APUS Locker Privacy Policy

1.Overview

APUS Locker (this “Product”) is a locker application developed, operated and managed by Beijing Qilin Hesheng Network Technology Co.,ltd.(“APUS” “We” or “us”). We fully respect and protect users’ personal privacy. While providing you with quality services, we will collect, use, disclose, store and protect your personal data in accordance with this Privacy Policy (the “Policy”).
We will explain how we process your personal data in this Policy and how you may access and control your personal data.
Please completely read and fully understand this Policy before using this Product. If you have any questions about this Policy, or have any complaints or suggestions, please contact us via the methods as described in this Policy. This policy will help you understand the followings:
How We Collect and Use Your Personal Data
How We Share, Transfer and Disclose Your Personal Data
Process Your Personal Data Using Third Party Services
How We Protect Your Personal Data
How You Access and Control Your Personal Data
How We Process the Minor’s Data
How Your Personal Data Is Transferred Globally
Contact Us
Update of Privacy Policy

2.How We Collect and Use Your Personal Data

We may collect your personal data as follows while we are providing services. These data is critical for us to realize various functions of this Product. We will use these data to help us develop and improve our products to provide better services. We will use your personal data in strict compliance with the purposes set forth in this Policy. We will inform you in advance and obtain your consent before we use these data for any other purposes than set forth in this Policy or we use the personal data collected for specific purposes for other purposes.

2.1.Category and purpose of your personal data we collect

2.1.1.Double-click desktop to lock phone

In order to avoid damaging the power button due to frequent use of phone’s power button to lock the screen, when you use APUS Launcher, you can use APUS locker to double-click the blank of APU Launcher to achieve the purpose of locking phone. To realize this feature, we need to determine if you have an APUS Launcher installed. When you install APUS Launcher, you can normally use the function of double-clicking desktop to lock phone. When you do not install APUS Launcher, we will guide you to download APUS Launcher through a browser application.

2.2.Your personal data we obtain from a third party

For now, we do not obtain your personal data from any third party. If certain services may require your personal data from a third party, we will notify you in advance and obtain your consent.

3.How We Share, Transfer and Disclose Your Personal Data

We will share with or transfer or disclose your personal data to a third party with your consent or explicit instructions. In addition, to improve the quality of our service, we may also share with or transfer or disclose your personal data to a third party under the following circumstances.

3.1.Subsidiary Products

We may share your personal data with our subsidiary products to provide a more consistent experience and better service. We guarantee that our subsidiary products will treat your personal data in accordance with the purposes and requirements shown in this Policy. We will obtain your prior consent again if our subsidiary products wish to use your personal data for purposes other than those set forth in this Policy.

3.2.Affiliated Company

We may share your personal data with our affiliated companies and will ensure their processing of your personal data is in compliance with the purposes and requirements of this Policy. We will obtain your prior consent again if affiliated companies intend to use your personal data for other purposes than set forth in this Policy.

3.3.Third party service provider

We may engage third party service providers to provide specific services. Third party service providers may collect data when providing services, and we will ensure that they follow our instructions, follow the purposes and requirements set out in this policy to process your personal data, and take appropriate confidentiality and security measures to safeguard data security.

3.4 Share of your personal data as required by law

Subject to compliance with this Policy, we may be required to share or disclose your personal data under certain circumstances, such as in accordance with laws and regulations, and compulsory requirements of government orders; to safeguard the legitimate rights and interests of yours, ours, and third parties; and to prevent or deal with fraud, secure or technical problems.

3.5 Change of organization and existing status of our company

For any change of the organization or existing status of our company (such as restructuring, merger or bankruptcy), your personal data may be transferred to the company entity after change or our affiliated company (the “Data Transferee”). The Data Transferee will continue to be bound by this Policy.

4.Process Your Personal Data Using Third Party Services

The Product may contain a hyperlink directing to third party products or services, such as a hyperlink to another website. You may click the hyperlinks in this Product to access third party products or services. Meanwhile, we may also embed third party links in this Product and you may click these links to access or use third party products or services on the interface of this Product. We hereby remind you that when you access or use third party products or services via the above methods whereby your personal data will be obtained by such third party products or services, the privacy policies of such third party products or services will apply to such personal data.

5.How We Store and Protect Your Personal Data

5.1.Security protection of personal data

We are committed to protecting your personal data. We have adopted all possible security technologies and procedures to protect your personal data against unauthorized access, use, revision, damage, destruction or disclosure. These security measures mainly include the following:

a)Your personal data is stored in the computer systems located in a controlled site with security measures such as encryption.

b)Only APUS employees who have the necessity to process relevant data for the purpose of product operation are authorized to access your personal data and such employees are required to comply with strict confidentiality obligations.

c)We are constantly striving to ensure the security of your personal data, and we adopt encryption technologies during data transmission to prevent your information against unauthorized access, use, revision, damage, destruction or disclosure.

d)We are more prudential when we transmit and store special categories of your personal data and adopt encryption technologies and other security measures to ensure data security.

In case of personal data security incident, according to the requirements of relevant laws and regulations, we will promptly inform you via push notification, announcement, etc. the basic situations and possible influence of the security incident, response measures we have taken or will take, suggestions for you regarding self-prevention and risk reduction, remedial measures for you, etc. We will timely deal with system vulnerabilities, cyber-attacks, virus intrusion, and other security risks.

5.2.Personal data storage term

The information whether you have installed APUS Launcher, which we will not save in mobile phone, nor will it upload to the server. We will only read it when necessary functions are implemented.

6.How We Process the Minor’s Data

This Product is not intended for a minor under 16 years old (or equivalent minimum age set by the laws of EU members). We will only process the information of these minors to the extent permitted by law and with the consent of their guardians.
We will implement relevant technical measures and make our best efforts to verify whether the processing of minors’ information has been approved by their guardians. We will try to delete relevant data as soon as possible if we are aware that we have collected the personal data of a minor without the prior consent of their certified guardians.

7.Contact Us

If you have any questions or suggestions about this policy, or you need to exercise your data management power to manage your private data, please feel free to contact us at: locker_plugin_privacy@apusapps.com . If you find any violation of the Policy, please feel free to contact our DPO at: dpo@apusapps.com.

8.Update of Privacy Policy

We reserve the right to revise or modify this Policy. For any update of this Policy, we will send you notice on the interface of this Product to remind you of relevant updates and indicate the updated provisions for your ease of reading. Please do completely read and fully understand the updated Privacy Policy. By continuing to use this Product, you will be deemed to have accepted the updated version of this Policy. We will not reduce your rights under this Policy without your explicit consent.

9.How Your Personal Data Is Transferred Globally

We provide APUS products and services around the world, which means to conduct business globally, your personal data might be transmitted to a jurisdiction or accessed from such jurisdiction outside of the country/region where you use this Product. These jurisdictions include but are not limited to Singapore, United States, and China.
Please note that we only return demographic information to China and we do not include information on individual user identities. At the same time, in order to provide you with better services, our third party partners may transmit your data to other countries. For example, in order to detect robots or cheating, we have purchased a Chinese supplier’s traffic monitoring service. The merchant may return the user information to China in order to assist us in analyzing whether there is cheating in the user.
Personal data protection legislation in such jurisdiction might be different or even absent. Under such circumstance, we will adopt various measures to ensure security of your personal data. For instance, we will ask you for your explicit consent before transmission of your personal data, or implement security measures such as encryption and pseudonymisation during data transmission; when your personal data is transferred to such jurisdictions, we will apply the same protection of your personal data in accordance with the Policy. We will endeavor to protect your personal data with the measures stipulated in Article 46 and Article 47 of the EU General Data Protection Regulation.

Last updated: [May16, 2018]