Cobo Guard Privacy Policy

LAST UPDATED: August 10, 2023

Introduction

The Privacy Policy (this "Privacy Policy") outlines how Cobo Technologies Limited and our affiliates (collectively, "Cobo Technologies" or "we") will collect, use, maintain, share, and store information related to the use of our services, content, technologies, or features offered by our mobile application and all associated websites (collectively, "Cobo Guard"). We are committed to protecting your personal data and this relates to where data is gathered and handled in accordance with the relevant applicable data protection law. Our services are not available to users in mainland China.

"Personal Information" refers to information relating to an identified or identifiable individual and does not include de-identified or aggregated information. Additionally, to the extent permitted by law, Personal Information does not include information that is legally available to the public or legally available in government records.

I. Information We Collected

In order to provide you with better services, we will collect your personal information from your computer and/or mobile device, including but not limited to the following:

II. Use of Personal Information Collected

We will use your personal information in the following ways:

For the personal information we collect and use beyond the purpose specified in this Privacy Policy, we will definitely acquire your explicit consent.

III. Sharing and Transfer of Personal Data

3.1. Sharing

We will not share your personal information with the third parties except for the following:
3.1.1. Sharing with explicit consent: We may share your information with other parties only if we obtain your explicit consent.
3.1.2. Sharing under legal circumstances: We may share your information in order to report illegal activities or investigate possible violation of any agreements, to settle a litigation or arbitration, or as requested by administrative or judicial authorities in accordance with the relevant applicable laws and regulations.

3.2. Transfer

We will not transfer your information to any third parties except for the following:
3.2.1. Transferring to the server: the personal information we collect and use will be stored in your place of residence. However, we may transfer and store your personal information on a server if it meets the requirements of relevant applicable laws and regulations.
3.2.2. Transferring with explicit consent: We may transfer your information to other parties only if we obtain your explicit consent.
3.2.3. We will ask the new company or organization holding your data to continue to be bound by this Privacy Policy or we will strongly advise that company, organization, or individual to request your explicit consent once more in the event of a merger, acquisition, or liquidation of Cobo Technologies with another legal entity or other merger, acquisition, or liquidation involving the transfer of user information.

3.3. Exceptions for sharing and transferring user information with prior written consent

Your prior written consent is not necessary to share or transfer your user information in the following cases:
3.3.1. Related to national security and national defense security.
3.3.2. Related to public safety, public health, and significant public interest.
3.4.3. Related to crime investigation, prosecution, trial and sentence enforcement, etc.
3.4.4. In order to safeguard yours or another individual's significant legal rights and interests, such as life or property, including when it is hard to obtain your prior consent.
3.4.5. Personal information that you disclose to the public by yourself.

IV. Protecting Your Personal Information

We shall use our best efforts to protect the security of the user data we collect from loss, unauthorized access, misuse, and modification.
4.1. To secure information with a sufficient level of security, we shall utilize a variety of security measures.
4.2. In the unlikely event that there is a personal information leak, we will immediately let you know by email, push notification, and other channels of communication. In the interim, we will also take the initiative to report the incident's resolution in accordance with the regulatory authorities' regulations.
4.3. We shall make every effort to ensure that only pertinent personal data is gathered. Unless a longer retention period is required or permitted by law, we will only keep your personal information for as long as it takes to accomplish the goals of this Privacy Policy.

V. Your Rights

You are entitled to certain rights in relation to your personal information.
5.1. If you believe that the personal information we have collected is inaccurate, you may request us to correct such information collected.
5.2. To restrict or object to the processing of your personal information for compelling and legitimate reasons related to your situation, unless such processing is expressly provided for by law.
5.3. You may request us to delete personal information in the following cases:

1) If our handling of personal information violates laws and regulations;

2) If we collect and use your personal information without your consent when the explicit consent is required;

3) If our processing of personal information constitutes a breach of our agreement with you;

4) If you no longer use our products or services, or if you wish to terminate your account; or

5) If we no longer provide products or services to you.

VI. Minors

6.1. Cobo Guard is primarily intended for adults. Without the permission of their parents or other legal guardians, minors are not permitted to open their own personal information accounts.
6.2. In the scenario of personal information collected from minors with parental consent, we will only use or publicly disclose this information as permitted by law, with the express consent of the parent or legal guardian, or as necessary to protect the minor.
6.3. Under this Privacy Policy, we consider everybody under the age of 18 to be a minor, regardless of how other laws and traditions define minors.
6.4. Once we discover that we have gathered personal information from a minor without their previous verifiable parental consent, we will work to erase the pertinent data as soon as we can.

VII. How Long We Retain Your Personal Data

To the extent necessary or authorized by law, or in accordance with the retention guidelines that we may occasionally change, we will keep your personal information for as long as necessary or appropriate to achieve the goals outlined in this Privacy Policy. The time needed to keep personal information for business purposes, the upkeep of related business records, the processing of your inquiries, our reasonable belief that the data is required to process any litigation, and whether legal and contractual obligations impose any requirements will all be taken into account when determining the length of such retention.

VIII. Cross-Border Transmission

We take the necessary steps to guarantee that the cross-border data transfer complies with relevant data protection regulations. If we transmit data from the European Economic Area to countries with insufficient levels of data protection, we may do so using standard contractual agreements. Your consent shall be the basis for such transfers if an appropriate decision, ordinary contractual conditions, or any other right to transfer your data are missing.

IX. Opt Out

By getting in touch with us, you can choose at any time to stop receiving marketing and promotional messages from us. Please be aware that even if you opt not to receive the aforementioned emails, we will still respond to you if you contact us for any other concerns relating to your usage of Cobo Guard.

X. Update of Privacy Policy

We may add, remove, modify, or update this Privacy Policy from time to time. This Privacy Policy will be updated as needed and posted on our websites and mobile applications and you will frequently check for updates or modifications. Your continuing use of the software, service, mobile device, or websites following the release of an upgraded version signifies your acceptance of the revised version.

XI. Contact Us

Please get in touch with us at [email protected] if you have any questions about this privacy statement or our privacy practices. Generally, we'll get back to you about your request in less than 30 days. If you are not pleased with our response, particularly if you feel that our handling of your personal information violated your legal rights, you might choose to file a complaint with the government, the courts, or other appropriate authorities.