephone, and other communications
  • Information collected from third-party sources with your consent

Information We Collect

1. Personal Information You Provide

We collect personal information that you voluntarily provide to us, including but not limited to:

  • Contact Information: Name, email address, phone number, postal address, company name, job title
  • Account Information: Username, password (encrypted), security questions and answers
  • Professional Information: Business requirements, project specifications, technical preferences
  • Communication Records: Messages sent through contact forms, emails, chat transcripts
  • Payment Information: Billing address, payment method details (processed securely by third-party payment processors)
  • Feedback and Surveys: Your responses to surveys, reviews, and feedback forms

2. Automatically Collected Information

When you visit our website, we automatically collect certain information:

  • Device Information: IP address, browser type and version, operating system, device identifiers
  • Usage Data: Pages viewed, time spent on pages, click-through rates, date and time of visits
  • Location Data: General geographic location based on IP address
  • Referral Data: The website or source that referred you to our site
  • Technical Information: Screen resolution, language preferences, time zone settings

3. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to collect information about your browsing activities:

  • Essential Cookies: Required for website functionality and cannot be disabled
  • Preference Cookies: Remember your settings and choices (e.g., language preference)
  • Analytics Cookies: Help us understand how visitors interact with our website
  • Marketing Cookies: Track your online activity to deliver relevant advertisements

You can control cookies through your browser settings. However, disabling cookies may limit your access to certain features of our website.

4. Information from Third-Party Sources

We may receive information about you from:

  • Business partners and affiliates
  • Public databases and social media platforms
  • Marketing and analytics providers
  • Professional references and background check services (with your consent)

How We Use Your Information

We process your personal information for the following purposes, based on lawful grounds:

Service Provision and Contract Performance

  • Deliver and manage our professional services
  • Process transactions and send transaction confirmations
  • Provide customer support and respond to inquiries
  • Manage user accounts and authentication
  • Execute service agreements and contracts

Business Operations and Improvement

  • Analyze usage patterns to improve website functionality
  • Conduct research and development for new services
  • Perform data analysis and quality assurance
  • Monitor and enhance security measures
  • Detect and prevent fraud, abuse, and illegal activities

Communication and Marketing

  • Send service updates, technical notices, and security alerts
  • Provide information about new services and features
  • Send promotional materials (with your consent)
  • Conduct customer satisfaction surveys
  • Respond to your comments and questions

Legal and Compliance

  • Comply with applicable laws and regulations
  • Respond to legal processes and government requests
  • Enforce our terms of service and policies
  • Protect our rights, property, and safety
  • Maintain records for audit and compliance purposes

Information Disclosure

We may share your information in the following circumstances:

  • With your consent or at your direction
  • With service providers who assist in our operations
  • To comply with legal requirements or court orders
  • To protect our rights, property, or safety

Legal Basis for Processing

We process your personal information based on the following legal grounds:

  • Consent: You have given clear consent for us to process your personal data for specific purposes
  • Contract Performance: Processing is necessary to fulfill our contractual obligations to you
  • Legal Obligation: Processing is necessary to comply with legal or regulatory requirements
  • Legitimate Interests: Processing is necessary for our legitimate business interests, provided your rights do not override these interests

Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods vary depending on the type of information and purpose:

  • Account Information: Retained for the duration of your account plus 2 years after closure
  • Transaction Records: Retained for 7 years in accordance with financial regulations
  • Communication Records: Retained for 3 years or as required by contract
  • Marketing Data: Retained until you withdraw consent or 2 years of inactivity
  • Website Analytics: Aggregated data retained for 2 years

After the retention period expires, we will securely delete or anonymize your personal information.

Data Security

We implement comprehensive technical and organizational measures to protect your personal information:

Technical Security Measures

  • Encryption: All sensitive data is encrypted in transit (TLS/SSL) and at rest
  • Access Controls: Multi-factor authentication and role-based access controls
  • Firewalls: Advanced firewall systems to prevent unauthorized access
  • Intrusion Detection: Real-time monitoring and intrusion detection systems
  • Regular Updates: Timely security patches and software updates
  • Data Backup: Regular encrypted backups stored in secure locations

Organizational Security Measures

  • Employee training on data protection and security best practices
  • Confidentiality agreements with all staff and contractors
  • Regular security audits and vulnerability assessments
  • Incident response plan and data breach procedures
  • Physical security controls for server facilities
  • Limited access to personal data on a need-to-know basis

Important Notice: While we implement industry-standard security measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but will notify you promptly in the event of a data breach as required by law.

Third-Party Services and Links

Our website may contain links to third-party websites or integrate third-party services. We are not responsible for the privacy practices of these third parties.

Third-Party Service Providers

We may share your information with trusted third-party service providers who assist us in:

  • Cloud hosting and data storage
  • Payment processing
  • Email delivery and communication services
  • Analytics and performance monitoring
  • Customer relationship management
  • Marketing and advertising platforms

These service providers are contractually obligated to protect your information and use it only for the specified purposes.

External Links

Links to external websites are provided for your convenience. We do not control these websites and recommend reviewing their privacy policies before providing any personal information.

International Data Transfers

Your information may be transferred to and processed in countries other than China. When we transfer data internationally, we ensure appropriate safeguards are in place:

  • Standard contractual clauses approved by relevant authorities
  • Data processing agreements with international service providers
  • Compliance with cross-border data transfer regulations
  • Adequate protection measures equivalent to those required in China

By using our services, you consent to the transfer of your information to countries that may have different data protection laws than China.

Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children.

If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete such information promptly. If you believe we have collected information from a child, please contact us immediately.

Your Privacy Rights

Under applicable data protection laws, including the Personal Information Protection Law of China (PIPL), you have the following rights:

Right to Access

You have the right to request access to your personal information we hold. We will provide you with a copy of your data in a commonly used electronic format.

Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. We will update your information promptly upon verification.

Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal information when:

  • The information is no longer necessary for the purposes it was collected
  • You withdraw consent and there is no other legal basis for processing
  • You object to processing and there are no overriding legitimate grounds
  • The information has been unlawfully processed
  • Deletion is required by legal obligation

Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and transfer it to another service provider.

Right to Object

You have the right to object to the processing of your personal information for direct marketing purposes or when based on legitimate interests.

Right to Restrict Processing

You have the right to request restriction of processing your personal information in certain circumstances, such as when you contest the accuracy of the data.

Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing before withdrawal.

Right to Lodge a Complaint

You have the right to lodge a complaint with the relevant data protection authority if you believe your rights have been violated.

How to Exercise Your Rights

To exercise any of these rights, please contact us using the information provided below. We will respond to your request within 15 business days or as required by applicable law. We may ask you to verify your identity before processing your request.

Automated Decision-Making

We may use automated decision-making processes for certain purposes, such as:

  • Fraud detection and prevention
  • Service personalization and recommendations
  • Website optimization and user experience enhancement

You have the right to request human intervention in automated decisions that significantly affect you. Contact us if you wish to discuss any automated decision that impacts you.

Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

  • Notify the relevant supervisory authority within 72 hours of becoming aware of the breach
  • Inform affected individuals without undue delay if the breach poses a high risk
  • Provide details about the nature of the breach, likely consequences, and measures taken or proposed
  • Maintain a record of all data breaches for regulatory compliance

Changes to This Privacy Policy

We reserve the right to update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

  • Update the "Last Updated" date at the top of this policy
  • Notify you by email if you have an account with us
  • Post a prominent notice on our website
  • Obtain your consent if required by applicable law

We encourage you to review this Privacy Policy periodically. Your continued use of our services after changes are posted constitutes acceptance of the updated policy.

Do Not Track Signals

Some web browsers transmit "do-not-track" (DNT) signals. Our website does not currently respond to DNT signals. We continue to monitor developments in DNT technology and may implement support in the future.

California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

  • Right to know what personal information we collect, use, and disclose
  • Right to request deletion of your personal information
  • Right to opt-out of the sale of personal information (we do not sell personal information)
  • Right to non-discrimination for exercising your privacy rights

To exercise these rights, please contact us at the information provided below.

European Union Users (GDPR)

If you are located in the European Union, you have rights under the General Data Protection Regulation (GDPR), including those outlined in the "Your Privacy Rights" section above. Our legal basis for processing your data includes consent, contract performance, legal obligation, and legitimate interests.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:

CHENGDU XIANGJIANTIAN TECHNOLOGY CO., LTD.
Data Protection Officer
Email: support@cthnetwork.top
Phone: 13363021102
Address: Room 504, Attached No. 464, Building 1, Floor 5, No. 1 Shawan Road, Jinniu District, Chengdu, Sichuan Province, China

We will respond to your inquiry within 15 business days. If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection authority.

Acknowledgment and Consent

By using our website and services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

This Privacy Policy is effective as of the date indicated at the top of this page and supersedes all previous versions.