This edition is published on 15/04/2023

Effective Date: 04/15/2023

 

Special Notes:

MODERN MALL Service Provider (or referred to as "we" or "us") is well aware of the importance of personal information to you, your trust is very important to us, we will strictly abide by the requirements of laws and regulations, take corresponding security protection measures, and strive to protect your personal information safe and controllable. Based on this, the service provider of MODERN MALL formulates this "MODERN MALL Privacy Policy" (hereinafter referred to as "this Policy / this Privacy Policy") and reminds you that: This Policy applies to all products and services provided by MODERN MALL. If we and our affiliates use the products or services provided by MODERN MALL (such as logging in with MODERN MALL account) but do not have a separate privacy policy, this Policy will also apply to such products or services. If we and our affiliates have separately established privacy policies for the products or services they provide to you, the corresponding privacy policies shall apply to the corresponding products or services. It should be noted that this policy does not apply to the services provided to you by other third parties, nor does it apply to the products or services that have separately set up a privacy policy in MODERN MALL.

This policy is closely related to your use of various services, before using the products or services of MODERN MALL, please be sure to read carefully and thoroughly understand this policy,especially the terms marked by us in bold/bold underline,to ensure that you fully understand and agree before starting to use. We strive to use easy-to-understand and concise language to make it easier for you to understand. If you have any questions, comments or suggestions about the content of this Policy, you can contact us through the contact information provided at the end of this Policy.

If you agree to this Policy by checking/confirming, etc., it means that you have understood the functions provided by the application and the necessary personal information required for the operation of the functions, and have been authorized to collect and use them accordingly.

The products and services involved in this Policy are only intended for use by persons over the age of 18 (inclusive), if you have not reached the above age, please immediately stop using the products, services and even platform software involved in this Policy.

This policy will help you understand the following:

1. How We Collect Your Information

2. How We Use Your Information

3. How We Share, Transfer, and Publicly Disclose Your Information

4. How We Protect Your Information

5. How do you manage your information?

6. How we process the information of minors

7. How this Privacy Policy is updated

8. How to contact us

 1. How We Collect Your Information

The personal information we need/may need to collect and use includes the following two types:

1. In order to provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally;

2. In order to provide you with additional functions of our products and/or services, you may choose to authorize us to collect and use the information. If you refuse to provide it, you will not be able to use the relevant additional functions normally or achieve the functional effects we intended, but it will not affect your normal use of the basic functions of our products and/or services.

In the process of using the products and/or services of MODERN MALL, we need/may need to collect your personal information to provide you with services, improve the quality of our services, ensure the safety of your account and funds, and comply with national laws, regulations and regulatory provisions We hereby remind you that we will follow the principles of legitimacy, legality and necessity to collect and use your personal information that you voluntarily provide in the process of using the products and/or services and software of MODERN MALL, generated from the use of the products and/or services and software, and legally obtained by us from third parties for the following purposes described in this Policy. If you provide the personal information of others, please ensure that you have obtained the authorization of the relevant subject, otherwise you shall bear the corresponding responsibilities arising therefrom.You understand and agree that:

1. We are committed to creating a variety of products and services to meet your needs. Due to the wide variety of products and services we provide to you, and the specific products/services that different users choose to use are different, the basic/additional functions and the types and scope of personal information collected and used will be different.

2. In order to bring you a better product and service experience, we are continuously striving to improve our technology, and then we may introduce new or optimized functions from time to time, and may need to collect and use new personal information or change the purpose or method of using personal information. In this regard, we will separately explain to you the purpose, scope and use of the corresponding information by updating this Policy, pop-up windows, page prompts, etc., and provide you with the method of independent choice of consent, and collect and use it after obtaining your express consent.

    During this process, if you have any questions, comments or suggestions, you can contact us through the contact information provided in this Policy, and we will answer you as soon as possible.

The specific functional scenarios we will provide for you include:

(1) Conduct real-name management on the basis of laws, regulations, and regulatory provisions

    When you register an account or use the service, you need to provide your mobile phone number as your account login name, and verify that the mobile phone number belongs to you.

(2) Identity verification information

1. Login verification

In order to allow you to log in to MODERN MALL more safely and conveniently, you can choose password login, SMS verification code login, etc.;

2. Verification of important operation behaviors

In order to ensure the security of your account, we need to verify your identity when awakening some important account operations (e.g., retrieving passwords, etc.), for which you may need to provide us with photocopies of ID cards, photos of holding ID cards, transaction vouchers and other identifiable proof materials collected based on your consent in the course of specific business development; If you do not agree to provide the above information, you will not be able to complete special operations, but it will not affect your use of other services provided by us.

3. Real-name authentication

In order for users to enjoy the free mortgage service, we need to collect your real name, ID card information, and perform face recognition operationsduring your use of the MODERN MALL service. Such as: real-name authentication, face recognition to obtain free custody service, personal face recognition signature, etc.

(3) Log information

In order to allow users to enjoy better push services, when you use our services, the system may use cookies and web beacon or other automatically collected technical information, including device or software information, such as configuration information provided by your mobile device, web browser, or other programs used to access our services, your IP address, and the version and device identifier used by your mobile device;

information you search for or browse while using our Services, such as the web search terms you use, the URLs of the social media pages you visit, and details of other information and content that you view or request while using our Services; information about the mobile applications(s) and other software you have used and how you have used them;

Information about your communications through our Services, such as the account number you have communicated with, and the time, data and duration of your communications.

(4) Location information

n order to allow you to enjoy better and more products (referring to regional products and services, some lessors can only provide regional financial leasing services based on laws and regulations) and delivery services, you can turn on the device location function and use the relevant services we provide based on location, and you agree that we can collect your specific location information, and you need to authorize the "location permission" to be turned on. We will collect latitude and longitude through third-party SDKs (such as Baidu Maps) and obtain your non-real-time location information after analyzing the aforementioned latitude and longitude, but we will not collect your whereabouts, and if you refuse to provide them, you will not be able to use the above services, but it will not affect your use of other services. In order to provide users with better delivery services, the information collected about your location when you turn on the device location function and use our location-based services, including:

1. Your geographic location information collected through GPS or WiFi when you use our services through a mobile device with location function;

2. Real-time information provided by you or other users containing your address and location, such as your region information contained in the account information you provide, shared information uploaded by you or others showing your current or former geographic location, and geotagged information contained in photos shared by you or others;

You can stop the location information on your phone by turning off the location function.

(5) Pasteboard information

In order for users to enjoy the convenience of filling in the address, we need to use pasteboard information

2. How We Use Your Information

1. Help you become our member

(1) Basic membership services

We provide you with basic membership services through the MODERN MALL platform account. In order to register as a member and use our membership services, you need to provide your mobile phone number, the member name and password you want to use to create an account on the platform. If you only need to use the browsing and search services, you do not need to register as a member and provide the above information.

For the services that can only be used through the account of the MODERN MALL platform, we may verify your membership status based on the above information provided by you to ensure that we are providing services for you.

(2) Additional Membership Services

Special membership benefits:If you choose to provide your real name, gender, date of birth, place of residence (delivery address), nickname, avatar and other personal information that is not required for registration, we can provide you with more personalized membership services such as membership birthday privileges. Among them, in order to ensure the recognition of the transaction, your nickname and avatar will be displayed publicly.

Real-person authentication:You can provide us with corresponding identity information (ID card, passport, household registration book and other identity document information) and biometric features (static or dynamic facial features) to complete real-person authentication according to the authentication requirements.

Authorized login: We may share your account information (profile picture, nickname and other information prompted on the page) with a third party with your consent, so that you can easily register or log in to a third-party account. In addition, we may obtain your third-party account information from a third party based on your authorization, and bind it to your MODERN MALL Platform account, so that you can directly log in and use our products and/or services through your third-party account. We will use your relevant information within the scope of your authorization and consent.

Account information display:If you already have an account on the MODERN MALL Platform, we may display your above-mentioned personal information in the services of the MODERN MALL Platform, as well as the operations you perform on the MODERN MALL Platform or in the products and services associated with the MODERN MALL Platform account, including the centralized display of your personal information, preferential rights and interests, and transaction orders through the MODERN MALL Platform account. We will respect the choices you make about the services of the platform and the account settings of the platform.

2. To provide you with information display of goods or services


During your use of our services, in order to identify the abnormal status of your account, understand the adaptability of the product, and provide you with page displays and search results that are more suitable for your needs, we may automatically collect your usage and store it as network log information, including: Device information: We will receive and record information about the device you use (includingdevice model, operating system version, device settings, device serial number, etc.) according to your specific operations during software installation and/or use. software and hardware characteristics such as the device environment), information about the location of the device (including the GPS location authorized by you, and sensor information such as WLAN access points, Bluetooth, and base stations).  Service log information: When you use the products or services provided by our website or client, we will automatically collect the details of your use of our services and save them as service logs, including browsing, clicking to view, search query, favorites, adding to shopping cart, transaction, after-sales, following and sharing information, publishing information, as well as IP address, browser type, telecommunications operator, language used, date and time of access.  Please note that individual device information and service log information are information that cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or combine it with personal information, such non-personal information will be regarded as personal information during the combination period, and we will anonymize and de-identify such information unless we have obtained your authorization or are otherwise provided by laws and regulations. We may collect your order information, browsing and search information, behavioral preferences (such as the rental period selection, brand liking, category requirements, browsing behavior and other information you provide to us), location information, etc., and combine the information you provide in the use of a service on MODERN MALL with the information from other services to conduct comprehensive statistics and analysis to form user portraits, including pushing message notifications to you on the App page, sending you push messages, promotional information or displaying commercial advertisements through SMS and App to make return visits by telephone, provide you with information and other services, or invite you to participate in customer research related to services, products or functions. For example, we will use the information you collect when you use one of our services, and we will also use your information in order to continuously improve and optimize the above features.

3. Help you complete order placement and order management

When you order specific goods and/or services in our products and/or services, we will generate an order for you to purchase or lease the goods and/or services through the system. During the order process, you need to provide at least your consignee's name, delivery address, consignee's contact number, and the order will contain information about the goods and/or services you have purchased or leased, the specific order number, the time when the order was created, and the amount you should payWe collect this information to help you complete the transaction smoothly, ensure the security of your transaction, inquire about order information, provide customer service and after-sales service, and other purposes that we have clearly informed. You can order goods and/or services for others through MODERN MALL, and you need to provide the aforesaid personal information of the actual orderer. In order to facilitate you to understand and query the order information and manage the order information, we will collect the order information generated during your use of our services to show you and facilitate your order management. You can additionally fill in/select additional information including additional contact numbers, delivery time, etc., to ensure the accurate delivery of goods or services.

4. To help complete the delivery of goods or services to you

In order to ensure the smooth, safe and accurate delivery of the goods and/or services you purchase or lease, we need to make the following arrangements for the platform's self-operated products and non-self-operated products;

1) Platform self-operation: We will disclose order-related delivery information to the express/logistics company that provides logistics information system and technical services for the MODERN MALL Platform, includingthe order number, information about the goods and/or services you purchased (name, price, preferential information), order time, consignee's name, consignee's address, and consignee's telephone information.

(2) Non-self-employed: In addition to providing relevant information to the delivery entity in accordance with paragraph (1) of this Article, it is also necessary to synchronize your order information with the seller who actually provides you with goods and/or services, including he order number, information about the goods and/or services you purchased (name, price, preferential information), the time of placing the order, the amount you actually paid and the payment method you used, the number of rental periods (if any), the name of the consignee, the delivery address, and the telephone number of the consignee, so that the relevant goods and// or the Provider provides you with Fulfillment Services.

    (3) Regardless of whether it is self-operated or non-self-operated business on the platform, in the process of receiving goods, in order to verify the identity of the consignee and ensure the accurate delivery of the products and/or services you lease or purchase, we entrust the delivery company to authenticate the identity of the recipient, and need to collect the recipient's face information and identity document information to ensure that the person and ID card are consistent. Please also note that when the delivery company collects the recipient's facial information, it will separately ask for the recipient's consent.

5. Customer service and dispute resolution

When you contact us or apply for in-sale, after-sales, and dispute resolution, in order to protect the security of your account and system, we need you to provide necessary personal information to verify your membership status. In order to contact you, help you solve the problem as soon as possible, or record the handling plan and results of related problems, we may keep your correspondence/call records and related content with us (including account information, order information, other information you provide to prove relevant facts, or contact information you leave behind), and we will use your account information and order information if you make inquiries, complaints or suggestions for specific orders. In order to provide services and improve service quality, we may also use other information about you, including the relevant information you provide when you contact customer service, and the questionnaire response information you send to us when you participate in questionnaires.

6. Provide you with security guarantees

In order to improve the security of your use of the services provided by us and our affiliates and partners, protect the personal and property safety of you or other users or the public from infringement, better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, and network intrusions, and more accurately identify violations of laws and regulations or the relevant agreement rules of MODERN MALL, we may use or integrate your member information, transaction information, device information, service log information, and our affiliates, The Partner obtains the information authorized by you or shared in accordance with the lawto comprehensively judge the risks of your account and transactions, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis and disposal measures in accordance with the law.

7. Other permissions include the following:

The following permissions can only be used for the implementation of specific functions or services with your express authorization, and you can also withdraw the authorization. In particular, even if we have obtained these sensitive permissions with your authorization, we will no longer collect your information when the relevant functions or services are not needed.

(1) Read the status and identity of the mobile phone;

In order to ensure the safe and stable operation of the services provided to you, prevent transaction and capital risks, and prevent viruses, Trojan horses, and websites, we need to record the type, method, device model, IP address, device software version information, device identification code, device identifier, region, network usage habits, device-related application information, and other log information related to the MODERN MALL service. If you do not consent to us obtaining/recording the aforesaid information, you may not be able to complete the risk control verification.

(2) Permission to obtain device location information

When you successfully log in to MODERN MALL, you can choose to turn on this permission so that you can accept service recommendations based on your location; If you choose to turn off this permission, you will not receive service recommendations based on your location, but it will not affect your use of other services provided by MODERN MALL.

(3) Camera permissions, access to device photos, media content and files, and permission to take photos and record videos;

When you use the functions of MODERN MALL, such as avatar picture settings, screenshot feedback function, identity verification, transaction payment, product sign-off, etc., you need to turn on the camera permission to obtain and access the device photos, media content and file permissions (subject to the specific functions you use), so that you can obtain the corresponding permissions of the service accordingly, if you choose to turn off the above corresponding permissions, it may affect the use of the corresponding services, but will not affect your use of other services provided by MODERN MALL.

(4) Obtain permission to access the address book

    In the process of using the MODERN MALL service, when you place an order, obtain the qualification for exemption from charge, etc., and fill in the emergency contact information, in order to automatically fill in the information and ensure the verification of the authenticity and validity of your account by risk control, you need to obtain the address book functionbased on comprehensive risk control factors. If you choose to disable this permission, it may affect the corresponding risk control verification function.

(5) Get access to the pasteboard

    In the process of using the MODERN MALL service, such as filling in the address and emergency contact information, you need to obtain the pasteboard functionin order to automatically fill in the information. If you choose to disable this permission, it may affect the corresponding risk control verification function.

8. Miscellaneous

(1) If the information you provide contains the personal information of other users, you need to ensure that you have obtained legal authorization before providing such personal information to MODERN MALL.

(2) If we use the information for other purposes not specified in this Policy, or use the information collected for specific purposes for other purposes, or if we actively obtain your personal information from a third party, we will obtain your consent in advance. If we indirectly obtain your information from a third party, we will clearly require the third party to collect personal information after obtaining your consent in accordance with the law before collection, and inform you of the content of the information to be shared, and if the sensitive information is involved, it must be clearly confirmed by you before providing it to us for use, and require the third party to make a commitment to the legality and compliance of the source of the personal information, and if the third party violates the law, we will clearly require the other party to bear the corresponding legal responsibility; At the same time, our professional security team will strengthen the security of personal information (including sensitive information reporting, encrypted storage of sensitive information, access control and so on). We will protect the personal information we have acquired indirectly with the same means and measures as we do for the personal information of our users.

(3) Exceptions to obtaining authorization and consent

You fully understand and agree that we do not need your authorization and consent to collect and use your personal information under the following circumstances, and we may not respond to your requests for correction/amendment, deletion, cancellation, withdrawal of consent, or request for information:

1.Related to national security and national defense security;

2.Related to public safety, public health, or major public interests;

3.Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and judgment enforcement;

4.For the purpose of protecting the life, property and other major legitimate rights and interests of you or other individuals, but it is difficult to obtain the consent of the person;

5.Personal information that you disclose to the public;

6.Personal information is collected from legally and publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels.

7.It is necessary to sign and perform relevant agreements or other written documents with you;

8.It is necessary to maintain the safe and stable operation of the products and/or services provided, such as discovering and disposing of faults of products and/or services;

9.It is necessary for legitimate news reporting;

10.When it is necessary for academic research institutions to carry out statistical or academic research based on the public interest, and when the results of academic research or descriptions are provided to the public, the personal information contained in the results is de-identified;

11.Other circumstances stipulated by laws and regulations.

(4) Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information, so that the data recipient cannot re-identify a specific individual and cannot recover it, or we may conduct de-identification research, statistical analysis and prediction of the collected information for the purpose of improving the content and layout of MODERN MALL, providing product or service support for business decisions, and improving our products and services (including using anonymous data for machine learning or model algorithm training), The use of such processed data does not require further notice to you and your consent.

(5) If we cease to operate the products or services of MODERN MALL, we will stop collecting your personal information in a timely manner, notify you of the notice of cessation of operation in the form of delivery or announcement one by one, and delete or anonymize the personal information we hold related to the closed business.

3. How We Share, Transfer, and Publicly Disclose Your Information

(1) Sharing

We will not share your personal information with companies, organizations and individuals other than MODERN MALL Service Providers, except in the following circumstances:

1. Sharing under statutory circumstances: We may share your personal information externally in accordance with laws and regulations, litigation and dispute resolution needs, or according to the requirements of administrative and judicial authorities in accordance with the law.

2. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

3. Sharing under your active choice: If you purchase or lease goods or services through the MODERN MALL Platform, we will share the necessary information related to the transaction in your order information with the provider of the relevant goods or services according to your choice, so as to realize your transaction and after-sales service needs.

4. Sharing with affiliates: In order to facilitate us to provide you with products and services based on the platform account, recommend information that may be of interest to you, identify abnormalities in member accounts, and protect the personal and property safety of affiliates, other users or the public from infringement, your personal information may be shared with our affiliates and/or their designated service providers. We will only share necessary personal information and be bound by the purposes stated in this Privacy Policy, and if we share your sensitive personal information or our affiliates change the purpose of use and processing of personal information, we will seek your authorization and consent again.

These SDKs include:

l Aurora Push SDK

Purpose of use: To push the latest activities of the platform for users

Type of personal information collected: Device identification information

Collector: iOS/Android

l AutoNavi Map SDK

Purpose of use: Collect your location information, access the network to obtain map services, use storage permissions to save map caches, and apply them to location-related business scenarios, such as: showing you the inventory information around your location, so that you can choose the delivery address, and show you the delivery information.

Type of personal information collected: Type of personal information collected: information about the location of the device (GPS location, WLAN access point, Bluetooth, Wi-Fi information, GNSS, base station and other sensor information), device information (IMEI, IDFA, Android ID, MEID, MAC address, OAID, IMSI, hardware serial number, operating system version information), IP address./strong>

Collector: iOS/Android

l Baidu Maps SDK

Purpose of use: Collect your location information, access the network to obtain map services, use storage permissions to save map caches, and apply them to location-related business scenarios, such as: showing you the inventory information around your location, so that you can choose the delivery address, and show you the delivery information.

Type of personal information collected: Type of personal information collected: information about the location of the device (GPS location, WLAN access point, Bluetooth, Wi-Fi information, GNSS, base station and other sensor information), device information (IMEI, IDFA, Android ID, MEID, MAC address, OAID, IMSI, hardware serial number, operating system version information), IP address.

Collector: iOS/Android

l Baidu liveness detection SDK

Purpose: To help users complete identity authentication.

Type of personal information collected: Device identification information

Collector: iOS/Android

l Umeng SDK

Purpose of use: To identify abnormal conditions of the device.

Type of personal information collected: device type, system version, user usage time, home page address

Collector: iOS/Android

l OKHttp3 SDK

Purpose: To quickly locate faults and performance bottlenecks, optimize code and service efficiency, ensure business stability, and improve user experience.

Type of personal information collected: Device identification information

Collector: iOS/Android

l ANDROID ID

Purpose: To provide statistical analysis services, and to improve performance and user experience through application startup data and abnormal error log analysis, so as to provide users with better services

Type of personal information collected: Unique device identifiers are collected

Collector: iOS/Android

(2) Assignment

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

2. In the event of a merger, acquisition or bankruptcy liquidation of the MODERN MALL Service Provider, or other circumstances involving merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue to be bound by this Policy, otherwise we will require the company, organization and individual to seek your authorization and consent again.

(3) Public disclosure

We will only publicly disclose your personal information in the following circumstances:

1. With your explicit consent or based on your active choice, we may publicly disclose your personal information;

2. If we determine that you have violated laws and regulations or seriously violated the relevant agreements and rules of the MODERN MALL Platform, or in order to protect the personal and property safety of the users or the public of the MODERN MALL Platform from infringement, we may disclose your personal information in accordance with laws and regulations or with your consent, including the relevant violations and the measures that the MODERN MALL Platform has taken against you. For example, if you seriously violate the rules of MODERN MALL by selling counterfeit goods, we may publicly disclose your store certification entity information and violations.

(4) Exceptions to obtaining prior authorization and consent when sharing, transferring, or publicly disclosing personal information

In the following circumstances, sharing, transferring, and publicly disclosing your personal information do not require your prior authorization and consent:

1. Related to national security and national defense security;

2. Related to public safety, public health, or major public interests;

3. Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and judgment enforcement;

4. For the purpose of protecting the life, property and other major legitimate rights and interests of you or other individuals, but it is difficult to obtain the consent of the person;

5. Personal information that you disclose to the public;

6. Personal information is collected from legally and publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels.

Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information, so that the data recipient cannot re-identify a specific individual and cannot recover it, the sharing, transfer and public disclosure of such processed data do not need to notify you separately and obtain your consent.

4. How We Protect Your Information

(1) We have taken reasonable and feasible security measures that comply with industry standards to protect your information and prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information. For example, the exchange of data between your browser and the server is protected by SSL encryption; At the same time, we also provide HTTPS protocol secure browsing method for the website of MODERN MALL; We use encryption technology to improve the security of personal information; We will use trusted protection mechanisms to prevent malicious attacks on personal information; We will put in place access control mechanisms to ensure that only authorized personnel have access to personal information; and we will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

(2) We manage and standardize the storage and use of information by establishing a data classification and grading system, data security management specifications, and data security development specifications.

We have full security controls over data through contact confidentiality agreements, monitoring and auditing mechanisms.

Strengthen security awareness. We also conduct security and privacy training sessions to raise awareness of the importance of protecting information.

(3) We will take reasonable and practicable measures to avoid collecting irrelevant personal information. We will only retain your personal information for the period necessary to achieve the purposes stated in this Policy, unless there are mandatory retention requirements by law, such as the E-Commerce Law of the People's Republic of China requires that the retention time of goods and services information and transaction information shall not be less than three years from the date of completion of the transaction. Our criteria for judging the aforesaid period include:

1. To complete the transaction purposes related to you, maintain the corresponding transactions and business records, and respond to your possible inquiries or complaints;

2. Ensure the safety and quality of the services we provide to you;

3. Whether you agree to a longer retention period;

4. Whether there are other special agreements on the retention period.

After your personal information has been retained beyond the retention period, we will delete or anonymize your personal information as required by applicable law.

(4) The Internet is not an absolutely secure environment, and when using the services of the platform, we strongly recommend that you do not use the communication methods recommended by the platform to send your information. You can connect and share with each other through our services. When you create a communication, transaction or sharing through our services, you can choose the person to communicate, trade or share, as a third party who can see your transaction content, contact information, communication information or shared content.

When using the services of MODERN MALL to conduct online transactions, you will inevitably have to disclose your personal information, such as contact information or contact address, to the counterparty or potential counterparty. Please protect your personal information properly and provide it to others only when necessary. If you find that your personal information, especially your account or password, has been leaked, please contact our customer service immediately, so that we can take corresponding measures according to your application.

Please note that the information you voluntarily share or even publicly share when using our services may involve your or others' personal information or even personal sensitive information. Please be more careful about whether you share or even publicly share relevant information when using our services.

Please use a complex password to help us keep your account secure. We will do our best to ensure the security of any information you send to us. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of information, resulting in damage to your legitimate rights and interests, we will bear corresponding legal responsibilities.

(5) We will update and disclose the relevant content such as security risks and personal information security impact assessment reports from time to time, which you can obtain through the announcement of MODERN MALL.

(6) In the unfortunate event of a personal information security incident, we will inform you of the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, suggestions for you to prevent and reduce risks on your own, and remedial measures for you. We will inform you of the relevant circumstances of the incident by email, letter, telephone, push notification, etc., and if it is difficult to inform the personal information subject one by one, we will take reasonable and effective measures to make an announcement. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

5. How do you manage your information?

 You can access and manage your information in the following ways:

How do you access and manage your own informationDuring your use of MODERN MALL service, in order to make it more convenient for you to access and manage your information, and at the same time protect your right to cancel your account, we have provided you with corresponding operation settings in the client, you can refer to the following guidelines to operate.

(1) To manage your information

1. You can log in to your account through the official website and applet, and log in to your account from the App in "My".

2. If you find that your information is incorrect, you can modify your information by yourself according to the prompts on the page, or you can contact our customer service or request correction through online customer service. For security reasons or in accordance with laws, regulations and regulatory provisions, you need to pass verification before you can modify your account name or bound mobile phone number; You can delete one of your order information and a collection of information.

3. Manage your authorization scopeIf you want to change the authorization scope, you can use the mobile phone permission settings and MODERN MALL "My One Settings. Privacy: Common Privacy Settings" to modify the scope of authorization; It can also be rented through MODERN MALL My → settings→Privacy →Authorization Management/Account Authorization" to remove authorization to share information with third parties. When you cancel your authorization to collect information, we will no longer collect that information; After you cancel your authorization to share information with a third party, we will no longer provide information to that third party in that business scenario.

(2) You can cancel your account through the following paths:

1. MODERN MALL operation path: open the MODERN MALL APP, log in to the MODERN MALL account→ personal center→ settings→ account security→ account cancellation;

2. Call the customer service hotline directly: 077633838 to apply for cancellation. When you can pass the identity verification and meet the agreed account cancellation conditions and cancel your account, all the information in your account will be cleared, and we will no longer collect, use or provide the personal information related to the account, but we still need to keep the information you provide or generate during the use of the MODERN MALL service for the time required by the regulator, and cooperate with the inquiry of the competent authority in accordance with the law during the storage time.

3. If you find that our collection and use of your personal information violates laws and regulations or violates the agreement with you, you can contact our customer service hotline or online customer service to request the deletion of the corresponding information.

4. The user agrees and understands that due to technical limitations, legal or regulatory requirements, we may not be able to meet all the requirements of the user, and we will reply to the user's request within a reasonable period of time.

5. If you find that our collection and use of your personal information violates laws and regulations or violates the agreement with you, you can contact our customer service hotline or request the deletion of the corresponding information through online customer service.  

(3) Inquiry, correction and supplementation of your information

You have the right to inquire, correct or supplement your information. Here's how you can do it yourself:

1. Log in to the mobile phone MODERN MALL client, enter "My - Settings/Personal Information" to query, correct or supplement personal address, nickname and other information;

2. Log in to MODERN MALL and choose to contact customer service, or log in to the mobile MODERN MALL client and select "Contact Customer Service" for help to assist you in querying, correcting or supplementing your information.

(4) Delete your information

You may request us to delete your personal information under the following circumstances:

1. If our processing of personal information violates laws and regulations;

2. If we collect and use your personal information without your explicit consent;

3. If our processing of personal information seriously violates the agreement with you;

4. If you no longer use our products or services, or you voluntarily cancel your account;

5. If we permanently no longer provide you with products or services.

If we decide to respond to your deletion request, we will also notify the subjects who have obtained your personal information from us as far as possible and require them to delete it in a timely manner (unless otherwise provided by laws and regulations, or these subjects have independently obtained your authorization).

When you or we assist you in deleting the relevant information, we may not be able to immediately delete the corresponding information from the backup system due to applicable legal and security technologies, and we will securely store your personal information and isolate it from any further processing until the backup can be erased or anonymized.

(5) Change the scope of your authorization and consent

Each business function requires some basic personal information to complete (see "Part 1" of this Privacy Policy). In addition, you can contact the customer service of MODERN MALL or change the settings of your smart mobile device to give or withdraw your authorization and consent.

Once you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out based on your authorization.

(6) Restrain the automatic decision-making of information systems

In some business functions, we may only make decisions based on non-human automated decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you have the right to request us to make an explanation, and we will also provide a method of appeal on the premise of not infringing on the trade secrets of MODERN MALL or the rights and interests of other users and the public interest.

(7) Respond to your above requests

For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

We will respond within 15 days. If you are not satisfied, you can also file a complaint through the customer service of MODERN MALL.

In principle, we do not charge a fee for your reasonable request, but we will charge a fee at our discretion for repeated requests that exceed a reasonable limit. We may reject requests that are not directly related to your identity, unreasonably repetitive, or that require too many technical means (for example, the need to develop new systems or fundamentally change current practices), pose risks to the legitimate rights and interests of others, or are impractical.

In the following circumstances, we will not be able to respond to your request in accordance with the requirements of laws and regulations: 

1. Related to national security and national defense security;

2. Related to public safety, public health, or major public interests;

3. Related to criminal investigation, prosecution, trial and enforcement of judgments;

4. There is sufficient evidence showing that the Personal Data Subject has subjective malice or abuses rights;

5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

6. Involving trade secrets.

6. How we process the information of minors

The products and services involved in this policy are only intended for use by persons over the age of 18, if you have not reached the above age, please stop using the products and services involved in this policy immediately, close and withdraw from the platform. We will delete your personal information at the request of your guardian or after we have identified your minor, and we also welcome you to use our products and services after you have reached the age of 18.

7. How this Privacy Policy is updated

Our Privacy Policy is subject to change.

Without your explicit consent, we will not limit your rights under this Privacy Policy. We will post any changes to our Privacy Policy on a dedicated page.

For major changes, we will also provide more prominent notices (including we will notify you through the announcement of MODERN MALL and even provide you with pop-up prompts).

The material changes referred to in this Policy include, but are not limited to:

1. Our service model has undergone major changes. Such as the purpose of processing personal information, the types of personal information processed, and the way in which personal information is used;

2. We have undergone significant changes in control and other aspects. Such as changes in information controllers caused by mergers and acquisitions;

3. Changes in the main objects of personal information sharing, transfer or public disclosure;

4. There are significant changes in your rights to participate in the processing of personal information and the way in which you exercise them;

5. Changes in the departments responsible for handling personal information security, contact information and complaint channels;

6. The personal information security impact assessment report indicates that there is a high risk.

We will also archive the previous version of this Privacy Policy on the special page of MODERN MALL for your reference.

 

8. How to contact us

 You can contact us in the following ways:

1. Company name: MODERN DIGITAL LIFE MALL CO., LTD.

2. Office address: Street 92, Khmounh, Sen Sok, Phnom Penh, Cambodia, 120803

3. Official website: https://moderndigitallifemall.com

4. In order to ensure the security of your information, when processing your request, the staff needs to verify your identity and credentials first. We have established a customer complaint management mechanism, including a follow-up process. In general, we will complete the processing within three working days after the verification is passed, and in the case of special events, we will reply within no more than 15 working days or within the time limit stipulated by laws and regulations. If you are not satisfied with our response, you may also file a complaint with the Consumer Protection Department or file a lawsuit with a court of competent jurisdiction.