To effectively ensure the secure and complaint processing of your Personal Data in the course of your access to DragonCor’s website (https://www.dragoncor.cn) and other business channels, Shanghai DragonCor Commercial Management Co., Ltd. (“We”) prepares DragonCor Privacy Policy (this “Policy”), pursuant to current laws and regulations, to detail our policies and measures regarding our collection, use, management and protection of Personal Data.

We endeavor to present this Policy in plain, simple, and concise language, and to draw your attention, by using bold text, to those provisions of this Policy that are closely relevant to your rights and interests. Therefore, before you use our services, please read carefully and fully understand this Policy, and consent to this Policy before using the services.

This Policy does not apply to information collected by third party products or services (including any third party websites) integrated into our website. Your use of these third-party services will be subject to the terms of service and privacy policies of these third parties (not this Policy). Please read the relevant terms and conditions of the third parties carefully.

This Policy informs you of the following information:

1. How do we collect and use your Personal Data
2. Cookies and similar technologies
3. How do we share, transfer, disclose and entrust the processing of your Personal Data
4. How do we protect your Personal Data
5. How do we store your Personal Data
6. Your rights
7. How do we process minor’s Personal Data
8. How do we update this Policy
9. How to contact us

1. How do we collect and use your Personal Data

When you approach us for business cooperation or inquiries through the contact information shown on the DragonCor Website or otherwise (e.g., “DragonCor” mini-program), we will collect your contact information (e.g., name, phone number and email address) and other information you may volunteer (e.g., name of your organization, contact address, specific inquiry, etc.), in order to contact you about business cooperation or to respond to your inquiry.

We may also use the above contact information to send you or your organization information about products and services that may interest you, or to solicit feedback or suggestions from you or your organization. If you or your organization refuse to receive information about our products and services or provide feedback, you may decline at any time.

When you follow DragonCor’s WeChat public accounts (“DragonCor 龙地”), we will collect certain of your WeChat account information (including your nickname, avatar, gender, region and other public information) and record your interaction with us.

Unless you refuse our processing by deleting your Personal Data, withdraw your consent or any other possible method, we will use your Personal Data, where it is permitted by relevant laws and regulations, for the purposes described in this Policy or purposes that are directly or reasonably compatible with the aforesaid.

Pursuant to relevant laws and regulations, we may process (including collect, use, entrust the processing of, share, transfer and disclose) your Personal Data without your consent in the following circumstances:

  • Where the processing is necessary for the conclusion or performance of a contract with you;
  • Where the processing is necessary for the performance of our statutory obligations;
  • Where the processing is necessary to respond to public health emergencies, or to protect the life, health and property safety of natural persons in an emergency;
  • Where your Personal Data is processed within a reasonable scope for the purposes of news reporting, public opinion supervision and other acts conducted in public interests;
  • Where Personal Data voluntarily disclosed by you or other personal data that has been lawfully disclosed are processed within a reasonable scope in accordance with relevant rules;
  • Where there are any other circumstances stipulated by laws or administrative regulations.

2. Cookies and similar technologies

When you visit our website or use other associated services, we may use Cookies to automatically collect certain technical information from your device, mainly including IP address, browsing history, browser settings, etc.

Such information allows us to better understand the visitors to our website, such as where they come from and what content attracts them to the website. We use this information for internal analysis and troubleshooting, and to improve the quality of website’s content. We also need to keep appropriate logs to record the status of the website in order to comply with relevant laws and regulations.

Please note that when you disable cookies by changing browser setting or use the “anonymous browsing” feature of browser, cookies will no longer collect your information.

3. How do we share, transfer, disclose and entrust the processing of your Personal Data

In order to improve the efficiency of information processing, we may engage third parties to process your Personal Data on our behalf. We will enter into data processing agreements with such third parties and require them to process Personal Data in accordance with the agreement, this Policy, and relevant laws and regulations related to Personal Data protection.

We may share your Personal Data with third parties in the following circumstances:

  • In the event of any change, merger, acquisition, reorganization, or liquidation involving the transfer of Personal Data, we will ask the new company or organization holding your Personal Data to continue to process your Personal Data in accordance with this Policy. If the new company or organization holding your Personal Data needs to use your Personal Data for purposes not stated in this Policy, the new company or organization will obtain your consent, unless otherwise provided by the relevant laws and regulations.
  • To relevant competent law enforcement body, regulatory, government agency, court or other third party where we believe that such disclosure is to (1) comply with relevant laws or regulations; (2) exercise, establish or defend our legal rights, or (3) protect your vital interests or those of any other person.

Prior to sharing, we may separately inform you of the names of the third parties, their contact information, the purpose and manner of processing and the types of Personal Data, and obtain your consent (or complete any formality as required by other lawful basis) where required by relevant laws and regulations.

Unless consented by you in accordance with the law, or otherwise obliged by relevant laws and regulations, we will not share or disclose your Personal Data in any scenarios other than those specified in this Policy.

4. How do we protect your Personal Data

We use appropriate technical and organizational measures to protect your Personal Data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. Please be aware and understand that we cannot ensure an absolute secure network. If you find that your Personal Data are breached, please contact us using the contact details provided in “How to contact us” immediately so that we can take corresponding measures.

In the event of any accident, force majeure event or other circumstances leading to the breach of your Personal Data, we will make every effort to control the situation and promptly inform you of the cause, the security measures we have taken and you can take and other relevant information. In the event of a security incident related to Personal Data, we will report to the competent authorities in accordance with the requirements of relevant laws and regulations, promptly investigate the problem, and take emergency measures.

5. How do we store your Personal Data

We will store in the PRC your Personal Data collected within the PRC. We will not transfer your Personal Data outside the PRC.

We will store your Personal Data only to the extent as necessary to the proper business needs of our company, except as provided otherwise by relevant laws or regulations. When the time limit for retention expires, we will delete or anonymize your Personal Data.

6. Your rights

If you want to access, correct and delete your Personal Data, and exercise other data subject’s legal rights under relevant laws and regulations (e.g. to withdraw the consent we obtained from you to collect and process your Personal Data, or to request us to transfer your Personal Data to a designated third party, etc.), you can contact us using the contact details provided in “How to contact us”.

We will respond to all requests we receive to exercise the data subject’s rights in accordance with relevant laws and regulations within the required time limit. To the extent as permitted by relevant laws and regulations, we may not be able to respond to your request to exercise your rights in the certain circumstances. For instance, if your request is contrary to our obligations under relevant laws and regulations, or may infringe our trade secrets, we may refuse to respond to your request. Besides, if we have sufficient evidence of your subjective malice or abuse of rights, or response to your request would infringe other individuals’ significant legitimate rights and interests, we may also decline your request. Under such circumstances, we would simultaneously provide you with our reason of refusal in the response.

If we terminate our services or operations, we will notify you at least thirty (30) days in advance and will delete or anonymize your Personal Data after termination of services or operations.

7. How do we process minors’ Personal Data

Please note that we do not intentionally collect and process Personal Data of minors under 18 years old. For the Personal Data of minors we collect upon the consent of parents or guardians, we will only use or disclose such data to the extent where permitted by laws, explicitly authorized by parents or guardians, or necessary for the protection of minors.

If you are the parent or guardian of a minor under the age of 18 and have questions on how we process minors’ Personal Data, please contact us using the contact details provided in “How to contact us”.

8. How do we update this Policy

We may update this Policy from time to time in response to changing legal, technical or business developments. When we update our Policy, we will take appropriate measures to inform you, depending on the significance of the changes we make.

You can see when this Policy was last updated by checking the “last updated” date displayed at the top of this Policy. If you continue to contact us through the contact information shown on the site or other channels, you are deemed to have accepted the updated Policy.

9. How to contact us

If you have any questions or concerns about this Policy or any other associated matters, please contact us via 021-61911600. We will review your question without delay and make timely reply.