Privacy Protection

Welcome to the Data Information and Privacy Protection Policy (hereinafter referred to as "this Policy")! 

Achteck (in this Policy, meaning Ganzhou Achteck Tool Technology Co., Ltd. and its affiliates, hereinafter referred to as "we" or "us") respects and protects the security of users' data information and privacy (collectively referred to as "information"). This Policy will explain to you (including users of our products and services, partner merchants, end customers of partner institutions, etc., hereinafter collectively referred to as "you") how we collect, store, use, share, transfer, and publicly disclose your information in the course of providing services to you, as well as how we provide you with mechanisms to access, update, control, and otherwise exercise your rights with respect to your user information, and protect your user information. Specifically, it includes the following:

• How we collect and obtain your information  

• How we use cookies and similar technologies  

• How we use user information  

• How we share user information  

• How we store and protect user information  

• Transfer and public disclosure of user information  

• How we ensure your access to and control over your own user information  

• Statement of liability for third parties  

• Special provisions on minors' privacy  

• Application and revision of this Policy  

• How to contact us  

Special Notice

Collecting, storing, using, and sharing your information is aimed at providing you with good services in a lawful and compliant manner, and continuously improving service quality and user experience by, for example, developing new services, optimizing and iterating existing service functions, and introducing partners to provide you with new products and services. You have the right not to provide us with the information listed in this Policy, but in many cases, if you choose not to provide it, we may not be able to provide you with account registration functions or the services you intend to obtain, or we may not be able to achieve the intended service quality. If you choose to provide your relevant information, you can enjoy better and more convenient services, and only then do we have the conditions to use your information within the necessary and legal scope to better protect your account and fund security, avoid adverse effects on you due to our inability to contact you in a timely manner, and avoid inconvenience to you in using our services due to the inability to carry out necessary cooperation and assessments.  

This Policy applies to the products and services provided by Ganzhou Achteck Tool Technology Co., Ltd. and its affiliates, including web pages, clients, public accounts, as well as smart hardware we authorize or provide, and our partial or full service functions integrated as third-party services into smart hardware, software, or services of other parties authorized by us. If such entities use our products or services but do not have an independent privacy policy, this Policy also applies to those products or services. Please note that this Policy does not apply to services provided to you by other third parties through the aforementioned web pages or clients. For example, when you download or use third-party applications or services through links, QR codes, etc. displayed on our official website, etc., the information you provide separately to third parties on their application or platform, client pages, or systems is not covered by this Policy.  

This Policy is closely related to your use of our services. We recommend that you read and understand all contents of this Policy carefully and make the choices you deem appropriate. We strive to use plain and concise language, and **highlight clauses that have a significant bearing on your rights in bold** for your attention. Before using our products or services, please carefully read and fully understand this Policy, and use the relevant products or services only after confirming that you fully understand and agree to it. Once you start using our products or services, it means you have fully understood and agreed to this Policy. If you have any questions, comments, or suggestions about the content of this Policy, you can contact us via [4000069898] or [4006561010].  

How We Collect and Obtain Your Information  

We obtain your user information through the following channels:  

1. Information you provide directly

1.1 We may collect and store any information you provide to us when using our services, including information you fill in online on our pages, post in online communities, provide when resolving disputes or contacting us regarding Achteck products and services, or information you authorize us to collect from third parties that lawfully hold your information, as well as information about your transactions and activities generated during your use of our services. Depending on the applicable scenario, such information may include one or more of the following: your institutional registration and entity information, business operation or transaction information, valid identity documents, contact information, occupation, mailing address, name, address, phone number and email, biometric information, transaction or behavioral information of your end customers, etc. In addition, if the service you use requires mutual verification or association with your bank card/bank account or other payment instrument accounts, you also need to provide us or the partners of such products and services with the necessary information to complete such operations, such as bank account information, payment customer information, etc. To facilitate your inquiry into your transaction status or historical records, and to comply with laws, regulations, and regulatory requirements, we will retain information generated or submitted during your use of our services. We will properly keep your information for the period necessary to provide services to you or as required by laws and regulations. If you do not use certain of our services, you may choose not to provide relevant information to us.  

2. Information we actively collect

2.1 During your use of Achteck-related services, in order to ensure the security of your funds and user information, when you visit our website, mobile client, or use our services, we may collect information sent to us by your computer, mobile phone, and other access devices, such as records of the types and methods of services you use, operation-related information when using services, such as your IP address, version and device identification code of your mobile device, device identifier, your location, and other log information related to our services. In addition to the above information, we may also collect other information for the reasonable need to provide services and improve service quality, such as information you provide when contacting our customer service team, questionnaire responses you send to us when participating in surveys, information you submit when participating in various marketing campaigns, and information about mobile applications (APPs) and other software you have used (limited to the reasonable scope related to our products and services). At the same time, to improve the security of your use of our products and services, and to more accurately prevent phishing websites, fraud, and Trojan viruses, we may understand some of your internet usage habits, commonly used software information, and other means to judge risks, and may record URLs, APPs, or software we consider risky. However, if you do not provide this information, it will not affect the basic functions of our services, but may affect the quality and information security of these products and services you enjoy.  

3. Information we obtain from other sources

3.1 To better provide services to you, prevent risks arising from your use of our related services, or assess liability for breach, you authorize us to inquire or collect your relevant information from Achteck's affiliates and partners, credit institutions, data service providers, and third-party institutions lawfully established and lawfully holding your relevant information, such as credit scores, credit reports, addresses, emails, phone numbers through which you can be contacted, etc., so that we or our partners can assess whether you meet the criteria for providing services to you.  

3.2 To meet your or your end customers' financing, installment, and other needs, we may need to process, analyze, and otherwise handle user information and end-customer data (entity information, identity information, contact information, transaction records, behavioral records, etc.) generated or submitted during your use of our services, in order to determine or assist partners in determining whether to provide services to you or your end customers.  

3.3 We may obtain account information you have authorized to share from third parties, and after you agree to this Policy, you may directly log in and use our services through third-party accounts. We will confirm the legality of the source of user information in accordance with agreements with third parties, and then use your user information on the premise of complying with relevant laws and regulations.  

4. Information we directly obtain in accordance with law

You fully acknowledge that in the following circumstances, we may collect, use, and share user information without obtaining your separate authorization:  

4.1 Related to national security and national defense security;  

4.2 Related to public safety, public health, and major public interests;  

4.3 Related to criminal investigation, prosecution, trial, and execution of judgments;  

4.4 For the purpose of safeguarding the life, property, and other major legitimate rights and interests of the user information subject or other subjects, but it is difficult to obtain the consent of the individual;  

4.5 The collected user information is information you have made public to the public;  

4.6 User information collected from legally publicly disclosed information, such as lawful news reports, government information disclosure, etc.;  

4.7 Necessary for concluding a contract at your request;  

4.8 Necessary for maintaining the security and stable operation of the products and services provided, such as discovering and handling service faults;  

4.9 Necessary for lawful news reporting;  

4.10 Necessary for academic research institutions to conduct statistics or academic research based on public interest, and when providing academic research or descriptive results to the public, the user information contained in the results is de-identified;  

4.11 Other circumstances provided by laws and regulations.  

How We Use Cookies and Similar Technologies  

1. Use of Cookies

1.1 To provide you with a more relaxed access experience, when you visit our website or use our services, we may identify you through small data files, which can help you avoid re-entering registration information or help determine the security of your account. These data files may be Cookies, Flash Cookies, or other local storage provided by your browser or related applications (collectively referred to as "Cookies"). Please understand that some of our services can only be realized through the use of Cookies. If your browser or browser add-on services allow, you may modify your acceptance of Cookies or reject our Cookies. The help section on the toolbar of most browsers will tell you how to prevent your browser from accepting new Cookies, how to have your browser notify you when you receive a new Cookie, or how to completely disable Cookies. In addition, you can close or delete similar data used by browser add-ons (such as Flash Cookies) by changing the settings of the browser add-on or by visiting the provider's web page. However, the aforementioned operations may, in some cases, affect your secure access to our website and use of our services.  

2. Use of Web Beacons and Similar Technologies 

2.1 Our websites may also contain some electronic images (called "single-pixel GIF files" or "web beacons"). The use of web beacons can help websites count users who browse pages or access certain Cookies. We may collect information about your browsing activities through web beacons, such as the page addresses you visit, the location of the referring page you previously visited, your browsing environment, and display settings. We may use web beacons on Achteck's websites to count user visits and dwell time, identify registered Achteck users by accessing Cookies, or provide you with personalized services.  

2.2 To provide you with a more secure access experience, if you use services provided by third parties rather than by us through our websites or clients, we cannot guarantee that these third parties will take protective measures in accordance with our requirements. To make every effort to ensure the security of your account, we may use dedicated network protocols and proxy technologies (referred to as "dedicated network channels" or "network proxies"). The use of dedicated network channels can help you identify high-risk sites we know, reducing the risk of phishing, account leakage, etc. It also better protects the common interests of you and third parties, preventing criminals from tampering with the service content you and third parties expect, such as ad injection and illegal content tampering caused by insecure routers, illegal base stations, etc. In this process, we may also obtain and store relevant information about your computer, such as IP address, hardware ID, etc.  

How We Use User Information  

1. Purposes and Objectives

The main purpose of collecting the information you provide is to provide you with safe, efficient, and personalized service experiences (including providing your end users with services they may be interested in or related to you, such as consumer installment plans, education or training product purchases, etc.). We will use your user information for the following purposes:  

1.1 Real-name authentication management. When you use Achteck services, we (or our lawful partners) first need to verify the authenticity of your identity, for which you need to provide your identity information, bank card or bank account information, and mobile phone number. We will submit the above information to third-party identity verification institutions that lawfully hold your information, so as to verify the accuracy of the information you provide. If you do not provide the above information, you will not be able to use services that must be subject to real-name management under relevant Chinese laws and regulations, such as payment, investment, financing, consumption, etc.  

1.2 Credit assessment. When you use Achteck services, we will use your basic information, identity information, property information, transaction information, and other information collected with your consent during specific business operations to conduct or cooperate with partners (such as banks, payment institutions, consumer finance companies, microfinance companies, trust institutions, factoring companies, etc.) in risk management and control, detecting, preventing, and/or remedying fraud or other potential illegal activities. At the same time, during your enjoyment of Achteck services, we will continuously use the above information to detect, prevent, or correct conduct that violates relevant laws, regulations, or applicable user agreements.  

1.3 Providing Achteck services to you. When you use Achteck-related services, we will use your identity information, property information, transaction information, and other information collected with your consent during specific business operations to assess the applicability of our services, verify the authenticity of transactions, process service requests, and synchronize with partners to complete transaction instructions and send you transaction notifications. At the same time, in order to comply with relevant laws, regulations, and regulatory requirements, and to facilitate your inquiry into transaction records or historical status, we will archive your identity information, transaction information, and behavioral information generated when using Achteck, and properly keep this information strictly in accordance with laws and regulations.  

1.4 Providing customer services and handling complaints. Our customer service system or personnel (including in-house or outsourced agents) will use your account information and transaction information. To ensure the security of your account, our call center and online customer service will use your account information to verify your identity. When you need customer service related to your transaction information, we will query your transaction information. To protect your and others' legitimate rights and interests, if you are complained about by others or complain about others, we will provide your name, ID number, and complaint content to consumer protection authorities and regulatory agencies for timely resolution of disputes, except where laws and regulations expressly prohibit provision.  

1.5 Service improvement and personalized services. We may collect your or your submitted end customers' transaction information, browsing information, and your interests for data analysis to form user profiles, so as to display products or services that may interest you. We may also obtain other information for the reasonable need to provide services and improve service quality, including information you provide when contacting customer service, questionnaire responses you send to us when participating in surveys, and information you submit when participating in Achteck online marketing, offline salons, forums, etc. We may associate information collected from your various devices so that we can provide consistent services across these devices. We may combine information from one service with information from other services for analysis and processing to provide you with services, personalized content, and suggestions.  

1.6 Functions necessary to ensure transaction security. To improve the security of our systems when you use our services, more accurately prevent phishing website fraud, and protect account security, we may judge your account risks by understanding your browsing information, transaction information, commonly used software information, device information, etc., and may record links ("URLs") we consider risky. We may also collect your device information to analyze Achteck system issues, count traffic, and troubleshoot possible risks, and to investigate when you choose to send abnormal information to us.  

1.7 Carrying out marketing activities. You have the right to receive information about our or our partners' products or services. We may push such commercial information to you via SMS, email, or other presentation methods. If you do not wish to receive such information, you may cancel by contacting Achteck customer service or using other unsubscribe functions provided by Achteck (free of charge). At the same time, without your explicit consent, we will not sell or rent your user information to any unrelated third party for the purpose of satisfying third-party marketing.  

1.8 Other activities carried out in accordance with law. 

2. Rules for use of information

2.1 We will use the collected user information in accordance with the provisions of this Policy and for the purpose of realizing our service functions.  

2.2 After collecting your user information, we will de-identify the data through technical means, and de-identified information will no longer be able to identify the subject. Please understand and agree that, in this case, we have the right to use de-identified information; and without disclosing your user information, we have the right to analyze the user database and commercially utilize it.  

2.3 Please note that all user information you provide when using our services, unless you delete it or refuse our collection through system settings, will continue to authorize us to use it during your use of our services. When you cancel your account, we will stop using it and delete or anonymize your user information in accordance with relevant laws and regulations.  

2.4 We will perform statistics on the use of our services and may share these statistics with the public or third parties to demonstrate the overall usage trends of our services. However, these statistics do not contain any personally identifiable information about you.  

2.5 When we display your user information, we will use content replacement, anonymization, and other methods to desensitize your information to protect its security.  

2.6 When we intend to use information collected for specific purposes for other purposes beyond the direct or reasonably related scope of the original purpose, we will seek your consent in advance.  

How We Store and Protect User Information  

1. We will store user information collected within the territory of the People's Republic of China within the territory of the People's Republic of China. If it is necessary to handle cross-border business and transfer your user information abroad to complete transactions, we will comply with the provisions of laws, regulations, and relevant regulatory authorities, and require the recipient to handle such user information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures.  

2. If we terminate services or operations, we will notify you at least thirty days in advance, and delete or anonymize your user information after termination of services or operations.  

3. We will take all reasonable and feasible measures to protect your user information:  

3.1 Data security technical measures. We will use encryption storage, encrypted transmission, desensitized display, and other security protection measures that meet industry standards, as well as industry-standard security technologies, to prevent unauthorized access and modification of your user information, and to avoid leakage, damage, or loss of your user information.  

3.2 Internal controls on data security. We will regulate the storage, access, and use of user information through systems and procedures such as setting data access permissions and multi-factor authentication, data classification and grading, data access log analysis, data security management specifications, and security development specifications. We will designate specific departments and institutions as well as dedicated personnel to be responsible for user information security affairs, and will strengthen the awareness of all employees about the importance of protecting user information through security and privacy protection training.  

3.3 To address possible risks such as user information leakage, damage, and loss, we will establish multiple systems to clarify classification and grading standards for security incidents and security vulnerabilities, corresponding handling procedures, and reasonable emergency response plans. In the event of a user information security incident, we will, in accordance with laws and regulations, promptly inform you of the basic situation of the security incident and its possible impact, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. At the same time, we will promptly inform you of the incident via email, letter, phone, push notification, etc. If it is difficult to notify each user information subject individually, we will make announcements in a reasonable and effective manner. We will also proactively report the handling of user information security incidents to regulatory authorities as required.  

How We Share User Information  

We promise to keep your information confidential. Except as otherwise provided in this Policy, we will share your necessary information with third parties only in the following circumstances, and we will make every effort to urge third parties to comply with laws, regulations, and other appropriate confidentiality obligations and take necessary security measures when using your user information:  

1. To provide you with our services.  

2. To achieve the purposes described in the "How We Use User Information" section.  

3. If you participate in sweepstakes, contests, or similar promotional activities, we will use the information you provide to manage such activities. If the activity is jointly promoted with a third party, we may share with them user information generated during the activity and necessary to complete the activity, such as the number of participants, winner list, winner contact information, etc., so that the third party can send you prizes or provide services to you in a timely manner.  

4. For purposes reasonably necessary to comply with applicable laws, regulations, and regulatory requirements, safeguard social public interests, or protect the personal and property safety or legitimate rights and interests of our customers, our companies, or employees.  

5. In accordance with legal provisions and reasonable commercial practices, when we plan to merge with other companies, be acquired by them, or engage in other capital market activities (such as IPOs, bond issuances, etc.), and in other circumstances where we need to accept due diligence from other parties, we may need to provide your information to necessary parties, but we will require these parties to take reasonable confidentiality measures for your user information through signing confidentiality agreements, etc., and require them to delete your information within a reasonable period after completing the necessary work.  

6. In cross-border transactions initiated by you (if any), to provide overseas relevant parties with information necessary to complete the transaction, subject to compliance with applicable laws, regulations, and regulatory requirements.  

Transfer and Public Disclosure of User Information  

1. Transfer of user information

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

1.1 Obtaining your explicit consent or authorization in advance;  

1.2 Providing it as required by applicable laws, regulations, legal procedures, or mandatory administrative or judicial requirements;  

1.3 Providing it in accordance with agreements signed with you (including agreements signed online or on paper and corresponding platform rules) or other legal documents;  

1.4 In the event of mergers, acquisitions, asset transfers, or similar transactions, if user information transfer is involved, we will require the new company or organization holding your user information to continue to be bound by this Policy; otherwise, we will require that company or organization to re-obtain your authorization and consent.  

2. Public disclosure of user information 

We will only publicly disclose your user information in the following circumstances and subject to security protection measures that meet industry standards:  

2.1 At your request, disclosing the user information you designate in a manner you have explicitly agreed to;  

2.2 If we are required to provide your user information by law, regulation, mandatory administrative enforcement, or judicial request, we may publicly disclose your user information in accordance with the type of user information required and the method of disclosure. On the premise of complying with laws and regulations, when we receive such requests for information disclosure, we will require the production of corresponding legal documents, such as subpoenas or investigation letters.  

How We Ensure Your Access and Control Over Your Information  

1. We will take appropriate technical measures to ensure that you can query, update, and correct your registration information or other user information provided to us during your use of our services.  

2. In the following circumstances, you may request that we delete your user information:  

2.1 If our processing of user information violates laws and regulations;  

2.2 If we collect or use your user information without your consent;  

2.3 If our processing of user information violates the agreement with you;  

2.4 If you cancel your Achteck account;  

2.5 If we terminate services and operations.  

If we decide to respond to your deletion request, we will carry out subsequent deletion processing in accordance with your request and relevant laws and regulations, and provide you with feedback on the results.  

3. If you find that your user information we collect and store is erroneous, you may contact our customer service at [4000069898] or [4006561010] to request correction. For reasonable requests, we will generally not charge a fee, but for repeated requests beyond reasonable limits, we may charge a certain cost depending on the circumstances. We may refuse requests that are unjustifiably repetitive, require disproportionate technical effort (e.g., developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are highly impractical (e.g., involving information stored on backup tapes).  

4. You may change the scope of your authorization for us to continue collecting user information or withdraw your authorization by deleting information, turning off device functions, or making settings in the Achteck client or web software. You may also withdraw all authorization for us to continue collecting your user information by canceling your account. Please understand that each business function requires some basic user information to be completed. Once you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawn consent or authorization, and we will no longer process your corresponding user information. However, your decision to withdraw consent or authorization will not affect user information processing previously carried out based on your authorization.  

5. Responding to your above requests: For security purposes, you may need to provide a written request or otherwise prove your identity before we process your request.  

6. Notwithstanding the above provisions, in the following circumstances, we will not be able to respond to your request in accordance with laws, regulations, or regulatory requirements:  

• Related to national security and national defense security;  

• Related to public safety, public health, and major public interests;  

• Related to criminal investigation, prosecution, and trial;  

• Where there is sufficient evidence to show that you have subjective malice or abuse of rights;  

• Responding to your request would cause serious harm to the legitimate rights and interests of other individuals or organizations.  

Statement of Liability for Third Parties  

Please note that your transaction counterparties, operators of third-party websites you visit, third-party services accessed through us, and third parties that receive your user information from us may have their own privacy protection policies. When you view web pages created by third parties or use applications developed by third parties, these third parties may place their own Cookies or pixel tags, which are not under our control and their use is not subject to this Policy. We will make commercially reasonable efforts to require these parties to take protective measures for your user information, but we cannot guarantee that these parties will take protective measures in accordance with our requirements. Please contact them directly for details of their privacy protection policies. If you find that web pages created by these third parties or applications developed by third parties present risks, we recommend that you terminate related operations to protect your legitimate rights and interests.  

Special Provisions on Minors' Privacy  

We attach great importance to the protection of minors' user information. If you are a minor, we recommend that your parents or guardians read this Policy and use our services or provide your information to us only with the explicit consent of your parents or guardians. If your guardians do not agree to your use of our services in accordance with this Policy or to providing information to us, please immediately stop using our services and notify us promptly so that we can take appropriate measures. If you are a guardian of a minor, if you have any questions about the user information of the minor under your guardianship, please contact us through the customer service hotline mentioned above.  

Application and Revision of This Policy  

1. To provide you with better services and as Achteck's business develops, this Policy will also be updated. However, without your explicit consent, we will not reduce the rights you are entitled to under this Policy. We will release updated versions on the websites and mobile terminals of Achteck and its various businesses, and remind you of relevant updates through website announcements or other appropriate means before they take effect. Please also visit our official website to stay informed of the latest privacy policy.  

2. For material changes, we will also provide more prominent notice (we will explain the specific changes to the privacy policy through, but not limited to, email, SMS, or special prompts on browsing pages). Material changes referred to in this Policy include, but are not limited to:  

2.1 Significant changes in our service model, such as the purposes of processing user information, the types of user information processed, and the ways user information is used;  

2.2 Significant changes in our ownership structure, organizational structure, etc., such as ownership changes due to business adjustments, mergers, acquisitions, etc.;  

2.3 Changes in the main recipients of user information sharing, transfer, or public disclosure;  

2.4 Significant changes in your rights regarding user information processing and the ways to exercise them;  

2.5 Changes in the department responsible for user information security, contact methods, and complaint channels;  

2.6 When the user information security impact assessment report indicates a high risk.  

3. If there are updates, we will also archive the old version of this Policy for your reference.  

How to Contact Us  

If you have any questions, comments, or suggestions regarding this Policy or matters related to your user information, you can contact us through the following channels, and we will make every effort to answer or handle them: call [4000069898] or [4006561010], or visit the official website of the product or service you use for online consultation.  

Lssuer: Ganzhou Achteck Tool Technology Co., Ltd.