User Privacy Statement
Shenzhen Tongpinhui Technology Co., Ltd. and its affiliated companies and subsidiaries (collectively referred to as "TPH", "we" or "us") respect your privacy. Our registered address is Room 203, Factory Building 29, Lianchuang Science and Technology Park, No.21 Bulan Road, Xialilang Community, Nanwan Street, Longgang District, Shenzhen. This Privacy Statement describes how personal information (as defined below) provided, collected or shared on the application is processed. It also sets out your options regarding the collection, sharing and use of your personal information. In accordance with the Personal Information Protection Law of the People's Republic of China, Cybersecurity Law of the People's Republic of China, Information Security Technology - Personal Information Security Specification, Provisions on the Scope of Necessary Personal Information for Common Types of Mobile Internet Applications and other relevant laws, regulations and technical specifications, we have drafted the content of this PumpNest User Privacy Statement (hereinafter referred to as this "Privacy Statement"). If you have any objections or questions about the content of this Privacy Statement, you may contact us in accordance with Article 13 "Contact Information" of this Privacy Statement.
Please read the following content carefully to understand how we collect and use your personal information. If you do not agree with the manner of use of personal information as set forth in this Privacy Statement, do not submit your personal information to us. We may modify this Privacy Statement at any time. All changes shall take effect immediately upon posting on the application. Material changes will be posted in a prominent position on the application or notified to you by other means. You understand that we will only collect, use, process and store your personal information in accordance with the revised Privacy Statement after you confirm and agree to the changes.
1. Personal Information We Collect
When you use PumpNest services, we may need to collect and use certain personal information from you. The personal information we collect and use falls into two categories:
When you use PumpNest services, we may need to collect and use certain personal information from you. The personal information we collect and use falls into two categories: 1. Information necessary for the core functions of PumpNest: Such information is essential for the normal operation of PumpNest.
2. Information that may be collected for the additional business functions of PumpNest: Such information is used to support the additional functions you wish to experience in the service. If you refuse to provide such information, specific additional functions will not be available or will not achieve the intended effect, but it will not affect the normal use of PumpNest's core functions.
We need to remind you in particular that, in order to provide you w
We need to remind you in particular that, in order to provide you with more comprehensive services, PumpNest embeds third-party SDKs or similar applications. Therefore, third-party SDKs or similar applications may also collect your personal information. For details, please see Annex 1: Third-Party SDK Directory. Types of personal information we may collect include:
● If you register or log in to an account, you need to provide us with information that identifies your user identity, either alone or in combination, including: username, password, email address and the matching result of the email verification link (email is not mandatory). We collect such information to complete the PumpNest registration process, provide you with continuous and stable services, and protect the security of your account. You should be aware that our collection of such information is based on the relevant requirements of laws and regulations; if you refuse to provide it, you may not be able to register a PumpNest account.
● When you run PumpNest, to meet the requirements of relevant laws, regulations, policies and competent authorities, verify the authenticity of user identity, and ensure the security of the system and services, you are required to complete the matching of the email verification link.
● If you submit feedback on our products, we may collect the type of breast pump, the content of the feedback, photos (optional) and your email address.
● If you set tasks, we may collect the content of your tasks, reminder date and time.
● We may collect your device code to help you remotely control the breast pump and display breast pump data, including pumping mode, usage time, duration of use and pumping volume.
● When browsing our application, your mobile device or browser may share your location data via WiFi and GPS. We will collect this information in accordance with your mobile phone and browser settings.
● Clipboard Information
Type of information: Only read the agreed source identification string (e.g., 7A5FGC) of PumpNest in the clipboard. This string is a random alphanumeric combination containing no personally identifiable information.
Collection scenarios: First launch of the App; entry to the "Registration/Login" page or designated promotion landing page; registration of account information.
Collection purpose: Operational statistics – to identify the conversion effect of registration links from different promotion channels and optimize promotion strategies.
Collection method: Local reading only; no caching or back-transmission of any clipboard content other than the aforementioned agreed string.
Required permissions: This behavior does not apply for any system permissions, nor does it rely on clipboard writing permissions.
2. How We Collect Your Personal Information
● Clipboard Information: Accessed on the local device through system APIs, triggered only after you explicitly agree to the Privacy Statement. If you refuse to agree, we will skip the clipboard reading process without affecting the use of core functions.
3. How We Use Personal Information
To the extent permitted by applicable law, we may use personal information for the following purposes:
● Operate the application, fulfill customer requests and complete purchases, and support our business operations;
● Infer your preferences from the information we collect about you and create a personal profile reflecting your preferences;
● Prevent criminal activities, claims and other legal liabilities;
● Support and personalize our application and advertising delivery;
● Protect the security and integrity of the application;
● Meet our contractual obligations;
● Comply with applicable legal or regulatory requirements and our policies;
● Calculate registration conversion rates based on anonymous channel strings in the clipboard and optimize advertising delivery effects;
● Other legitimate and necessary purposes for collecting personal information.
4. Disclosure of Personal Information
We may disclose your personal information in the following circumstances:
● Disclosure based on legal obligations or security reasons – when we in good faith believe that accessing, using, storing or disclosing personal information is reasonably necessary to (a) meet or comply with any law, regulation, legal process or enforceable government request, (b) enforce or investigate conduct that may violate the Terms of Use, (c) detect, prevent or otherwise address fraud, security or technical issues, (d) support audit and compliance functions, or (e) protect the rights, property or safety of PumpNest, its users or the public from harm.
5. Storage and Retention Period of Personal Information
● Methods and Period of Information Storage
We will store your information in a secure manner, including local storage (e.g., data caching via the APP), databases and server logs. We will only store your personal information for the period necessary to achieve the purpose of the service or under the conditions stipulated by laws and regulations, unless otherwise provided by laws and regulations.
● Geographical Location of Information Storage
Personal information we collect within the territory of the People's Republic of China will be stored in China. If cross-border transmission is required, we will separately request your authorized consent and ensure compliance with the provisions of national laws, regulations and relevant regulatory authorities to provide adequate protection for your personal information.
● Deletion of Information
If PumpNest ceases operations, we will immediately stop collecting your personal information, notify you of the cessation of operations by individual notice or announcement, and delete or anonymize the personal information we hold about you.
Personal information that has been deleted or anonymized cannot be recovered. If we are required by law to continue storing your personal information, such personal information will be stored separately from other types of information.
6. How We Protect Your Personal Information
We use commercially reasonable efforts to protect the confidentiality and security of the personal information we process. However, despite our efforts to store personal information in a secure operating environment, we cannot guarantee the absolute security of personal information during transmission or storage in our systems. In addition, although we strive to ensure the integrity and security of personal information, we cannot guarantee that existing security measures can completely prevent third parties such as hackers from illegally obtaining personal information.
7. Your Choices and Rights
Depending on your place of residence, you may have the following rights in relation to your personal information:
● Right of Access: You have the right to know what personal information we have collected about you and to access such data.
● Right to Data Portability: You have the right to obtain a copy of your information in a portable and easy-to-use format.
● Right to Erasure: You have the right to delete the personal information we have obtained about you, subject to certain exceptions.
● Right to Rectification: You have the right to correct inaccurate personal information.
● Right to Opt-Out: You have the right to opt out of the processing of your information for the following purposes: (i) targeted advertising delivery; (ii) sale of personal information; or (iii) user profile analysis (the analysis that will lead to decisions with legal effect or similar material impact on you).
To exercise any of the above rights, please refer to Section 11 below.
If you withdraw your consent or refuse our processing of your personal information, or choose not to provide specific personal information, we may not be able to provide you with some or all of the services.
8. Protection of Children's Privacy
We do not sell products for purchase by children under the age of 13. We sell baby products for purchase by adults and provide some baby-oriented services. If you are a parent or legal guardian and believe that your child has provided us with their personal information, you may send an email to bruce@tph-tech.com or contact us in accordance with the information listed in Section 12.
9. Links to Third-Party Applications
We assume no responsibility for the operation of any third-party services linked to this application, including the information or content contained therein. We recommend that you verify and make inquiries before disclosing personal information to third parties, as any disclosed personal information will be subject to the third party's privacy statement.
10. Exercising Your Privacy Rights
You will not be subject to any form of discriminatory treatment for exercising the rights set forth in this Privacy Statement. Specifically: we will not refuse to provide you with goods or services, implement differential pricing for you, or reduce the quality level of goods or services provided to you for such reasons.
To exercise any privacy rights granted to you by applicable data protection laws, please submit a request to us by any of the following means:
Identity Verification Requirements: We must verify your identity before processing your request. If initial verification fails, we may request you to provide additional information to complete the verification process. Personal information provided in the request will be used for identity verification purposes only. If you submit a request as an authorized agent of a European consumer, we will also need to verify your agency identity, which may require you to provide a written power of attorney or proof of entrustment.
We will endeavor to respond to requests within the time limit stipulated by applicable law. If an extension of processing time is needed, we will notify you in writing of the reasons and duration of the extension.
We will not charge any fees for normal requests, except for excessive, repetitive or manifestly unfounded requests. If a fee is indeed required, we will explain the basis for the charge and provide a fee estimate before completing your request.
If we are unable to verify your identity and confirm that the personal information is related to you, we will not be able to respond to your request or provide you with the relevant personal information. To the extent permitted or required by law, we may reject certain requests or only satisfy part of a request. For example, if you request the deletion of personal information, we may retain the personal information that is required to be retained by law.
Appeal Mechanism: If you are not satisfied with the processing result of your request and you have the right to appeal in accordance with the law, we will inform you of the specific appeal process in the response to your request.
11. Changes to This Privacy Statement12. Changes to This Privacy Statement
Please note that we may revise or update this Privacy Statement from time to time; please review the content of this statement regularly. In the event of material changes, we will provide you with the updated Privacy Statement. Unless otherwise stated, any changes to this Privacy Statement shall take effect immediately upon posting on the application.
12. Contact Us
If you have any questions about our practices or this Privacy Statement, please contact us at bruce@tph-tech.com.
13. Account Cancellation Channels
If you need to withdraw or change the authorization you have previously agreed to, you may change the scope of authorization for us to continue collecting information by means of deleting information, disabling device functions, canceling your account, etc.
Please be aware that after you withdraw your authorization, we will no longer be able to provide you with the specific functions and/or services corresponding to the withdrawn authorization, but your decision to withdraw authorization will not affect the personal information processing activities carried out previously based on your authorization.
You may apply for canceling your PumpNest account and erasing all your information in PumpNest by the following method:
● Cancellation via customer service: Send an email to bruce@tph-tech.com, and we will complete the verification and processing within 15 working days.
Please be aware and understand that due to the potential value of your account, correcting or deleting personal information, withdrawing personal information authorization, or canceling the account may require you to provide real-name identity information for identity verification. Upon receiving the information, we will respond to your request within 15 working days, and we will delete the aforementioned collected information within 2 working days, unless otherwise provided by laws and regulations.