BullPool Group and its global affiliates (collectively, «BullPool», "we", "us", and "our") respect your privacy. Therefore, we have developed a privacy statement (hereinafter referred to as "this Statement") that covers how we collect, use, disclose, process, and protect your personal data when using our websites, products, or services. Please take a moment to read and understand our Privacy Statement and let us know if you have any questions. This Statement explains how BULLPOOL processes your personal data, but does not cover all processing scenarios as you will be informed in specific processing activity. Therefore, before using a specific product or service, it is recommended that you read the privacy notice or supplementary statement released by BULLPOOL for that product or service to understand how it processes your personal data. This Statement applies only to websites, products, and services that display or mention this Statement.
This Statement describes: I. How BULLPOOL Collects and Uses Your Personal Data II. How BULLPOOL Uses Cookies and Similar Technologies III. How BULLPOOL Processes, Shares, Transfers and Disclose Your Personal Data IV. How BULLPOOL Protects Your Personal Data V. Your Rights VI. How BULLPOOL Protects Children's Personal Data VII. Links to Third-Party Websites, Products, and Services VIII. International Transfers of Your Personal Data IX. Contact Us X. Updates to This Statement I. How BULLPOOL Collects and Uses Your Personal Data A. Personal Data Collected by BULLPOOL Personal data means any electronic or other information which alone or jointly with other information can be used to identify a natural person or make him/her identifiable. You may directly provide us with such data when you use our websites, products, or services, or interact with us by, for example, creating a BULLPOOL account or contacting us for support. We may also obtain data by recording how you interact with our websites, products, or services. For example, we may use technologies like cookies or receive use data from software running on your device. As permitted by law, we may also obtain data from public and commercial third-party sources, for example, purchasing statistics from other companies to support our services. The personal data we collect includes name, enterprise name, postal and email addresses, phone number, login information (account and password), photos, and personal identification information, etc., depending on how you interact with BULLPOOL, for example, the website you visit or the products and services that you use. We also collect the information you provide to us and the content of messages you send us, such as the query information you provide, or the questions or information you provide for customer service support. In addition, we may also collect Non-identifiable data, which refers to data that cannot be used to identify an individual, for example, the statistics on website visits, application downloads, and product sales volume. Before using our products or services, you may need to provide personal data. You do not have to provide your personal data to BULLPOOL, but in some cases, the non-provision of certain personal data will cause the inability to provide you with some related products or services. B. How BULLPOOL Uses Your Personal Data BULLPOOL may use your personal data for the following purposes: (1) To register a BULLPOOL ID. (2) To verify your identity. When you verify your identity, we and third-party service providers may collect personal data from you including your name, mobile number, and identification number. Among them, mobile number and identification number are personal sensitive information, which is used by third-party service providers to verify your identity. We will encrypt your identification number for business risk control, and we will also use encryption measures during information transmission to ensure the security of the personal data you provide. (3) To process your purchase order. Information relating to e-commerce orders may be used for processing the purchase order and related after-sales services, including customer support and re-delivery. For example, in order to ship goods to you and provide after-sales services, we require you to fill in the consignee's address, name, mobile phone number, and postal code, and may share this information with third-party warehousing, logistics, and service providers. When you make the payment, we may need to collect your order number, payment sequence number, order amount, and payment method, among which, the order number, order amount, and payment method may be shared with third-party payment companies. Your name and order number may need to be shared with tax authorities in order to invoice and send you an invoice, and your invoice address, name, mobile number, and postal code may need to be submitted to third-party logistics providers in order to send you an invoice. In order to protect the security of your transactions, we may need to collect your account information, device information, IP address, bank card number, your registered mobile phone number, and email address, where your IP address, bank card number, registered mobile phone number and email address will be anonymized. In order to provide after-sales service, we may need to record information with regard to the equipment you purchased. (4) To send you important notifications. (5) To provide personalized user experience and content. (6) To send you information with respect to products and services you might be interested in, invite you to BULLPOOL’s promotional activities and market surveys, or send marketing information to you. If you do not want to receive such information, you can opt out at any time. (7) To collect user feedback. The feedback you choose to provide is important to help BULLPOOL improve its services. To process your feedback, we may use the personal data you provide to contact you and keep records. (8) To carry out internal auditing, data analysis, and research; analyze business operation efficiency and measure market shares; and improve BULLPOOL's products and services. (9) Troubleshooting when you send us error reports. (10) Ensuring the security of our products, services, and customers or users. (11) To comply with applicable laws, regulations, relevant industry standards, or our policies. (12) Other purposes with your consent. II. How BULLPOOL Uses Cookies and Similar Technologies BULLPOOL’s websites, online services, interactive applications, email messages, and advertisements may use "cookies" and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non-personal data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also treat these identifiers as personal data. A. Cookie A cookie is a text file stored by a web server on a computer or mobile device, and the content of a cookie can be retrieved and read only by the server that created the cookie. Cookies are unique to the browser or mobile application you are using. The text in a cookie often consists of identifiers, site names, and some numbers and characters. Sometimes, BULLPOOL stores cookies on computers or mobile devices for the purpose of improving user experience, including the following scenarios: (1) Technical cookies: Login and verification. When you use a BULLPOOL ID to log in to a website, the “session-based” cookies ensure that your visit to this site functions as smoothly as possible. (2) Personalization cookies: Storage of your preferences and settings. A website can use cookies to save settings, such as the language setting and font size on your computer or mobile device, items in your shopping cart, and other browser preferences. (3) Advertising cookies. BULLPOOL uses cookies to collect information about your online activities and interests and provide you with advertisements that correlate most highly with you. (4) Statistical cookies. With cookies, BULLPOOL can collect information about your use of our websites and other applications, either for a single visit (using a session cookie) or for repeated visits (using a persistent cookie). We will not use cookies for any purpose other than those described in this Statement. You can manage or delete cookies at your own preference. For details, please visit AboutCookies.org . You can clear all the cookies stored on your device, and most current web browsers provide the option of blocking cookies. However, blocking cookies will require you to change your user settings every time you visit our website. Find out how to manage cookie settings for your browser here: 、 、 、 and If you clear cookies, you will need to change your settings the next time you visit BULLPOOL's websites. Note that some of BULLPOOL's services require the use of cookies. Disabling cookies may affect your use of some or all functions of these services. B. Web Beacons and Pixel Tags In addition to cookies, BULLPOOL, and some third parties may also use web beacons and pixel tags on websites. A web beacon is usually an electronic graphic image embedded into a website or email to identify your device cookies when you browse the website or email. Pixel tags allow BULLPOOL to send emails in a way that is readable to you and find out whether an email is opened. BULLPOOL and some third parties use these technologies for various purposes, including analysing service usage (together with cookies) and providing more satisfactory content and advertisements to you. For example, when you receive an email from BULLPOOL, it may contain a click-through URL that links to a BULLPOOL web page. If you click the link, BULLPOOL will track your visit to help us learn about your preferences for products and services and improve our customer service. You can unsubscribe from the mailing list of BULLPOOL at any time if you do not want to be tracked in this manner. C. Other Local Storage BULLPOOL and some third parties may use other local storage technologies, for example, local shared objects (also called "Flash cookies") and HTML5 local storage, in certain products and services. Similar to cookies, these technologies store information on your device and can record some information about your activities and preferences. However, these technologies may use different media from cookies. Therefore, you may not be able to control them using standard browser tools and settings. For details about how to disable or delete information contained in Flash cookies, please click here. D. Do Not Track Many web browsers provide a Do Not Track function that can release Do Not Track requests to websites. Currently, major Internet standardization organizations have not established policies to specify how websites should handle these requests. If you enable Do Not Track in your browser, all of BULLPOOL’s websites will respect your selection. E. Application Operation: Aiming at conducting user statistics and operation optimization, we probably need to collect the following user information: device identification code (such as IMEI, Android ID, and device serial number), as well as device manufacturers, device brands, device models, and Android versions. F. Individualization Service: we may need users to use the camera function in order to simplify user operations. III. How BULLPOOL Processes, Shares, Transfers and Disclose Your Personal Data A. Entrusted Process BULLPOOL may entrust third parties to process your personal data on BULLPOOL's behalf, including but not limited to the companies that could handle hotlines, send emails, and provide technical support. Those companies will only use the personal data for providing the services to you on behalf of BULLPOOL. BULLPOOL will sign strict confidentiality agreements or personal data processing agreements with the entrusted parties, requiring them to comply with this Statement and take appropriate confidentiality and security measures when processing personal data. B. Share “Share” refers to the process by which BULLPOOL provides personal data to other personal information controllers and each party has independent control over the personal data. We do not share personal data with other companies, organizations, and individuals unless one of the following circumstances applies: (1) Sharing with consent: After obtaining your consent, BULLPOOL will share the information that you have authorized with specified third parties or categories of third parties. (2) Sharing pursuant to laws and regulations: BULLPOOL may share your information as required by laws and regulations, for resolving legal disputes, or as required by administrative or judiciary authorities pursuant to law. (3) Sharing with BULLPOOL's affiliates: Your information may be shared within BULLPOOL's affiliates only for explicit, and legitimate purposes, and the sharing is limited only to information required by services. For example, we verify the global uniqueness of accounts before allowing them to be registered. (4) Sharing with business partners: Your information, including order, account, device, and location information, may be shared with third parties such as business partners to ensure the smooth completion of the services provided to you. Your information will be shared for legitimate, proper, necessary, specific, and definite purposes, and only the information necessary to provide services will be shared. (5) Sharing with service providers: BULLPOOL may share your information with third parties who support our functions, including third parties who supply or provide us with infrastructure technology services, logistics and distribution services, payment services, data processing services, etc. We share this information in order to achieve the functions of our products and services, for example, we may share your order information with logistics service providers to arrange delivery; or we may need to share your order number and order amount with third-party payment institutions to enable them to confirm your payment instructions and complete payment. In scenarios (3) to (5), BULLPOOL will ensure the lawfulness of this sharing and sign stringent non-disclosure agreements (NDAs) and/or data processing clauses with the companies, organizations, and individuals with whom personal data is shared, requiring them to comply with this Statement and take appropriate confidentiality and security measures when processing personal data. C. Transfer “Transfer” refers to the process of transferring control of personal data from BULLPOOL to another personal data controller. We will not transfer your personal data to any company, organization, or individual, except in the following cases: (1) Transfer with express consent: After obtaining your express consent, we will transfer your personal data to other parties; (2) In the case of merger, acquisition, or bankruptcy liquidation, such as the transfer of personal data, we will require the new company or organization that holds your personal data to continue to be bound by this Statement, otherwise we will require the company or organization to seek authorization from you again. D. Disclosure We will only publicly disclose your personal data in the following circumstances: (1) After obtaining your express consent. (2) Public disclosure based on law or reasonable grounds: BULLPOOL may publicly disclose your data when required by law, legal process, litigation, or public and government authorities. IV. How BULLPOOL Protects Your Personal Data BULLPOOL attaches great importance to the security of your personal data and has adopted standard industry practices to protect your personal data and prevent it from unauthorized access, disclosure, use, modification, damage, or loss. To this end, BULLPOOL takes the following measures: (1) We take reasonable and feasible measures to ensure that the personal data collected is minimal and relevant to what is necessary in relation to the purposes for which they are processed. We will retain your personal data only for as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory, or internal policy requirements, unless an extension of the retention period is required or permitted by law. If we no longer need to use your personal data for the purposes set out in this Statement and privacy notice of a specific product or service and/or we are not legally required to retain your personal data, we will take reasonable steps to destroy your personal data or render it anonymous. (2) We use a range of technologies such as cryptographic technologies to ensure the confidentiality of data in transmission. We implement trusted protection mechanisms to protect data and data storage servers from attacks. (3) We deploy access control mechanisms to ensure that only authorized personnel can access your personal data. In addition, we control the number of authorized personnel and implement hierarchical permission management on them based on service requirements and personnel levels. (4) We strictly select business partners and service providers and incorporate personal data protection requirements into commercial contracts, audits, and appraisal activities. (5) We hold security and privacy protection training courses, tests, and publicity activities to raise employees' personal data protection awareness. BULLPOOL is committed to protecting your personal data. Nevertheless, no security measure is perfect and no product, service, website, data transfer, computing system, or network connection is absolutely secure. To cope with possible risks, such as personal data leakage, damage, and loss, BULLPOOL has developed several mechanisms and control measures, clearly defining the rating standards of security incidents and vulnerabilities, and corresponding processing procedures. BULLPOOL has established a dedicated emergency response team to implement security planning, loss reduction, analysis, locating, and remediation, and to perform tracking operations with related departments based on security incident handling regulations and requirements. If any personal data incident occurs, BULLPOOL will notify you, pursuant to relevant legal and regulatory requirements, of the basic information about the security incident and its possible impact, measures that BULLPOOL has taken or will take, suggestions about active defense and risk mitigation, and remedial measures. The notification may take the form of an email, text message, push notification, etc. If it is difficult to notify data subjects one by one, we will take appropriate and effective measures to release a Security Notice. In addition, we will also report the handling status of personal data security incidents as required by supervisory authorities. V. Your Rights A. Access, Rectification, Deletion Legislation in some countries and regions to which BULLPOOL provides products and services or from where BULLPOOL processes personal data, provides that data subjects the rights request (hereinafter referred to as "requests") in regards to the accessing, rectifying, or deleting related personal data by BULLPOOL retains. Requesting modes and channels Data subjects' requests must be submitted in accordance with BULLPOOL's designated privacy channels. The requests are valid even when the requester does not specify the laws on which the requests are based. If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete, please submit your request to our online service. A copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests for the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws. Validity of requests Most laws require data subjects to comply with specific requirements when they initiate requests. This Statement requires data subjects to: (1) Submit requests to our online service. (2) Provide sufficient information for BULLPOOL to verify their identities (to ensure those who initiate the requests are the data subjects themselves or those authorized by them). (3) Ensure that their requests are specific and feasible. There are some circumstances, provided by laws and regulations, in which BULLPOOL may not have to comply with the request in full or at all. Processing period of requests BULLPOOL will make every effort to ensure that a response is made within one month of the request for access to the personal data subject, and this period may be extended by another two months if necessary, taking into account the complexity and volume of requests. In the event of a delay in providing information, BULLPOOL will inform the personal data subject of the relevant circumstances and the reasons for the delay. In the event of a conflict between the time limit set out in this paragraph and the local laws and regulations, the local laws and regulations shall prevail. Result of requests Upon receipt of the requests from the data subjects, the following results may occur: (1) The request will be denied In some cases, the personal data subject's request will be denied, including but not limited to: a. When the local law does not grant the relevant rights to the personal data subject; b. When the identity of the person making the request cannot be verified; c. Requests made by personal data subjects cannot be verified, are out of scope, or are likely to make BULLPOOL unable to comply with applicable laws, or make repeated requests; d. The information is relevant to BULLPOOL in a dispute or potential dispute, and the execution of the requested content is likely to harm BULLPOOL's interests; e. If the information is retained for statistical and research purposes only, and the publication of statistics and research results will not disclose the identity of the individual; f. Other circumstances provided by law; If BULLPOOL rejects the request for access to the personal data subject, it will formally explain the reason to the requestor. (2) The request will be processed When the situation in (1) does not occur, BULLPOOL will fulfill the request of the personal data subject. In order to improve the likelihood of success of the request, please provide as much detailed information as possible at the time of making the request, such as the type and specific content of the request, the relevant information of the information holder (such as the name of the BULLPOOL products and services you use), and the time frame during which the information is generated or processed. Special Policy (1) The laws and regulations in most jurisdictions may specify the circumstances under which an organization may not provide data to a personal data subject. These include situations where providing the data would undermine efforts to combat terrorism, where the personal data subject has made repeated requests, or where obtaining and providing the information would require disproportionate resources. (2) In principle, BULLPOOL does not provide the following information: a. Information in relation to other individual - The personal data subject access request seeks to obtain data that may relate to others other than the personal data subject. BULLPOOL does not provide such information unless the individual concerned has consented. b. Duplicate application - The requester makes the same or similar request for the same personal data subject, the data has not changed in the past period of time, and BULLPOOL has already provided the data, in which case BULLPOOL will usually not provide a copy of the data. In addition, BULLPOOL is under no obligation to provide information that has already been made public. c. Statements made under conditions of confidentiality - BULLPOOL is under no obligation to provide information about the personal data subject if such information is made under conditions of confidentiality. d. Special Documents - Any special information retained by BULLPOOL will not be made public upon the request of the personal data subject for access. In general, special information includes any confidential documents (such as direct communication between the client and his lawyer) and information for the purpose of obtaining or giving corresponding legal advice (whether it is information involved in the proceedings themselves or in the course of court proceedings). B. Consent Withdrawal You can change the authorized personal data collection scope or withdraw your consent without affecting the lawfulness of the processing activities based on the consent and prior to such withdrawal. Your rights can be exercised by deleting information, disabling related functions, or setting privacy options on your BULLPOOL's product. BULLPOOL will release the methods for withdrawing consent for specific products and services in the privacy notice or supplementary statement of those products and services or upon request according to section A above. C. Deregistering a BULLPOOL ID You can deregister your account in BULLPOOL ID-related products. After you deregister your account, we will stop providing products and services, and delete your personal data unless otherwise stipulated by law. Your account cannot be restored after deregistration. You need to register a new BULLPOOL ID if you want to use related BULLPOOL’s products or services again. You can submit a deregistration application and complete the process in the setting menu after logging in to your BULLPOOL ID on related devices, applications, or official website. VI. How BULLPOOL Protects Children's Personal Data We consider it the responsibility of parents to monitor their children’s use of our products and services. Nevertheless, it is our policy not to require personal data from children or offer to send any promotional materials to persons in that category. BULLPOOL does not seek or intend to seek to receive any personal data from children. Should a parent or guardian have reasons to believe that a child has provided BULLPOOL with personal data without their prior consent, please contact us to ensure that the personal data is removed and the child unsubscribes from any of the applicable BULLPOOL’s services. VII. Links to Third-Party Websites, Products, and Services BULLPOOL's websites, application software, products, and services may contain links to third-party websites, products, and services. BULLPOOL's products and services may also use or provide products or services from third parties. All links to third-party websites, products, and services are provided for users' convenience only. We are not responsible for and cannot control how third parties use the personal data that they collect from you. Our privacy policy does not apply to other sites linked to our services. You need to determine your interaction with such links on your own. Before submitting your personal data to third parties, please read and refer to these third parties' privacy policies. VIII. International Transfers of Your Personal Data Our products and services are delivered through resources and servers located in different places, to offer our products and services, we may need to transfer your personal data among several countries. By providing us with your personal data through BULLPOOL's website or otherwise, you expressly consent to BULLPOOL's cross-border transfer of such personal data for the purposes mentioned in this Statement. Authorized BULLPOOL personnel and third parties acting on our behalf may access, use, and process personal data collected from you in a country/region that is different from the country/region where you entered the personal data, which may have less stringent data protection laws. When we transfer your personal data to other countries/regions, we will protect the personal data as described in this statement or as otherwise disclosed to you at the time the data is collected (e.g. via privacy notice or supplementary statement of specific product or service). BULLPOOL has implemented global privacy practices for processing personal data protected under various data protection laws. BULLPOOL transfers personal data between the countries in which we operate in accordance with the standards and conditions of applicable data protection laws, including standards and conditions related to security and processing. With respect to personal data coming from the EU, we comply with applicable legal requirements providing adequate safeguards for the transfer of personal data to countries outside of the European Economic Area ("EEA"). We use a variety of legal mechanisms, such as standard contractual clauses to implement the cross-border transfer of your personal data; or implement other safeguards provided for in the GDPR. IX. Contact Us Questions, comments, and requests regarding this Privacy Policy are welcome. We have set up a dedicated personal data protection team and a person in charge of personal data protection. If you have any questions, complaints, or suggestions about this privacy policy or personal data protection-related matters, you can submit them to the designated data center to comply with applicable privacy laws. For such feedback, the Protection Officer (Personal Data Protection Officer) can be contacted at support@bullpool.io If you wish to make a complaint about how we have handled personal data, please first contact us at support@bullpool.io and we will endeavor to process your request as quickly as possible. X. Updates to This Statement BULLPOOL reserves the right to update this Statement at any time. Should this Statement be revised from time to time, BULLPOOL will release the change notice via various channels, for example, posting the latest version on our official website: https://www.bullpool.io If we make any material changes, we may notify you by means of a notice on this website. "Material changes" in this Statement include but are not limited to: (1) Material changes in our service modes, for example, purposes of personal data processing, types of processed personal data, and ways of using personal data (2) Material changes in our ownership structure, organizational structure, etc., for example, ownership changes caused by business adjustment, bankruptcy, or acquisition (3) Changes in the main objects of personal data sharing, transfer, or disclosure (4) Material changes in your rights regarding personal data processing and the ways in which you can enjoy those rights (5) Changes in BULLPOOL’s departments, contacts, and complaint channels responsible for the security of personal data processing (6) High risks identified in personal data security impact assessment reports
