ThunderSoft takes your personal data privacy seriously. This Privacy Policy explains which information is collected and processed through our website ThunderSoft.com (hereafter “Website”). It applies to personal data obtained by ThunderSoft, ThunderSoft Building, Building No 3, No.9 Qinghua Dong Road, Haidian District, Beijing, China (hereafter “ThunderSoft”, “we” or “us”).

1. Definitions

Our Privacy Policy is based on the definitions of the Personal Information Protection Law of the People's Republic of China (PIPL), including the following definitions:

‘Personal Information’ means various information related to an identified or identifiable natural person recorded electronically or by other means (‘data subject’)  (cf. Art. 4 (1) PIPL).

‘Processing’ includes personal information collection, storage, use, processing, transmission, provision, disclosure and deletion, among others. (cf. Art. 4 (2) PIPL).

‘Processor’ refers to an organization or individual that autonomously determines the purposes and means of personal information processing. (cf. Art. 73 (1) PIPL).

‘Entrusted party’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the processor.

‘Third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data .

‘Consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Processor and Contact Details

The processor processing personal data within the meaning of the PIPL is:

Thunder Software Technology Co.,Ltd.
ThunderSoft Building, Building No 3, No.9 Qinghua Dong Road, Haidian District, Beijing, China (hereafter “ThunderSoft” or “we”, “us”)
biz@thundersoft.com

This Privacy Policy meets our obligations to provide the relevant information in connection with processing your personal data under Art. 17 PIPL.

Should you wish to receive information on your personal data processed by us or to update it, or should you have any questions about data protection on our Website, you are welcome to contact us by e-mail at biz@thundersoft.com or by post at the address above at any time.

3. Processing of your Personal Data

How and how much of your personal data we process depends on whether you contact us via our Website, provide us with information about participants applying for a conference, register for our Newsletter or merely use our Website for information purposes. You may exercise your rights in respect of the personal data processing described below at any time (see section 7 below).

3.1. Collecting Personal Data with your Assistance

When you use this Website, we collect and store your personal data if you provide it of your own accord, e.g. when you register for our Newsletter, applying for a conference or contact us via contact form. You are always free to decide whether to let us have your personal data for the purposes concerned.

3.1.1. Enquiries via e-mail

If you contact us by e-mail, we store your e-mail address and any personal content which the message contains to be able to process your enquiry.

If your enquiry is product-related, e.g. concerns matters about products or orders, complaints, contract and supplier research, etc., we process your personal data to set up or implement contractual relations (Art. 13 (2) PIPL).

Due to administrative reasons, it may be necessary for us in view of the nature of your request and the country in which you are located, to forward your request and your personal data to the relevant department of another group company or a sales partner of ours. The forwarding is to be able to answer your inquiry in the best possible way. For additional information regarding the transfer of personal data to third parties, see section 4.1.
We will delete the personal data concerned once there is no further purpose in keeping it. You may also exercise your rights regarding the processing of your personal data at any time (see section 7 below).

3.1.2. Enquiries via Contact/ Request Form

If you contact us via our contact form or request form( Especially when you providing information in order to participate in a meeting), we collect and store the personal data you enter in the fields concerned. This may include (depending on the specific contact or request form) in particular:

·First and Last Name*

·E-mail-address*

·Mobile Phone Number

·Company Name*

·Job-title

·Country*

·Request Topic*

·Message/ Purpose*

Details marked * are mandatory fields without which we cannot process your enquiry or arrange the participation process for you.

We only use this personal data to process your enquiry / request and save it in case that there are any follow-up questions. To answer your queries, we may forward them to our company’s internal contact concerned. This also applies in case your enquiry or request is product related, Art. 13 (2) PIPL).

Due to the nature of your request and the country in which you are located, it may be necessary for us to forward your request to the relevant department of another group company or a sales partner of ours for administrative purposes. The forwarding is based on our legitimate interest in being able to answer your inquiry in the best possible way. For additional information regarding the transfer of data to third parties see section 4.1.

We will delete the personal data concerned once there is no further purpose in keeping it. You may also exercise your rights when it comes to processing the personal data at any time (see section 7 below).

3.1.3. Newsletter

3.1.3.1. SUBSCRIBING TO OUR NEWSLETTER

ThunderSoft’s Website offers a newsletter, which informs you about our products, services and campaigns. You can subscribe to this newsletter by ticking a checkbox and confirming with the “Send message button” or “Subscribe button” which reads as follows:

Newsletter Declaration of Consent

I have read the Privacy Policy and I consent to my personal data being processed in accordance with section 3.1.3 of the Privacy Policy so that the newsletter can be sent to me. My consent is voluntary and can be revoked at any time.

If you order our newsletter and consent to your personal data being processed in accordance with Art. 13 (1) PIPL), we will process your personal data as follows:

When you subscribe to the newsletter, we store your e-mail address, your first name and surname. We use this data for internal statistical purposes and for further tailoring our newsletter’s content for you.

Once you subscribe to the newsletter, we will send you an e-mail to your e-mail address, which you provided, where you will find a link to follow in case you subscribed to our newsletter by mistake or changed your mind. If you follow the link, we will automatically cancel your subscription.

3.1.3.2. UNSUBSCRIBING TO THE NEWSLETTER

If you no longer wish to receive our newsletter, you may at any time revoke the underlying consent (Art. 15 PIPL) and thus unsubscribe. To do so, click on the respective link contained in each newsletter. You will then be guided through the unsubscribe process. Alternatively, you may also send us your objection to receiving the newsletter by e-mail to biz@thundersoft.com.

3.2. Collection of Personal Data without your Involvement

We record and use personal data, which is generated automatically when you visit our Website to provide our services.

3.2.1. Logfiles and (session) cookies

If and when you visit our Website, our servers will record your personal data temporarily in logfiles as follows:

·Your computer IP address

·The client’s file request (filename and URL)

·http status code

·The website you are visiting us from

We process your personal data in discovering abuse (spam, viruses etc.) and detecting and correcting problems.

At a number of points, our Website also uses ‘cookies’ to make our products more user-friendly and effective. Cookies are little text files which aim at putting our Website on your computer and/or other Internet-capable devices like tablets or smartphones. If your browser settings accept cookies, your browser will add this text in a little file.

The cookies we use are necessary for our Website to work and perform unless this Privacy Policy provides otherwise. There are two different kinds of cookies, which we may use: ‘session cookies’ and ‘persistent cookies’. Session cookies are temporary and stay on your device until you leave our Website again, while persistent cookies remain on your device or until you delete them manually, even once you leave our Website. (How long a cookie remains on your device depends on how long it’s ‘lifetime’ is.). We use the information in the cookies solely to offer you the services and functions you want.

Cookies themselves do not damage your computer, and do not contain any viruses. You can set your browser so these cookies cannot be saved in the first place or are deleted when your Internet session ends, but, please, remember that in that case you may not be able to use all functionalities of our Website.

3.2.2. Google Tracking Tools

Our Website uses tracking and marketing tools of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

If you are resident in the European Economic Area, Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) is the controller for your personal data.

If you expressly consent to the processing of your personal date as described in sections 3.2.2.1 – 3.2.2.2 (Art. 13 (1) PIPL), Google will generate the information its services require using cookies. The personal data is normally sent to one of Google’s servers in the USA and saved there. Google assures that they will comply with the specific legal framework related to data transfer

There are a number of ways in which you may stop cookies being used, such as:

·By setting your browser software accordingly; in particular, by suppressing third party cookies, you will not receive any third party ads. But, please, note you may then not be able to use all the functionalities we offer in full;

·By installing the plug-in which Google provides at https://www.google.com/settings/ads/plugin;

·By deactivating the interest-related ads of providers who belong to the About Ads campaign via http://www.aboutads.info/choices. Please note: This setting will be deleted when you delete your cookies.

If you use different browsers/peripherals to use our Website, you must repeat these steps with all the browsers and devices you use.

3.2.2.1. GOOGLE UNIVERSAL ANALYTICS

We use Google Universal Analytics on our Website. Google Universal Analytics saves cookies in your web browser for up to two years since you last visit and records the personal data below amongst others when you visit our Website, sends it to one of Google’s servers in the USA and saves it there:

·Browser type/version

·The operating system you are using

·Referrer URL (last site you visited)

·Accessing computer’s host name (IP address)

·Time server request made

·Achieving ‘website targets’ (e.g. contact requests)

·What you do on sites (e.g. clicks, scrolling and dwell time)

·Roughly where you are (city, state)

·Technical information like browsers, Internet providers, terminal and screen resolution

·Where you came from (i.e. via what website and/or ad you contacted us).

Google Analytics does not merge the IP address, which your browser sent, with any other personal data. We have also extended Google Analytics on our Website to include the code ‘anonymiseIP’. This guarantees that your IP address will be marked. Only in exceptional cases, will the full IP be sent to one of Google’s servers in the USA and abbreviated there.

The cookies which Google Analytics uses also contain a randomly generated user ID by which you can be recognised when you visit websites in future. The information the cookies generate is saved along with the randomly generated user ID, which makes it possible to analyse pseudo user profiles. This user-related personal data is automatically deleted after 14 months. Other data remains saved in aggregated form indefinitely.

Google Analytics uses the information obtained by using cookies to analyse how you use our Website, compile Website activity reports and provide us with Website usage and Internet-related services, so we can improve our offer and design it to be more interesting for you as the user. We also get information on how our site is working, such as detecting navigation problems.

Google Analytics may also use the information obtained for its own purposes, which is why we do not use Google’s services on our Website, unless you explicitly consent to thereto when processing your personal data (see Art. 13 (1) PIPL). You may of course withdraw your consent at any time as stated in this section 3.2.2.

To find out more about personal data protection when using Google Analytics, please, go to https://support.google.com/analytics/answer/2838718?hl=de&ref_topic=6010376. To find out more about protecting your personal data when using Google services, you can also visit:
https://marketingplatform.google.com/about/analytics/terms/us
https://policies.google.com

3.2.2.2. GOOGLE TAG MANAGER

This Website uses Google Tag Manager, a solution we use to manage website tags via an interface. The tool itself (which implements the tags) is a cookie-less domain and does not record any personal data. The tool serves to trigger other tags, such as Google Analytics (cf. section 3.2.2.1 above) which record personal data themselves in some cases. Google Tag Manager does not access this personal data. If you deactivate at domain or cookie level, these continue for all tracking tags implemented using Google Tag Manager.

4. Disclosure of Information to Other Third Parties

In addition to the third parties described above, such as our group companies and with which we share personal data in connection with the Website tools and features, we may also have to share personal data with other third parties in strict compliance with applicable data protection laws.

4.1. Disclosure to External Service Providers

We may have to allow external service providers to access personal data (particularly IT service providers, sales partners and group companies), when requiring support and design services for our online profile and Website.

In such case, we will ensure that the transfer of your personal data will occur in full compliance with data protection laws (e. g. by signing DPAs in accordance with Art. 38 PIPL).

·For content design and development of the Website:
Your personal data will be sent to [Please enter name and address of the agency as well as a link to their privacy policy]

Drawing on professional suppliers of such services is expressly provided for by law and serves our legitimate interest in being able to professionalize what we offer you and offer it commercially rationally. We remain fully responsible for protecting your personal data.

·For marketing and administrative purposes:
Some of our group companies and sales partners are located outside the People’s Republic of China, including our subsidiaries located in Europe and the United States, which will have access to our marketing data to the extent require.

4.2. Statutory Disclosure

In addition, we reserve the right to disclose your personal data to third parties, if the law, public authorities, such as fiscal or administrative authorities, or criminal prosecution authorities require us to do so. We do not disclose any personal data to third parties otherwise.

5. Location of Data Processing and Data Security

Your personal data is processed mainly in Beijing, China and we will store your personal data in locked facilities and behind firewalls: it is not transferred outside the People’s Republic of China, unless it is necessary to provide services to you as defined in Art. 13 (2) PIPL. Working on this basis, personal data recorded on our Website may be transferred to the United States (to Google,, for instance).

We protect personal data by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. We use appropriate technical and organizational means to secure personal data from inappropriate access, accidental or unlawful destruction, amendment, distribution and transfer, and other unlawful processing. We concluded agreements in line with Art. 21 PIPL if we use contract processing.

6. Storage Time

We only retain personal data as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal or official requirements.

7. What are your Rights?

Right to be informed: You as a data subject may demand at any time that we inform you without charge how much of your personal data we save, where it comes from, whom we send it to and for what purpose we store it (Art. 17 PIPL). To exercise your right to information, you may contact any member of ThunderSoft’s staff.

Right to personal data portability: The data subject may request to receive your personal data, which you provided to us, in a structured, commonly used machine-readable format and to transmit those data to another controller (Art. 45 PIPL), provided (i) you consent to its being processed under Art. 13 (1) PIPL or Art. 29 PIPL or is based on a contract under Art. 13 (2) PIPL and (ii) the processing is carried out by automated means.

Right to rectification: The data subject shall have the right to obtain from the controller without undue delay the rectification of personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement (Art. 46 PIPL).

Right to erasure: The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without delay and the controller shall have the obligation to erase personal data without due delay where one of the following grounds applies (Art. 47 PIPL): (1) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (2) the data subject withdraws consent on which the processing is based according to point (a) of Article 13 (1), or of Article 29 (2), and where there is no other legal ground for the processing; (3) the data subject objects to the processing pursuant to Article 24 and there are no overriding legitimate grounds for the processing; (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Chinese law to which the controller is subject.

Right to object: The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (4),(5),(6) or (7) of Art. 13, including profiling based on those provisions (Art. 24 PIPL).

If you as data subject object, we will not process the personal data concerned any more, unless we can show overriding legitimate grounds for processing it, which outweigh the data subject’s interests, rights and freedoms or processing serves to assert, exercise or defend claims in law. If we process personal data to engage in direct advertising, the data subject has the right to object to that personal data being processed for the purposes of such advertising at any time.

Right to withdraw consent under data processing law: The data subject shall have the right to withdraw his or her consent at any time (Art. 15 PIPL).

If you assert your rights as a data subject against us, we will examine it and uphold it unless the law requires otherwise, and notify you of the outcome.

As a data subject, you do not have to observe any particular formalities to claim your rights to complain to a supervisory authority. If you want to exercise, your rights stated above, please, contact us at biz@thundersoft.com, for example or use the contact details on our Website.

8. Changes to this Privacy Policy

ThunderSoft reserves the right to make changes or updates to this Privacy Policy at any time by giving notice on this page. You are strongly recommended to check this page often, noting the date of the last modification listed at the bottom.