This Privacy Policy sets out how Beijing MecKey Engineering Co. and its affiliates (“Spare Parts Mall”, “we” or “us”) collect, use, disclose, process and protect information provided by you when you access our products and services via beijian.meckey.com and our mobile-application suite (list available here). We may collect certain information for identity-verification purposes when you use our services. All such information shall be processed strictly in line with this Privacy Policy and our User Terms and Conditions.

This Privacy Policy has been prepared with your interests in mind. It is critical that you understand our personal-data collection and processing practices, and that you maintain ultimate control over your personal information shared with Spare Parts Mall.

For the purposes of this Privacy Policy, “personal information” means any data that identifies or is capable of identifying a natural person, whether standing alone or combined with other information. This includes without limitation: information you voluntarily submit, system-generated data linked to you, and data collected in the course of your service usage. Depending on the service, this may cover financial information, social-related data, location data and login-log records.

Your use of Spare Parts Mall’s products and services constitutes your confirmation that you have read, understood and accepted all terms of this Privacy Policy, including any subsequent updates and amendments. Where required by applicable law — including data-protection legislation in your jurisdiction such as the EU General Data Protection Regulation (GDPR) — we will obtain your explicit separate consent prior to processing special categories of personal information, including automated decision-making activities. We commit to protecting the privacy, confidentiality and security of your personal information as required by applicable law. These obligations apply to all our employees and authorised agents.

We strive to deliver an optimal user experience. If you have questions about our data-processing practices described in this Privacy Policy, please contact us at service@meckey.com and we will respond to your specific requests. We welcome your feedback.

To provide you with our services, we need to collect personal information necessary for service delivery. Should you decline to provide required personal information, certain services may become unavailable.

We only collect information for specified, explicit and lawful purposes linked to the services you select. We will not process such information for purposes incompatible with those originally stated. Subject to the services you use, we may collect one or more of the following categories of information (whether or not qualifying as personal-data):

Information you submit or upload (including contact details): Personal information required for service delivery, further explained under “How This Personal Information Will Be Used”. For example, when using the Platform’s shopping function, you may provide your full name, contact details and email address.

System-generated data linked to you: Account identifiers used to distinguish individual end-users.

Third-party-provider-sourced data linked to you: Such as advertising identifiers assigned by third-party service providers.

Financial data: Company-level or personal-level information provided for invoicing purposes when using Spare Parts Mall’s e-commerce capabilities.

Social-related data: Voluntarily-submitted information such as occupation and educational background when you use MecKey social-service features.

Location-related data (service-specific only): Region, country code, city code, mobile-network identifiers, cell-ID, geolocation coordinates, time-zone and language preferences.

Login-log data: Records associated with your use of features, applications and websites, including cookies and other anonymous-identifier technologies, IP-addresses, network-request metadata, temporary-message history, system logs and error-tracking information.

We may also gather non-identifiable information, which will be aggregated, anonymised or de-identified. For example, device model and operating-system version. This data supports service optimisation. The scope and volume of collected data depend on how you interact with our products and services.

Personal-data collection enables us to deliver products and services and meet statutory-compliance obligations. You consent to our processing of your personal-data for purposes laid out in this Privacy Policy, and to disclosure to our affiliates (operating in communications, social-media, technology and cloud-service sectors) and authorised third-party service providers (defined elsewhere).

Your personal information may be processed for the following purposes:

Delivery, maintenance, enhancement and development of products and services, including after-sales support and customer-care functions for web-based and device-delivered services.

Two-way communications concerning your devices, services and support-related enquiries (service updates, support replies, event alerts and official notifications).

Execution of marketing-promotion activities; please refer to the “Direct Marketing” section for further details.

Enabling user-generated comments on public forums.

Organisation of promotional campaigns including sweepstakes and social-media initiatives.

Usage-pattern analytics and statistical reporting to drive product-and-service improvements.

Data retention for business-administration and legal-compliance requirements.

Provision of local functionalities independent of server communication.

Additional use-cases for your information (including personal-data):

User-experience optimisation via opt-in analytics programmes to evaluate platform-usage patterns.

Feedback handling: Your feedback helps us improve services. We may use your submitted personal-data to follow-up on feedback and maintain relevant records.

Administrative notifications: To communicate amendments to our terms, conditions and privacy provisions.

Device-performance analytics for hardware-and-software-related experience improvements.

Subject to your prior express consent, we may use your name, telephone number, email address and Spare Parts Mall-account identifier to distribute promotional materials for offerings from Beijing MecKey Engineering Co. and its partners (network, mobile-app and cloud-solution providers). Recommendations may be generated based on your purchase records, browsing behaviour, demographic attributes and geographic-location data. Consent shall be obtained via unambiguous affirmative action or as required by applicable legislation, which may include a standalone notice. You may unsubscribe from marketing-related emails by clicking the unsubscribe link contained within marketing messages. We shall not share your personal-data with commercial partners for direct-marketing purposes.

Spare Parts Mall and our third-party service providers use cookies, tags and scripts to analyse usage trends, administer the website, track user-site interactions, and compile aggregated demographic statistics of our user base. We receive both individual-level and aggregated analytical reports derived from data collected through these technologies.

Log files: as with most websites, we gather and store selected information within log files. This may include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring and exit pages, operating-system details, date-time stamps and clickstream data. Automatically-collected log-file data will not be linked to any other personal-information we hold.

Advertising: we engage third-party service providers to display advertisements on our website and manage our advertising placements on external sites. Our third-party vendors may deploy cookies and comparable technologies to record your browsing activity across their and other third-party websites, for the purpose of delivering interest-targeted advertisements. We shall obtain your prior express consent prior to serving such interest-based advertising. Should you object to interest-driven ad targeting, you may activate your browser’s do-not-track setting.

Local storage — HTML5/Flash: We utilise Local-Storage Objects (LSOs) including HTML5-based local storage to save content and user preferences. Third-party partners delivering website features or advertisements may also leverage HTML5 local-storage to collect and store information based on your browsing behaviour. Each mainstream browser supplies built-in controls for clearing HTML5 local-storage objects. To manage Flash cookies, please click the following link: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

We may disclose your personal information to third parties (defined below) for the purpose of fulfilling your requests for products and services.

We may share your information with third-party service providers and affiliates listed later in this section. We will share your personal data only upon your explicit authorization, which extends to sub-processors processing your personal data. Where we share personal data with a third-party service provider, we will impose contractual terms governing such third-party’s obligations in accordance with applicable local data-protection legislation. Contracts will require third-party service providers to comply with privacy standards applicable in your jurisdiction.

To operate our business and deliver full functionality for our products and services, we may from time to time disclose your personal data to other Spare Parts Mall affiliates (engaged in communications, social media, technology or cloud-related businesses), or to our third-party service providers. These include telecommunications carriers, data centres, data-storage facilities, customer-service providers, advertising & marketing vendors, and agents acting on our behalf (collectively the “Third-Party Service Providers”). Third-Party Service Providers may process your personal data on our behalf or for the purposes outlined above. When you use certain mobile applications on our devices, we may share your IP address with third parties to deliver requested services. If you no longer consent to such sharing, please email us at service@meckey.com.

Spare Parts Mall cooperates with a group of separate companies that collectively form the Spare Parts Mall ecosystem. Spare Parts Mall ecosystem companies are independent entities invested in and operated by Spare Parts Mall, and are experts in their respective fields. Spare Parts Mall may disclose your personal information to Spare Parts Mall ecosystem companies in order to provide and improve the exciting products or services (including software and hardware) offered by them. Some products or services still use the Spare Parts Mall brand, while others may use their own brands. Spare Parts Mall ecosystem companies may from time to time share with Spare Parts Mall data relating to Spare Parts Mall-branded products or services, in order to deliver software and hardware services that provide better functionality and user experience. Spare Parts Mall will adopt appropriate management and technical measures to ensure the security of your personal information during processing, including but not limited to the encryption of personal data. If Spare Parts Mall is involved in a merger, acquisition, or sale of all or part of its assets, we will notify you via email and/or a prominent notice posted on our website of any changes to ownership or use of your personal data, as well as your available rights and choices concerning your personal data.

Where required under applicable law, we may disclose your personal data without obtaining your further consent.

We may share anonymized information in aggregate form with third parties (for example, advertisers on our website) for commercial purposes; we may share general usage trends of our services, such as the number of customers in particular groups who purchase certain products or engage in certain transactions.

For the avoidance of doubt, Beijing MecKey Engineering Co. may collect, use or disclose your personal data without your consent only to the extent explicitly permitted by applicable local data-protection laws.

We are committed to keeping your personal information secure. To prevent unauthorized access, disclosure, or other similar risks, we have implemented reasonable physical, electronic, and managerial procedures to safeguard the information we collect from your mobile devices and from the Spare Parts Mall website. We will take all reasonable measures to protect your personal information.

For example, when you access your Spare Parts Mall account, you may choose our two-factor authentication (2FA) procedure for greater security. When you send or receive information from a Spare Parts Mall device to our servers, we ensure that the information is encrypted using Secure Sockets Layer (SSL) and other algorithms.

All of your personal information is stored on secure servers and protected within controlled facilities. We classify your data based on its importance and sensitivity, and ensure that your personal information receives the highest level of security. We ensure that employees and third-party service providers who have access to such information in order to provide products or services to you are bound by strict contractual confidentiality obligations; if they fail to fulfill these obligations, they will be subject to disciplinary action or termination of cooperation. Likewise, we have dedicated access-control measures for our cloud-based data storage. In summary, we regularly review our information-collection, storage, and processing practices, including physical security measures, to prevent any unauthorized access and use.

We will take all feasible measures to protect your personal information. Please note that internet transmission is not entirely secure. Accordingly, we cannot guarantee the security or integrity of personal data transmitted to or from us over the internet.

In the event of a personal data breach, we will promptly notify competent supervisory authorities and, under certain circumstances, notify affected data subjects of the breach, in compliance with applicable law and data-protection regulations in your jurisdiction.

You can protect your personal information by not disclosing your login password or account information to anyone (unless that person has been formally authorized by you), and you can set a unique password for Spare Parts Mall to prevent the leakage of passwords from other sites from compromising the security of your Spare Parts Mall account. You should never, at any time, disclose the verification code you receive to anyone (including anyone claiming to be Spare Parts Mall customer service). Whenever you log in as a Spare Parts Mall account user, especially on someone else’s computer or on a public Internet terminal, you should always sign out at the end of the session.

Spare Parts Mall is not responsible for security lapses caused by your failure to keep your personal information private, which result in a third party’s access to your personal information. Notwithstanding the above, if any other Internet user uses your account without authorization, or if any other security breach occurs, you should notify us immediately.

We retain personal information for the purposes for which it was collected, or as required by applicable law. Once the purpose of collection has been fulfilled, we will stop retaining the data, or will perform de-identification / masking. Where it is necessary for the public interest, scientific or historical research, or statistical purposes, Spare Parts Mall will continue to retain the relevant data in accordance with applicable law, even if further processing is unrelated to the original purpose of collection.

We recognise that privacy-related concerns vary between individuals. We provide multiple options for you to restrict the collection, use, disclosure and processing of your personal data and manage your privacy settings, including logging in to and out of your account. If you have previously given consent for us to process your personal data for the purposes set-out herein, you may modify or revoke such consent at any time by writing to service@meckey.com.

You have the right to request access to and/or correction of any personal information we hold about you. When you update your personal information, we will require verification of your identity before processing your request. Once we have sufficient information to process your request to access or correct your personal information, we will respond within the time limits set by applicable data-protection law.

Upon your request, we will provide one copy of the personal data we have collected and processed about you free of charge. For any further requests in respect of such information, we may charge a reasonable fee based on applicable law and actual administrative costs.

If you wish to request access to the personal data we hold, or if you believe that any information we hold about you is incorrect or incomplete, please contact us by mail or at the following email address. Email: service@meckey.com.

If you are a user within the scope of the General Data Protection Regulation (GDPR), you have the right to require us to erase your personal data. We will assess your erasure request and, where the requirements of the GDPR are met, will take appropriate steps (including technical measures) to process it.

If you are a user within the scope of the GDPR, you have the right to require us to restrict the processing of your personal data. We will assess your restriction request and, where the requirements of the GDPR are met, will process your data in accordance with the specific circumstances provided for in the GDPR, and will notify you before lifting the restriction.

If you are a user subject to the GDPR, you hold the right to object to processing based solely on automated decision-making — including profiling — which produces legal- or similarly significant effects concerning you.

If you are a user within the scope of the GDPR, you have the right to obtain your personal data in a structured, commonly used format and to transfer it to another data controller.

You may withdraw your consent, including the collection, use, and/or disclosure of your personal information in our possession or control, by submitting a request.

Where we need to transfer personal information outside your jurisdiction—whether to our affiliated companies (in the communications, social media, technology, and cloud businesses) or to third-party service providers—we will do so in accordance with applicable law. By implementing uniform safeguards, we ensure that all such transfers meet the requirements of applicable local data-protection law. You have the right to be informed of the security-protection mechanisms used by Spare Parts Mall in the course of transferring your personal data.

Spare Parts Mall is a global operator headquartered in China. Accordingly, while ensuring compliance with applicable regulations, we may transfer your data to Spare Parts Mall’s global entities, which will process your personal information for the purposes described in this Privacy Policy. We may also transfer your personal information to third-party service providers that may be located in countries outside the European Economic Area.

If Spare Parts Mall transfers data generated by you within the European Economic Area to Spare Parts Mall entities or third-party service providers located outside the European Economic Area, we will use the standard contractual clauses adopted by the European Union, or the safeguards provided for in the GDPR. If you wish to obtain a copy of the standard contractual clauses, please contact us at service@meckey.com.

Spare Parts Mall uses globally operated and controlled infrastructure to process and back up personal data. The jurisdictions in which these global facilities are located may or may not provide data-protection laws similar to those in your jurisdiction. You understand that the risks differ under different data-protection laws, and that we may transfer and store your personal information at overseas facilities. This does not, however, change any of our commitments to comply with this Privacy Policy and to protect your personal information.

We believe that it is the responsibility of parents or guardians to supervise children’s use of our products or services. However, we refuse to obtain personal information from minors, or to send any promotional materials to such persons.

Spare Parts Mall does not knowingly collect personal information from minors. If a parent or guardian has reason to believe that a minor has submitted personal information to Spare Parts Mall without prior consent, please contact us to ensure that such personal information is deleted and that the minor is unsubscribed from any applicable Spare Parts Mall services.

If you have agreed to the applicable User Agreement, and there is any inconsistency between such User Agreement and this Privacy Policy, the User Agreement shall prevail.

We will review this Privacy Policy on a regular basis in light of business and technological changes, and we may update it. If we make material changes to this Privacy Policy, we will notify you by email (sent to the email address associated with your account) or by posting a notice on all Spare Parts Mall websites or by mobile-device notification, so that you can understand what information we collect and how we use it. Such changes to the Privacy Policy will apply from the effective date specified in the notice or on the website. We recommend that you review this page regularly for the latest information on our privacy practices. Your continued use of our products, websites and mobile devices constitutes your acceptance of the updated Privacy Policy. Where we collect additional personal information from you, or where we use or disclose your personal information for new purposes, we will seek your consent again.

Our Privacy Policy does not apply to products or services provided by third parties. Spare Parts Mall’s products or services may include third-party products or services, as well as links to third-party websites. When you use these products or services, your information may also be collected. Accordingly, we strongly recommend that you take the time to read the third party’s privacy policy, just as you would read ours. We are not responsible for, and cannot control, how third parties use the personal information they collect from you. Our Privacy Policy does not apply to other websites linked through our services.

When you use these specific products, the following third-party terms and privacy policies apply:

When using advertising services of specific applications, depending on your choice, you will agree to one of the following two service terms.

Google’s privacy terms: https://policies.google.com/

Facebook’s privacy terms: http://www.facebook.com/about/privacy/update?ref=old_policy

When using Google Input Method, you will agree to Google’s terms: http://www.google.com/policies/privacy

When using SwiftKey Input Method, you will agree to SwiftKey’s terms: http://swiftkey.com/en/privacy

Social media (features) and widgets

Our website contains social-media features such as “share” buttons or interactive mini-programs running on the site. These features may collect your IP address and the pages you browse on our website, and may set cookies to enable the relevant features to function properly. Social-media features and widgets may be hosted by third parties or hosted directly on our website. Your interaction with these features is governed by the privacy policy of the provider.