Promulgation date: 【September 14, 2021】
Effective date of this Version: [9-22-2021]
We will process your questions or feedback within 15 business days.
I. How We Collect and Use Personal Information
III 、 How We May Share, Transfer and Disclose Personal Information
IV 、 How We Retain, Store and Protect Personal Information
V 、 How We Manage Your Personal Information
VI 、 Third-party Services
VII 、 How to Handle Underage Users' Information
VIII 、 Amendments to and Notices of Privacy Policies
IX 、 How to contact us
I. How we collect and use personal information
Personal information refers to all kinds of information recorded in electronic or other forms, which can be used independently or in combination with other information to identify the identity of a particular natural person or reflect the activities of a particular natural person.
1 、 The personal information we collect depends on a variety of factors, such as the specific type of product or service you use, the specific environment in which you use it and the specific way in which you use it, and the privacy settings you make. The personal information we would collect for clear and lawful purposes includes the personal information you provide to us, the personal information generated by your interaction with our products and the information we collect automatically as you use. The personal information collected by us includes the following:
(1) Name and contact information. Includes your mobile phone number, email, work, position, photo, gender, birthday, WeChat, QQ or other personal information. These names, contact information needs to be submitted to us by you, for example: if you are the manager of the mall, login in our robot management platform needs to register an account, you need to submit the above information account registration.
(2) Passwords and vouchers. Includes passwords for Your Account, password prompts, and security information for account verification.
(3) Location information. If you access our services through mobile devices or other networked devices, we may use technical means such as GPS, IP address or Wifi to analyze and determine your location when you use our services.
(4) Your personal information on third-party websites. If you use third-party websites, such as WeChat or QQ, to log in our services, we will collect your account ID (generally a string of anonymous random numbers), nickname, avatar and other information on the third-party platforms in accordance with the rules of such third-party platforms.
(5) Voice information. Our robots support speech recognition. When you interact with our robots, we will collect your voice commands such as searches and queries. These voice commands may sometimes include background sound or other user's voice information.
(6) Image information. Some of our intelligent service robots provide passenger flow statistics, access control, visitor registration and other functions. These robots are generally deployed in shopping malls, stations and other public places as well as the internal office areas of certain enterprises. When you actively interact with robot devices with face recognition, we will collect your photo images and other information. If you are an employee of an enterprise, you are also required to submit your photo information in order to use the face recognition access control function.
(7) Information on interaction and use. We will collect information about how you use our products or how you interact with us, such as pages viewed, functions used, actions performed, time spent online, frequency and duration of use, etc.
(8) Device information. If you access some of our services on a mobile device, such as APP and WeChat applet, we may collect your device information, including device information such as device identifier (such as IMEI number of Android phone), operating system type, version number, system language, IP address, list of applications on the device, available storage space of Bluetooth settings, browser type and information about WLAN access points near the device.
(9) Log information. In order to understand the operation of devices and services and troubleshoot software and hardware failures, we will collect log information of websites and robot hardware, such as browser type, hardware model, hardware serial number, failure timestamp, IP address, pages opened when used at the time of failure and other failure-related software or hardware information.
(10) User feedback. For example, when you contact our business, customer service, operations teams, we will collect the content of the messages you send to us, such as contact information, user feedback, survey data, etc.
2 、 We will collect and use your personal information for the following purposes:
(1) Account registration: we collect name and contact information for platform account registration and login, so as to login and use some of our products or services normally;
(2) Account security identification and anti-fraud: we collect account passwords, credentials and other information and security tips for account security identification and anti-fraud, and protect user account security;
(3) Security patrol: some of our robot hardware products have security patrol, abnormal person monitoring functions, etc., these robots will automatically take photos or videos of the surrounding environment in the process of operation, which may include your image, face recognition information;
(4) Access control and visitor registration: if you are an employee or visitor of an enterprise, you may use the access control and visitor registration functions of robots deployed in the enterprise. We need to collect your name, contact information, face photo and other information for face recognition access control and visitor registration;
(5) Voice search, query and navigation. We will collect your voice information to provide you with intelligent, personalized voice search, query and navigation services;
(6) Business operations analysis: we use information to analyze our business operations, such as traffic statistics, active user statistics, feature acceptance analysis, etc., with which we can make better decisions to improve our products and services;
(7) Product or service development: we use the information collected to develop new products or services. For example, we use de-identified information to better understand the potential functional needs of customers, so as to develop new products or services that may be popular with users;
(8) Software and hardware function analysis and troubleshooting: we will use the information collected, such as hardware information, operating logs, network logs, etc., to analyze the operating status of our products and services, so as to ensure the normal operation of our services;
(9) Customer communication and service: if you are a purchaser or lessee of our intelligent robot products, or an employee or representative of your affiliated company, we will use the contact data collected to communicate with you and solve your problems in using our products;
(10) Aggregate analysis: we will use the collected information for aggregate and regional analysis and research for industry research, public interest, and scientific purposes, and we will take appropriate technical and organizational measures to remove relevant personal identifiers to protect personal privacy.
3 、 Rules on the use of your personal information
(2) After we collect your personal information, we will de-identify the data through technical means. The de-identified information will no longer identify you. Please understand and agree that we shall have the right to use de-identified information in such cases and to analyze and commercially utilize the user database without disclosing your personal information.
(3) Please note that all personal information provided by you through your use of the Products will continue to be licensed for use during the term of your use of the Products, unless deleted by you or refused to be collected by us through a system setting. When you log off your account, we will stop using and delete your personal information.
(4) We maintain usage statistics for our products, and may share these statistics with the public or third parties, in order to demonstrate overall product usage trends. However, these statistics will not contain any personally identifiable information about you.
(5) When we display your personal information, we may use methods such as content replacement and anonymization to desensitize your information to protect your information.
4 、 Tips on Sensitive Personal Information
(1) Cookies are a short piece of text automatically sent by the browser when a user visits a website, usually including an identifier, the name of the website, and some numbers and characters. Generally, each website will generate unique cookies for the user, and the cookies data will be stored on your device. Cookies will help the browser record some of the user's settings and habits when visiting the website, so that when the user visits the website in the future, the user's login steps will be simplified, and the user's visit experience will be optimized. Currently, our official website (en.orionstar.com) uses Google Analytic analytics tools to determine the origin of the website and analyze the website audience through Google Analytic cookies; we also use custom cookies to record your language preference when visiting our website, so that you can be shown the corresponding language directly on your next visit; we also use session cookies to record your communication with our online customer service, etc.
(2) If you want to delete or disable cookies, you can open your browser settings and go to the relevant cookies control and management options. The following are some common browser cookies management methods:
L For other browsers, please contact the developer of the browser to find out how to disable cookies. Please note, however, that disabling cookies may affect your ability to use certain features of our website.
III 、 Personal Information We May Share, Transfer and Disclose
(1) How we share users' personal information.
Sharing is when Orion Star shares your personal information with other independent controllers of personal information. We generally do not share your personal information with third parties, except for the following circumstances:
A) Sharing with your explicit consent. We may share your personal information with third parties in accordance with the contents of your consent, including the type of personal information you have agreed to be shared, the purpose of processing, the recipient, etc.;
B) Sharing with affiliates and internal employees. For the purpose of providing the Products and Services, we may need to share your personal information with our employees, affiliates and specific employees of affiliates. We will strictly limit the scope of such sharing. These employees or affiliates may only access and process certain personal information for the normal purpose of providing the Services to you;
C) Sharing with third party partners. Some of the functions of our Services are provided by our partners. Therefore, some of your personal information may be shared with them in order to ensure the normal provision of the Services by these partners. We will only process your personal information for specific, specific and lawful purposes, and will only disclose the information necessary for the provision of the Services. Neither we nor our third party partners will use your personal information for any purposes that are not related to the Services;
D) Sharing by law or to protect your vital interests. We may share your personal information with third parties as necessary to prevent fraud and to protect our, your, third parties' or the general public's property, property or other material interest, as required by applicable law, for the purpose of litigation or dispute resolution, in response to a subpoena of a judicial authority or to comply with a similar request from any other law enforcement agency, or to prevent fraud and to protect ourselves, your, third parties' or the general public's property;
E) Anonymized and Aggregate Information. We may use specific technological methods to strip away all personally identifiable information from your personal information. Aggregate, anonymized information may be shared with affiliates and non-affiliates for the purpose of analysis and research related to the provision of the Products and Services.
(2) How we transfer personal information
Transfer is the process by which Orion Star transfers the control of your personal information to other independent controllers of personal information. Generally, we will not transfer your personal information to any company, organization or individual, except for the following circumstances:
A) Transfer with your explicit consent. We may transfer your personal information to other parties with your explicit consent.
B) Merger and acquisition, division and bankruptcy of enterprises, etc. In the event of a merger, acquisition, bankruptcy, or other sale of all or part of our assets, the personal information that is in our possession or control concerning you may be transferred to third parties.
(3) How we publicly disclose personal information
A) Public disclosure with your explicit consent.
B) Public disclosure on a legal or equitable basis. We may publicly disclose your personal information when required by applicable law, for the purpose of litigation or dispute resolution, in response to a subpoena of a judicial authority or to comply with a similar request from any other law enforcement agency, or to prevent fraud and to protect our, your, third parties' or the general public's property, property or other material interest, as we in our sole discretion consider urgent, reasonable and necessary to share.
IV 、 How we retain, store and protect personal information
The personal information we collect and generate in the course of our operations in the People's Republic of China is stored in the PRC.
We will take the following measures to protect your information:
(i) Technical measures for data security
We will adopt security precautions in line with industry standards, including establishing reasonable systems, regulations and security technologies to prevent your information from unauthorized access, modification and data damage or loss. Our services employ multiple encryption technologies. For example, on some of our services, we will utilize encrypted transport technologies (such as TLS) to protect your personal information. We employ encryption technologies to encrypt and preserve your personal information, and isolate it with quarantine technologies.
In the use of personal information, such as information presentation or information association computing, we employ multiple data desensitization technologies to enhance the security of information in use. We also employ strict data access control and multi-factor authentication technology to protect information, in order to prevent data from being used in a non-compliant manner.
(II) Other security measures we have adopted to protect personal information.
We manage and standardize the storage and use of information by establishing data security management standards and data security development standards.
We exercise overall data security control through access to information confidentiality agreement, monitoring and auditing mechanism.
We also hold training courses on security and privacy protection to enhance employees' security awareness and awareness of the importance of protecting information.
(III) We only allow our employees and business partners on a need to know basis to access your personal information, and have in place strict access control and monitoring mechanism. We also require all people who may have access to your personal information to comply with relevant confidentiality obligations. Failure to do so may result in legal action or suspension of the relationship with us.
(IV) We take all reasonable and practical measures to ensure that we do not collect unrelated personal information.
(V) The Internet is not an absolutely secure environment, and it is impossible to be certain that email, instant messaging, social software or other services to communicate with other users are fully encrypted. We recommend that you use complex passwords when using such tools and pay attention to the security of your information.
(VI) The Internet is not a 100% secure environment. We will endeavor to ensure or guarantee the security of the personal information you send to us. If our physical, technical or management protective facilities are damaged, resulting in unauthorized access, public disclosure, alteration, or destruction of personal information, resulting in damage to your legitimate rights and interests, we will bear the corresponding legal liability.
(VII) Security Incident Disposal
When communicating with third parties or purchasing goods and services through our products, you will inevitably disclose your information, such as contact information or postal address, to the counterparty or potential counterparty. Please protect your information properly and provide the same to others only when necessary.
In response to the possible risks arising from the disclosure, destruction and loss of personal information, we have established a number of systems, specifying the classification and grading standards of security incidents and security vulnerabilities and the corresponding disposal procedures. We have also established a special emergency response team for security incidents, which, in accordance with the requirements of security incident disposal standards, will initiate security plans for different security incidents, stop loss, analyze, locate, formulate remedial measures, and work together with relevant departments to trace the source and crack down.
Unfortunately, after the occurrence of information security incidents, we will, in accordance with the requirements of laws and regulations, promptly inform you of the following: basic information and possible impact of the security incidents, measures we have taken or will take to deal with the incidents, suggestions for you to prevent and reduce risks on your own, remedial measures, etc. We will also promptly inform you of relevant information of the incidents by mail, letter, telephone, push notification, etc. When it is difficult to inform the information subjects one by one, we will make public announcements in a reasonable and effective manner. In the meantime, in accordance with the requirements of regulatory authorities, we will actively report the disposal of information security incidents.
Please understand that due to the limitation of technology and risk precautions, even if we have tried to strengthen security measures as much as possible, we cannot always guarantee 100% security of information. You should be aware that the systems and communication networks used by you to access Orion Star service may experience problems due to circumstances beyond our control.
Please be sure to keep safe custody of your account number, password and other identification elements. When you use the product, we will use your account number, password and other identification elements to identify you. Once you disclose the above information, you may suffer losses which may be adversely affected. If you find that your account number, password and/or other identification elements may be or have been disclosed, please contact us immediately so that we can take timely and appropriate measures to avoid or reduce related losses.
V 、 How to manage your personal information
In accordance with the requirements of laws and regulations such as the Cyber Security Law and the Provisions on the Protection of Personal Information of Internet Users, as well as with reference to the common practices in other countries and regions, we attach importance to users' autonomy in personal information and have taken multiple measures to ensure that users may exercise the following rights to their personal information:
(1) Access to your personal information:
You have the right to access to your personal information, subject to the exceptions provided by laws and regulations. If you have registered for one of our services, you may search and edit your personal information in the Account Setting Center by logging in to your registered account. If you are unable to manage such personal information in the above manner, you may contact us at [firstname.lastname@example.org].
(2) Correction of your personal information:
If you find that we process the personal information about you incorrectly, you have the right to correct or update the incorrect or incomplete information. If you are unable to do so through the Account Setting Center, you may contact us at [email@example.com].
(3) Delete your personal information.
You may submit a request to us to delete your personal information at [firstname.lastname@example.org] under the following circumstances:
Our processing of your personal information violates mandatory requirements of laws or regulations;
Our collection or processing of your personal information without your consent;
Our collection or processing of your personal information in violation of the agreement with you;
A certain product or service of ours ceases to operate and does not continue to be provided to you;
You no longer use our products or services.
(4) How to cancel an account:
If you use one of our services that requires an account login, you may log in to your previously registered account and choose to cancel your account on the settings page. If you are unable to self-submit a logout request on the account management page, you may contact us at [email@example.com].
VI 、 Third-party products or services
Our products and services may contain websites/links from third parties or access SDKs from third parties (collectively, the "third-party services"). We have set up internal management mechanism and workflow for accessing the third-party services. Prior to accessing the third-party services, we use our best efforts to conduct security assessment on the information security capability of the third-party services. However, we have no actual control or management over the third-party services and cannot provide any express or implied warranty for the compliance of data collection and processing activities in connection with the third-party services. These third-party services act as independent data controllers and process your personal information in accordance with their own privacy policies. You are requested to make independent judgments about your interactions with third parties when using our services and read and understand the privacy policies of such third parties before submitting your personal information to them. We are not responsible for the data collection and processing activities of third parties.
VII 、 How to deal with underage users' information
1 、 We recommend that any underage user obtain prior consent from his/her parent or legal guardian (the "guardian") before participating in online activities. We will protect the relevant information of minors in accordance with the relevant national laws and regulations. If you are a minor under the age of 14, you are requested to notify your guardian and jointly read and accept our "Rules on the Protection of Children's Personal Information and Notice for Guardians", and to seek the prior consent and guidance of your parent or guardian before using Orion Star services and submitting your personal information.
2 、 If we become aware that a minor's personal information has been collected, we will attempt to delete the relevant content as soon as possible without the guardian's prior consent. If the guardian becomes aware that a minor visits or uses our products or services and needs to access, modify or delete personal information related to the minor, please contact us in the manner described in this Section 9.
VIII 、 Amendments to and Notices of Privacy Policies
Material changes in our service model. Personal information to be processed, including the purpose, type and way of using personal information processed, etc.;
2 、 We have had a material change in our ownership structure. For example, changes in owners due to business adjustment, bankruptcy, merger and acquisition;
3 、 The main objects of sharing, transferring or public disclosure of personal information have changed significantly;
4、Material changes in your rights to participate in the processing of personal information and in the way in which you exercise them;
5 、 The departments responsible for handling personal information security, the contact information and the channels for lodging complaints have changed significantly;
6、Other important events or circumstances that may materially affect your rights and interests.
We may issue service-related announcements when necessary (for example, when we suspend a service for system maintenance). You may not be able to cancel these service-related announcements that are not promotional in nature.
IX 、 How to Contact Us
2 、 In principle, we will respond to your request within 15 working days. If you are not satisfied with our response, in particular, our processing of personal information harms your legitimate rights and interests, you may contact us again or report to the competent authorities.
Appendix: Terms and Definitions
(1) Orion Star: Beijing Orion Star Technology Co., Ltd.., the operating party of orionstar.com and its affiliates. Its affiliates include, without limitation, Beijing Kingsoft Security Co., Ltd., Beijing Cheetah Mobile Technology Co., Ltd., etc.
(2) Personal Information: All kinds of information recorded electronically or otherwise, which can identify the identity of a particular natural person or reflect the activities of a particular natural person alone or in combination with other information. The definition of personal information is very broad under the current laws of our country. According to the definition in GB/T 35273 — 2020, Information Security Technology Personal Information Security Specification, the personal information we mainly collect and process includes:
Basic personal information
Personal name, birthday, personal phone number, email address, etc.
Personal biometric information
Personal voiceprint, facial recognition features, etc.
Network identity information
Personal information subject account, social media account, nickname, avatar, IP address, etc.
Personal education job information
Personal occupation, position, employer, etc.
Personal communication information
Communication records and contents, SMS, MMS, email, and data describing personal communications (commonly referred to as metadata), etc.
Address book, friends list, group list, email address list, etc.
Personal Internet access record
User log Stored personal information subject operation record, including website browsing record, software use record, click record, favorite list, etc.
Personal device information
Device model, operating system, unique device identifier (a string of characters programmed into a device by the device manufacturer that can be used to uniquely identify the device)
Personal location information
Including accurate positioning information, longitude and latitude, etc.
Personal biometric information
Voiceprint, facial recognition features
Other personal sensitive information
Communication records and contents, address book, friends list, group list, whereabouts, web browsing record, accurate positioning information, etc.
(4) Personal information subject refers to the natural person identified and associated by personal information, which generally refers to the natural person users of Orion Star products and services, excluding legal persons or other organizations.
(5) Anonymization refers to the process of processing personal information by certain technical means so that the personal information subject cannot be identified or associated, and the processed information cannot be recovered. Personal information that has been anonymized is no longer personal information.
(6) De-identification: refers to the process of processing personal information by certain technical means so as to make it impossible to identify or associate the subject of personal information without the aid of additional information. De-identification personal information generally cannot independently identify and associate the personal information subject, but needs to be stored separately from other information. We will still treat de-identification personal information as personal information.