Privacy

Privacy Policy

Last Updated: July 31th,2023

MGI Tech Co., Ltd. and its wholly owned or controlled subsidiaries (hereafter collectively referred to as "MGI", "us", "we", or "our") are committed to protecting your privacy. When you interact with us, we may collect and use your relevant information. As a global enterprise, we will adopt corresponding safeguard measures according to applicable laws and regulations with our best efforts to keep your personal information safe and under control.

This Privacy Policy (hereafter referred to as "this Policy") applies when you use our official website (e.g., https://www.mgi-tech.com, hereafter referred to as "Official Website" or "Website"), or when you interact with us, we collect your personal information via online channel (all kinds of channels including website, WeChat Official Account and applications) or offline channel (all scenarios including exhibition, meeting, training, visits, and phone call). When appropriate, we may also provide you with separate privacy policy or statement to inform you about how we collect and process your personal information under certain specific circumstances (e.g., when we provide specific products or services). If any conflicts or discrepancies incur between those separate privacy policies or statements with this Policy, in principle, those separate privacy policies or statements will prevail, unless otherwise stated or agreed.

Please pay attention on the terms marked in bold to ensure that you fully understand and agree to this Privacy Policy before using this Website or interacting with us. If you are re-directed to this Website from a third-party website or you visit third-party websites through this Website and accept services provided by them, we are not responsible for the commitments offered by privacy policies from third-party websites. Please note that, we do not have the control over the product or services offered by third parties or personal information processed by them. This Policy does not apply to the personal information protection issues arising from the products or services provided by third parties, nor apply to any information that you voluntarily provide to third parties, so we suggest you to read the privacy policy of third parties or contact that third party to get details regarding their privacy policy. If you find any risks from third-party developed websites or applications, we suggest you to cease from taking related actions to protect your legitimate rights and interests.

I. How We Collect and Process Your Personal Information

1  Definition

In this Policy, "personal information" refers to various information related to an identified or identifiable natural person, excluding anonymized information. "Sensitive personal information" refers to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership genetic data, biometric data uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

2  How We Collect Your Personal Information

1)  Information that you proactively provide to us

a. Contact information: If you need to consult us regarding MGI product or service, get to know about potential opportunities for business cooperation, purchase and receive MGI products and services, provide feedback to our product, service, performance of order or problems in the cooperation, join online or offline seminar, exhibition, forum, competition and other marketing or promotional activities, visit our offices, and interact with MGI by other means, we may require you to provide your personal information and the information of your company (such as your name, email address, phone or cellphone number, address, institution or company, position or function, products of interest, field of interest) for us to confirm your identity, provide your required service and information, handle your feedback, or respond to your request appropriately by other means.

b. Payment information: In connection with transaction, you may also need to provide us with your payment information, such as receiving bank and its address, bank account number, SWIFT CODE, payee's address and other related verification data.

c. Employment application information: If you look for job opportunities from us, you may click "Join Us" or other interfaces with similar functions and provide your contact information, the curriculum vitae or other information for application.

2)  Information that automatically collected when you use our Website or other services

In order to fulfill our cybersecurity related legal obligations and to enhance your user experience and security when using our products or services, we may automatically collect data such as your device type, IP address and browsing history on our Website when you use the Website and other services.

3)  Information collected from third-party partners of MGI

Where permitted by applicable law, we may obtain information generated or shared by you from third parties or public sources in connection with your use of third-party partner services. For example, you may authorize a third-party account to login and use our service, or authorize to import your account, nickname or other information from third-party platform. We will use your personal information in accordance with our agreement with the third party and subject to relevant laws and regulations.

3  How We Process Your Personal Information

1)  Our purposes of processing your personal information and the legal basis for such processing:

a. To enable you or your company to know about the online and offline services we provide from time to time, e.g., providing news on your interested products, based on the consent provided by you, and/or where such processing is necessary for our legitimate interest in promoting our products and services;

b. To respond to your or your company's needs or enquiries, where such processing is necessary for your interest, our legitimate interest in responding to requests about our products or services and/or performance of a contract, including taking steps prior to entering into a contract;

c. To contact you about products, services or events that may be of interest to you or your company and to obtain feedback from you or your company, based on the consent provided by you, and/or where such processing is necessary for our legitimate interest in promoting our products and services;

d. To create and update account, order, and transaction information for you or your company where such processing is necessary for performance of a contract, including taking steps prior to entering into a contract;

e. To communicate and sign contracts with you or your company where such processing is necessary for performance of a contract, including taking steps prior to entering into a contract;

f. To fulfil contractual obligations to you or your company where such processing is necessary for the performance of a contract;

g. To provide the requested services, information or product support where such processing is necessary for performance of a contract;

h. To comply with applicable statutory obligations where such processing is necessary for our compliance with a legal obligation;

i. To conduct financial and other necessary compliance reviews where such processing is necessary for our compliance with a legal obligation;

j. For analytical activities to improve the quality of our products and services, based on the consent provided by you;

k. For handling and responding to complaints, where such processing is necessary for your interest, and/or our legitimate interest in handling and responding to complaints about our products or services;

l. For recording, tracing our products or services, or managing our Website where such processing is necessary for our compliance with a legal obligation;

m. For human resource management where such processing is necessary for our compliance with a legal obligation, and/or performance of a contract, including taking steps prior to entering into a contract.

2)  Communication for Promotion

We may use your email, transaction history, products of interest and other information to promote our newsletters, products or services to you. If you do not wish to receive promotions from us, or other emails not related to information necessary for your transaction such as your order, account, billing, etc., you may opt out of receiving such messages without any negative impact on your relationship with MGI by following the opt-out method provided in the email. In addition, we reserve the right to contact you if necessary, including in the case of legal requests, order tracking, billing updates, service-related account creation, product upgrade changes, product recalls, etc.

3)  You acknowledge and agree in the following situations we do not need to obtain your consent to process your personal information:

a. Where it is necessary to respond to a public health emergency, or in an emergency, to protect your life, health and property and that of other people;

b. Where it is necessary for the performance of our statutory duties or obligations;

c. When we conduct news reports, public opinion supervision and other acts for the public interest, and process personal information within a reasonable scope;

d. When we process personal information that you have disclosed or that has been legally disclosed within a reasonable range in accordance with applicable laws;

e. Where it is necessary to enter into and perform a contract to which you are a party;

f. In other circumstances as stipulated by applicable laws or administrative regulations.

II. How We Share, Transfer and Publicly Disclose Your Personal Information

MGI will not share, transfer, or publicly disclose your personal information to other third parties except as described in this Policy.

1  Share

To ensure the stable operation of our products or services, to ensure your user experience, and for other lawful and reasonable purposes, we may share your personal information with third parties in certain circumstances, and we will require such third parties to process your personal information in accordance with applicable legal requirements:

1) If you have requested it by yourself;

2) Where your express consent has been obtained in advance;

3) For potential business cooperation, enquiries about products and services or business coorperation matters relating to performance, payments, training, maintenance, etc., which you have requested, we may not be able to complete alone. To respond to your request, we may need to share your information with our affiliated companies, suppliers or other business partners (such as after-sales service providers, logistics companies, etc.) that supporting our business;

4) We may share the information you provide when participating in our marketing or promotional activities to event partners such as joint-organizers, co-organizers, sponsors, etc.;

5) We may share your information with internet service providers in order to maintain and manage our Official Website and other media, to enhance your user experience and to perform our network security and safety obligations;

6) We may share your information with external auditors, legal advisors, insurance companies and banks to meet regulatory requirements and secure transactions;

7) In order to complete our cooperation with you or your company, and to achieve unified management of the MGI Group, your personal information may be shared between MGI and its wholly-owned and controlled subsidiaries;

8) In order to respond to your job applications, we may need to forward your submitted CV to our affiliated companies, background check companies and recruitment service providers for screening and assessment;

9) We may share your personal information as required by applicable law, or as requested by administrative, judicial or other regulatory authorities, and as necessary to fulfill other legal obligations.

If you do not want us to share your personal information with third parties, you may contact us through the ways set out in section IX of this Policy, but this may affect the services you receive from us.

2  Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

1) If you have requested it by yourself;

2) Where your express consent has been obtained in advance;

3) If, as our business develops, we need to transfer personal information as a result of a merger, separation, dissolution or declaration of bankruptcy, we will inform you of the name and contact details of the recipient. The recipient shall continue to protect your personal information in accordance with the applicable legal provisions.

3  Disclose Publicly

We will only disclose your personal information publicly in the following circumstances:

1) If you have requested by it yourself;

2) Where your separate consent has been obtained in advance;

3) Where required by applicable law or in response to legal procedure, we may publicly disclose your personal information to the relevant regulatory authorities.

III. How We Use Cookies and Related Technologies

In order to ensure that our Website works properly and efficiently, to make your visit easier and to provide you with content that may be of interest to you, we use cookies (a small text file) to provide you with a more personalized user experience and service. For example, in the case of your use of the Website service, when you visit the Website for the first time, we store it on the device from which you visit the Website (where your browser allows it). When you visit the Website again, the Website will learn your relevant preferences (such as the language, font size and other browsing preferences of your computer or mobile device) by reading the cookies. The main cookies we use include the following:

1  Strictly Necessary Cookies

These Cookies are necessary for the operation of this Website and are used to perform the basic functions of the Website. The list of cookies is as follows:

2  Analytical Cookies

Analytical Cookies are primarily used to help us understand how visitors arrive at the Website, how they use it and for how long, and how we can improve the visitor experience.

3  Advertising Cookies

We place advertising cookies with your permission. Advertising cookies collect information about your browsing habits in order to make our content and advertising as relevant to you and your interests as possible. These cookies are also used to help us measure the effectiveness of our advertising campaigns by tracking the number of clicks.

We do not use the cookies we create for any purpose other than that described in this Policy. You can manage or disable the use of cookies by setting your browser software according to your preferences.

IV. How We Store and Protect Your Personal Information

1  Storage of Personal Information

We will only retain your personal information for as long as is reasonably necessary to fulfil the purposes set out in this Policy, unless there is a pre-requisite retention requirement under law or regulation. We determine the duration of storage of personal information by reference to the longer of the following criteria: completion of the purpose of the service or transaction to which you relate, maintenance of the corresponding business and transaction records in response to your possible enquiries or complaints; ensuring the security and quality of the services we provide to you; whether you have agreed to a longer storage period; and the existence of other special agreements or legal or regulatory requirements regarding the duration of data retention. After the retention period has expired, we will delete or anonymize your personal data in accordance with the requirements of applicable law.

2  Protection Measures for Personal Information

MGI is committed to protecting the security of your personal information. In an effort to prevent unauthorized access or disclosure, maintain data accuracy and ensure the proper use of personal information, we take appropriate physical and technical measures to protect your personal information. We may store personal information in locations outside of our direct control (e.g., on a colocation server or database maintained by a hosting provider), in which case we will require such providers to ensure appropriate physical and technical measures in place. The Internet is not an absolutely secure environment and we recommend that you use complex passwords, keep your passwords and  account information in confidential, and take care to protect the security of your personal information.

V. How You Can Exercise Your Relevant Rights to Personal Information

Please take care to ensure that your personal information is accurate each time you provide it to us and that you are in a secure environment at the time you provide it.

To the extent permitted by applicable law, you have the right to exercise any or all of the following rights by contacting us through Section IX of this Policy:

1. The right to access and copy your personal information;

2. The right to request us to correct or supplement your personal information if you find it is inaccurate or incomplete;

3. The right to delete or request us to delete your personal information;

4. The right to decide on the processing of your personal information, and the right to restrict or refuse us to process your personal information;

5. The right to request us to explain the relevant rules on our processing of your personal information;

6. The right to request the transfer of your personal information to your designated personal information processor, and we will provide the means to do so if such transfer complies with the applicable legal and conditions required by the relevant regulatory authority;

7. The right to lodge a complaint with a supervisory authority.

Where permitted by applicable law, you also have the right to withdraw your consent at any time when we process your personal information on the basis of your consent, but the withdrawal of consent does not affect the lawfulness and validity of our processing of your personal information on the basis of your consent prior to the withdrawal, nor does it affect our processing of your personal information on any other appropriate legal basis.

Please note that we may not be able to completely delete the information you wish to delete from our system immediately, as limited by requirement of relevant laws and regulations or the technical conditions of the different information. Before the complete deletion, we will only store the relevant information and take necessary security measures as required by law and regulations.

For security purposes, we may require you to prove your identity and the legitimacy of your request by appropriate means and we will respond to your request as soon as reasonably possible after we have received your feedback and verified your identity. Please also understand that we need to process your request as far as legally permissible and practicable, otherwise we may not be able to fulfill your request.

VI. Protection of Personal Information of Minors

We take the protection of personal information of minors very seriously. Our products, services and media such as our Official Website are primarily aimed at adults. If you are under the age of 16 or age of majority as specified in your jurisdiction, please do not register or provide us with any information about yourself on our Website, products or services from Weibo, WeChat or other our official platforms. We will not knowingly collect personal information from minors in violation of the law. If you become aware that we have inadvertently collected personal information from minors, please notify us immediately in accordance with section IX of this Policy and we will take all reasonable measures to delete the relevant data as soon as possible, unless compulsorily required to do so by law or regulation.

VII. Cross-border Transfer of Personal Information

We are a global company headquartered in China and our affiliates, business partners or suppliers may be located in different countries and regions. We may transfer your personal information to our affiliates, business partners or suppliers outside your country or region in order for them to assist us in processing your personal information for the purposes described in this Policy. Such countries and regions may have different personal information protection laws and we will take reasonable measures to protect your personal information within the requirements of the applicable laws.

VIII. Update of This Policy

This Policy is effective as of the date set out at the beginning of this Policy. In order to provide you with a better experience and as our services continue to evolve, we reserve the right to amend this Policy at any time to reflect our latest services and to align with the latest regulatory requirements. If we make material changes to this Policy, we will notify you prominently on the Privacy Policy page of our Website and indicate at the top of this Policy when it was last updated.

IX. How to Contact Us

If you have any questions about this Policy, or wish to exercise any of your rights under this Policy, you may contact us as follows. If you are not satisfied with our response to your request, you may submit a complaint to the competent authority.

Company: MGI Tech Co., Ltd.

Address: Building 11, Beishan Industrial Zone, Yantian District, Shenzhen 518083, China

Email: dataprotectionofficer@mgi-tech.com