Privacy Policy
Last updated: March 30, 2023
Effective date: March 30, 2023
Thank you for using APPs developed by TOPDON. We take your privacy very seriously and appreciate your trust and confidence in us. We set out a Privacy Policy (the "Policy") to inform you of how this APP will collect, use, and store your personal information, and what rights you have in relation to your personal information. Before using the APP, please read, understand and accept this Policy.
It is important you read carefully and fully understand the terms in this Policy, especially those relating to exemption or limitation of liability, which may be highlighted in bold and require your special attention. Unless you have read and accepted all terms specified in this Policy, you may not download, install or use this APP.
This Privacy Policy applies to the APP and related Services and does not apply to the products or services provided by any other third parties through the APP (hereinafter referred to as "third-party services"). You should fully understand the third-party services and their privacy policy before granting your consent to use them.
You acknowledge and agree that we share your personal information within the TOPDON group of companies (these related companies include but are not limited to Hunan Lianke Technology Co., Ltd, Shenzhen Lianke Technology Co., Ltd, TOPDON TECHNOLOGY Co., Ltd., TOPDON USA INC.). Please note that TOPDON’s products have their own region-specific privacy policies, which are separate from this Privacy Policy. For users in North America, TOPDON USA INC. is the contracting party while for users in mainland China and all other countries and regions, TOPDON TECHNOLOGY Co., Ltd. is the contracting party.
This Privacy Policy helps you understand:
1. How We Collect Your Personal Information
2. How We Use Your Personal Information
3. How We Store Your Personal Information
4. How We Share, Transfer and Disclose Your Personal Information
5. Third-party Service Providers and Services
6. Applicable Scope of This Policy
7. Amendments and Updates
8. Miscellaneous
9. Contact
1. How We Collect Your Personal Information
We will act in compliance with the laws and regulations applicable, follow the principles of lawfulness, fairness, necessity, and good faith, and only collect necessary personal information as follows to provide related services:
1.1. Registration Information at the Time of Creating an Account
You need to create an account at your first use of this APP. When you register an account and set the password, you may need to provide: email, mobile number. Failure to provide such information may cause your inability to use our services normally. If you are only browsing through or conducting searches within the APP, you have the right to choose whether or not to register or provide the information we have requested.
1.2. Information Necessary for Providing the Services
In order to enable you to access our product features and services, we will collect and use certain personal information that you provide to us or that is generated during your using of the services. The following are some examples:
1.2.1 Device-related Information
Based on device model and granted authorization during your installation and using of this APP, we may collect and use device-related information, such as the device serial number, software version, hardware version, device current time, MAC address, etc.
1.2.2 Data Information
Based on device model and granted authorization during your installation and using of this APP, we may collect and use device-related information :
1.2.2.1 Diagnostic data information
including the data stream, fault code, VIN, vehicle brand, vehicle model, year, engine, etc.
1.2.2.2 Car-Key data information
including the vehicle key type, etc.
1.2 Data for Personalized Services and Content
In order to display or recommend more relevant (rather than general push) content or advertisements to you, we will collect your browsing and usage records when you use our products and/or services or related products and/or services are running in the background , device information (device model, MAC address, operating system, network environment, network operator of the device, IP address, log information, etc.); please note that the aforementioned separate types of information are information that cannot identify a specific natural person. If we can identify a specific natural person after combining such information with other information, such information will be regarded as personal information during the combined use period. Unless otherwise authorized by you or stipulated by laws and regulations, we will Anonymize and de-identify such information. According to the requirements of laws and regulations, we follow the principles of legality, justice, necessity and integrity, and only collect personal information necessary to realize product functions.
2. How We Use Your Personal Information
As permitted by applicable laws and regulations, and in accordance with this Policy, we use the collected personal information for the following purposes:
2.1 Development and Improvement of Services and Contents, and Data Analysis
To improve the products and services we provide to you, we may conduct statistics and analysis of product usage, and perform necessary operations and analysis such as running some functionalities, evaluating, maintaining and improving product features, developing new products or services, offering customer support, etc. Provided such information does not reasonably identify you.
2.2 Implementing and Maintaining Security Safeguards
For the purpose of ensuring security safeguards of your account, we may execute and improve our safety programs, including detecting, deterring, and resolving fraudulent use of, or abuse of our services, other harmful or illegal activities, and technical difficulties.
2.3 Sending Notices
From time to time, we may use your contact information (such as your email address, mobile phone number, etc.) to send important notices, such as notices about the upcoming changes or improvements to this APP.
2.4 As Required by Applicable Laws and Regulations
As required by applicable laws and regulations, we may collect and use your personal information without seeking your consent if:
2.4.1 The information is required for the fulfillment of obligations imposed by laws and regulations;
2.4.2 The information is necessary for responding to public health emergency, or protecting your life and property in case of emergency;
2.4.3 The information is being processed reasonably, in the public interest, for news reports and public opinion supervision, etc.;
2.4.4 The information has been made publicly available by yourself or by other public channels (processing of such information will be based on reasonable grounds);
2.4.5 The disclosure is based on laws and administrative laws and regulations.
3 How We Store Your Personal Information
3.1 How Long We Store Your Information
(1) In general, we retain your personal information for as long as your use of the APP.
(2) After you delete personal information or cancel your account on your own, we will delete information or anonymize your personal information according to applicable laws and regulations after retaining such information for a required period of time.
A. If we receive a request from the People's Procuratorates, the public security organs, and the state security organs for cooperation on investigating user’s illegal or criminal behaviors in the use of our services, or if there is imminent danger to someone’s life or property, we may encrypt, isolate, and/or store personal data (even if the data were deleted or the account was cancelled) for statute of limitations prescribed by the Criminal Law.
B. We retain your data (including your illegal records, default records, and credit records) permanently if there are serious violations of laws and regulations, this Policy, our internal rules, etc. during your use of our services.
C. Except for specific information providing an independent privacy policy, we will use your personal information strictly in accordance with this Policy.
3.2 Where We Store Your Personal Information
(1) We have and maintain servers in different areas in the world. Servers used to process your information may not be located in your country/region. Data protection laws and strength of power invested in such laws vary with countries/regions. No matter where the server that processes your information locates, protection measures adopted will be the same as specified in this Policy. Besides, we will also abide by certain laws and regulations related to data transmission.
(2) Upon receiving any formal written complaint, we will contact with the complaining party, and work with appropriate supervisory institute (including local data protection institutes) to resolve complaints relating to the transfer of your data which cannot be settled directly by us with you.
3.3 How We Protect Your Personal Information
(1) We will apply a variety of security technologies and procedures to establish a sound management system to protect your personal information from leakage and damage and to avoid unauthorized access, use, or disclosure.
(2) We will take the following technical measures to protect your personal information:
A. Users’ sensitive personal information will be encrypted and stored on our server through data isolation technology.
B. An encryption protocol is used during data transmission.
C. We will put in place a system to strictly control sensitive data access, including authorization application and permit.
D. We will have a data security monitoring and auditing system for comprehensive data security control.
3.4 Termination of Services
In the event that we discontinue providing our products or services, we will notify you of such change by sending a notification, posting an announcement, or other means, delete or anonymize your personal information within a reasonable period, and cease to collect your personal information, and we will also close the service port for third-party applications to ensure that no third parties can collect and use your personal information.
4. How We Share, Transfer and Disclose Your Personal Information
TOPDON may not disclose your personal information to any third parties except under the following circumstances:
4.1 With Your Express Consent
We may disclose your personal data after having obtained your express consent, clearly informed you of the type of information and the purpose of providing such information, and that such disclosure is in compliance with the requirements of relevant laws and regulations.
4.2 With TOPDON-affiliated Companies
We may share your personal data with TOPDON affiliates and subsidiaries, and we will require them to process such data in accordance with our statement, terms stated in this Policy and other relevant confidential and security measures. However, we will take strict technical measures to ensure the security of your personal information.
4.3 With Authorized Third-party Partners
To ensure the operation of the APP and related services, and provide you more services and features, we may invoke software development kits (SDKs) or other software provided by authorized third parties as necessary. We will perform strict security checks on the purpose and methods of these third parties’ using of your personal information. Unless otherwise authorized by you, or as otherwise specified by laws and regulations, the operator of such third-party may not use your personal information for any other purpose.
We may share, transfer, or make public your personal information as required by applicable laws and regulations without requesting your consent, if:
(1) The information is required for us to fulfill our obligations imposed by laws and regulations;
(2) The information is directly related to national security or national defense;
(3) The information is directly related to public safety, public health, and major public interests;
(4) The information is directly related to a criminal investigation, prosecution, trial, or execution of judicial decisions;
(5) The collection and use of your information are necessary to protect your or other individuals' legitimate rights and interests, life safety, and property safety, and your authorization for collecting such information cannot be obtained for some reason;
(6) The information has been made public by yourself;
(7) The information has been made publicly available in legitimate news coverage, governmental announcements, and other public channels.
5. Third-party Technologies and Services
In order to ensure the stable operation of the APP or realize related functions, we may access the software development kit (SDK) provided by the third party to achieve the aforementioned purpose. We will fulfill our duty of prudence and conduct strict security monitoring on the software tool development kit (SDK) used by partners to obtain information to protect data security.
The third-party SDK we access mainly serves the needs of you and other users, so we may adjust the third-party SDK we access when meeting new service requirements and business function changes. We will disclose to you the latest status of accessing the third-party SDK in this note in a timely manner.
6. Applicable Scope of This Policy
The products and services that this Policy applies to are provided by TOPDON TECHNOLOGY Co., Ltd.
It is important to note that this Privacy Policy does not apply to services provided to you by other third parties. Your use of these products or services provided by third parties is subject to the third-party privacy policy. We encourage you to carefully review the privacy policies of any third parties you access before submitting any personal information.
7. Amendments and Updates
This Policy may be updated, revised, amended, or modified as appropriate based on changes in the functions/services of this APP or changes in the processing of information.
In the event of any updates, changes, or amendments to any provisions in this Policy, we will provide you with the changed Policy by pushing a notification, showing a pop-up, or other means. If we make any material changes to this Privacy Policy in accordance with applicable laws and regulations, we will notify you through appropriate channels and re-obtain your explicit consent.
The above-mentioned material changes include but are not limited to:
(1) Significant changes occurred in our service model, such as the purpose and types of processing personal information, the way personal information is used, etc.;
(2) Significant changes occurred in TOPDON’s ownership structure, organization structure, etc., such as ownership change resulted from business adjustment, bankruptcy, and merger and acquisition;
(3) Changes of the subjects to whom your information is provided, transferred, or publicly disclosed;
(4) Material changes to your rights to process personal information and the way they are exercised.
8. Miscellaneous
(1) This Policy will be implemented in accordance with the Personal Information Protection Law of the People's Republic of China and the Cybersecurity Law of the People's Republic of China. and other relevant local laws and regulations.
(2) Where any provision of this Policy becomes invalid or unenforceable for whatever reason, the remaining provisions shall remain in force and binding.
9. Contact
If you have any questions, complaints, or suggestions about this Privacy Policy or the use of your personal information, please contact us in any of the following ways:
(1) Contact us through [www.topdon.com], or,
(2) Send your feedback to:
(a) Mainland China
Tel: 86-755-21612590
Email: support@topdon.com
Address: Unit 2005 20/F, No.3040 Xinghai Avenue, Qianhai Shimao Tower, Qianhai Shenzhen-Hong Kong Cooperation Zone, Shenzhen, P.R. China
Postcode: 518000
(b) North America
Tel: 1-833-629-4832
Email: support@topdon.com
Address: TOPDON USA INC., 400 Commons Way, Suite A Rockaway, New Jersey 07866
We will review your feedback as soon as possible, and respond to you within fifteen business days upon receipt of your feedback.
TOPDON USA INC.