Xing Zhi

This Privacy Policy applies to XingZhi, as well as any services accessible on the XingZhi platform that state that this Privacy Policy applies to the use of such service (for example, when users make payment for in-app purchases). Those XingZhi services may have further privacy-related terms that you must agree to if you use those services. Any capitalised terms used in this Privacy Policy have the same meaning as the equivalent defined terms in the XingZhi Terms of Service, unless they are defined otherwise in this Privacy Policy.

Please note that this Privacy Policy does not apply to Information that you choose to disclose or submit to:

a) services other than XingZhi (such as other products or services supplied or operated by us or our affiliates or partners), that do not expressly state that this Privacy Policy applies;
b) any third party services (including any third party websites) that you may access through XingZhi;
or
If you are using XingZhi on behalf of a company, partnership, association, government or other organisation, you agree to notify your organisation’s relevant individual owners, shareholders, directors, officers, managers, employees and other relevant individuals whose Personal Information we collect or you provide to us from time to time of the collection of their Personal Information, and you agree to obtain their consent to the processing of their Personal Information in accordance with this Privacy Policy as required by applicable laws and regulations. If you would like to request your personal information be removed from our database, please contact us at xingzhicustomerservice@gmail.com.

WHAT INFORMATION DO WE COLLECT AND HOW WE COLLECT IT?

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How do we use your information” below.

We process different categories of information and data in providing XingZhi. These are set out below:

when you access XingZhi, as we derive location information from your IP address, device, or internet service to prevent multiple or fraudulent log-ins to your account.
device attributes, such as your mobile carrier-related information and your IP address;
“Log Data”, records the time and date when you log into XingZhi.
“Non-Personal Information” is any information that is not reasonably practicable to directly or indirectly identify you.
“Personal Information” is any information, or combination of information, that relates to you, that can be used (directly or indirectly) to identify you. We set out examples of Personal Information (and how we collect such Personal Information) in “How do we use your information” below.
“Additional Information” is information about you or relating to you that is voluntarily recorded by you on XingZhi. Additional Information includes GAN Calendar Notes and Appreciation Diary.

References to “Information” in this Privacy Policy mean both Personal Information and Non-Personal Information.

HOW DO WE USE YOUR INFORMATION?

This section provides more detail on the types of personal information we collect from you, and why.

Information	Purpose of Processing
Registration Data and Log-in Data. Your full name, display name, email, mobile phone number, password, gender, date of birth and country of residence	– to set up an account on XingZhi. – log in to an account on XingZhi. – to notify you about changes to XingZhi. – to provide you with user support. – to enforce our terms, conditions, and policies. – to communicate with you.to provide personalised help and instructions.to develop new and improve existing services. – to protect any rights, property or safety of ours or other users of XingZhi.for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, account management, and survey purposes.
Additional Account Security. Email address verification, Google account, WeChat account	– to verify your identity. – account security.
Log Data. See definition above.	– to better understand how you access and use XingZhi. – to administer XingZhi. – for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, and account management.
Bank / Debit / Credit card information	– to facilitate your purchases within XingZhi – bank / debit / credit card information is collected and the information verified via a third-party payment processing service. This information is not permanently stored on XingZhi servers and is immediately disposed after a verification request has been performed by the third-party payment processing service.
Customer Support Information. Any information that you provide to our customer support team.	– to investigate your support issue.
Device Data. Media stored on your device.	– to facilitate the displaying of such media on XingZhi
Pseudonymised and Aggregated Data. We pseudonymise and aggregate certain Personal Information to improve our services.	– Analysis of what features or actions are taken within the app in order to improve app experience – Fraud detection and account safety analysis – User demographic analysis on items such as region, nationality.

WHO DO WE SHARE YOUR DATA WITH?

We will not transfer your Personal Information to any other third parties except as specified below, or in circumstances where you consent to such transfer.

Only where necessary will we share your information with selected recipients who have a legal basis and valid jurisdiction to request such data. These categories of recipients include:

government, public, regulatory, judicial and law enforcement bodies or authorities: there are circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, such as a court order, subpoena or other legal process, to enforce our terms, address issues relating to security or fraud, or protect our users and provided the requesting entity has valid jurisdiction to obtain your personal information;
related group companies: we share your Personal Information within our group of companies (and all related group companies may only use your personal information in accordance with this policy), including XINGZHI DEVELOPMENT CENTRE SDN. BHD. (located in the Malaysia), International Association of Xing Zhi Appreciation (located in Hong Kong), Harvest Mark Enterprises Limited (located in Hong Kong) and International Xing Zhi Volunteer Team (located in Malaysia) for the purpose of:

providing XingZhi to you, assisting us in carrying out the purposes set out under the “How do we use Your Information” section above, and carrying out our obligations and enforcing our rights under the XingZhi Terms of Service or this Privacy Policy; and
in the event of an internal restructuring of our or our affiliates businesses, or the sale of XingZhi or any of its assets to a third party, the entity that consequently operates XingZhi may be a different entity to us and we will transfer your information accordingly so that your service can continue;
payment service providers: to facilitate and ensure that all purchases within XingZhi are verified to your identity. Any third party (selected by us) with whom we share user data is required to provide the same or equal protection of user data as stated in this policy and is prohibited from retaining, using, or disclosing your information except as necessary to provide services to us.

ADDITIONAL INFORMATION

XingZhi enables you to record your thoughts and life ambitions either via Appreciation Diary or GAN Calendar Notes within XingZhi. Any information recorded is only viewable by you and is not shared publicly.

Please consider carefully of what you post and communicate through XingZhi.

COMMUNICATIONS FROM US

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend XingZhi for maintenance, or security, privacy, or administrative-related communications). We send these to your email address or notification in XingZhi and/or our official website www.myxingzhi.com. You may not opt-out of these service-related announcements, which are not promotional in nature and used solely to protect your account and keep you informed of important changes to XingZhi.

SENSITIVE PERSONAL INFORMATION

In some jurisdictions, certain types of Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as “sensitive” and is subject to stricter regulation than other types of Personal Information. Please note that content and information that you input to XingZhi, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.

Before communicating any Personal Information of a sensitive nature within XingZhi, please consider whether it is appropriate to do so.

By posting any Personal Information of a sensitive nature within XingZhi, you are consenting to such information being available within the controls you have selected (for example, available to the audience of users you select as being capable of viewing your post or profile information).

AGE RESTRICTIONS

If you are under the age of 13, you must not use XingZhi. If you are between the ages of 13 and 18 (or the relevant age in your jurisdiction where you are considered a minor), your parent or guardian must agree to this Privacy Policy (both for themselves and on your behalf) before you can use XingZhi. We do not knowingly collect Personal Information from any children under the age of 18 without such consent. Please contact us if you believe we have any Personal Information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such Personal Information.

WHERE DO WE PROCESS YOUR DATA?

Xing Zhi Development Centre operates globally. The Personal Information that we collect from you will be transferred to, stored at, or processed in:

Malaysia
Hong Kong, China
Mainland China

Our engineering, technical support, and other teams that support the operations of XingZhi are based in our offices in Malaysia and China; and may have incidental access to certain of your data in order to provide the service (for example, in order to fix technical issues that you report).

SECURITY OF YOUR PERSONAL INFORMATION

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore, we do not assume any responsibility for any transmission of your information which you do at your own risk.

HOW LONG DO WE KEEP HOLD OF YOUR DATA?

We will retain your Personal Information as set out in the following table, except where we are otherwise required to retain such data in accordance with law. Should you or we terminate your account for any reason, we will take steps to ensure that your Personal Information is no longer available through XingZhi, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination.

Information Type	Retention Period
Registration data	Until such time as you instruct XingZhi to delete your account or you have not logged in for 180 days. Your account will be permanently deleted within 60 days of both verification of account ownership and the account deletion request.
Login data	Information is retained from the date of such log in until the date of log out
Profile data and profile media	Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services).
Additional account security	Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services).
Information provided to customer service	Until such time as you instruct XingZhi to delete your account. Your account will be permanently deleted within 60 days of the account deletion request.

Full description of data is set out in the section “How Do We Use Your Information” above.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

DISCLAIMER

The accuracy and completeness of your personal data depends on the information you provide. We assume that the information you have provided is accurate, up-to-date and complete unless you inform us otherwise.

REVISIONS OF THIS PRIVACY POLICY

We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy.

Whenever we make any changes to this Privacy Policy that are important for you to know about, we will notify you via email or other means before the change becomes effective.

If you do not agree to the changes in our use of your Personal Information, you must notify us immediately and deactivate your XingZhi account with us. Continued use of XingZhi, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Summary

SCOPE AND APPLICATION OF THIS PRIVACY POLICY