Personal Information Protection Policy

In order to effectively protect the personal information of the users of DZZN.COM website and optimize the user experience, DZZN (hereinafter referred to as "we" or "us", the actual operator of DZZN.COM website) has formulated the "DZZN.COM Personal Information Protection Policy" (the "Policy") in accordance with the current regulations and policies. (the "Policy"). This Policy will explain in detail the policies and measures of Mass Intelligence in acquiring, managing and protecting users' personal information. This Policy applies to all services provided by Mass Intelligence to you, regardless of whether you obtain Mass Intelligence services through computer devices, mobile terminals or other devices. In order to effectively protect the personal information of Volkswagen Intelligence users and optimize the user experience, Volkswagen Intelligence (hereinafter referred to as "we" or "us") has formulated the "Volkswagen Intelligence Personal Information Protection Policy" (the "Policy") in accordance with the current regulations and policies. This Policy will explain in detail the policies and measures of Mass Intelligence in acquiring, managing and protecting users' personal information. This Policy applies to all services provided by Mass Intelligence to you, regardless of whether you obtain Mass Intelligence services through computer devices, mobile terminals or other devices.

If you have any questions about this Policy or related matters, you may contact us at any time by visiting the Mass Intelligence online contact form, the official Mass Intelligence service account, or by calling any of our customer service numbers, among many other ways.

This policy will help you understand the following:

1. Collection of personal information

2、The use of cookies and web beacons

3. Use of personal information

4. Protection of personal information and security measures

5. Storage of personal information

6. Sharing, transfer and public disclosure of personal information

7. Management of personal information,

8. Special protection of minors' personal information

9. Revision of Personal Information Protection Policy

10. Dispute resolution

This Policy is a fundamental legal document for your use of the Mass Intelligence Services and its various functions. We hope that you will read it carefully and make it clear that you fully understand and accept the contents of this Policy before using the Mass Intelligence Services, and we hope that you will be able to make appropriate choices based on your own understanding. We endeavor to express the relevant terms involved in this Policy through plain language and provide links to further explanations for your better understanding. By continuing to use our products and/or services after we have updated this Policy (and we will promptly alert you to such updates), you agree to the contents of this Policy (including the updated version) and consent to our collection, use, retention and sharing of your relevant information in accordance with this Policy.

The personal information covered by this policy includes: basic personal information (including personal name, birthday, gender, address, personal telephone number, e-mail address); personal identification information (including identity card, military officer's card, passport, driver's license, relevant identification, etc.); personal location information; network identification information (including system account number, IP address, e-mail address, and passwords and passwords related to the foregoing); Address book; personal Internet access records (including search records, software usage records, click records); personal common device information (including hardware model, device MAC address, operating system type, software list, unique device identifier (such as IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information, etc.) describing the basic situation of personal common device information). (information that describes the basic information of the device that the individual uses frequently).

Personal sensitive information refers to personal information that may jeopardize the safety of persons and property once it is leaked, illegally provided or misused, and is highly likely to lead to damage to one's reputation, physical and mental health, or discriminatory treatment, etc. The personal sensitive information involved in this policy includes: personal identification information (including ID cards, military officer's cards, passports, driver's licenses, household registers, and related identification certificates, etc.); network identification information (including account names, account nicknames, email addresses and passwords and password protection questions and answers related to the foregoing); and other information (including address books, personal phone numbers, cell phone numbers, trip information, web browsing records, precise location information, bank accounts). For personal sensitive information, we will prominently identify it in this policy, so please take care to read it carefully.

Collection of personal information:

You are aware and agree that when you register for an account with Volkswagen Intelligence or use the services provided by Volkswagen Intelligence, Volkswagen Intelligence will record the relevant personal information provided by you, such as passwords, cell phone numbers, etc., and that the abovementioned personal information is the basis for you to obtain the services provided by Volkswagen Intelligence. At the same time, for the purpose of optimizing user experience, Volkswagen Intelligence will obtain other information related to the enhancement of Volkswagen Intelligence's services. For example, when you visit Volkswagen Intelligence, we may collect information on the popularity of our services, browser software information, etc. in order to optimize our services.

Before you use Mass Intelligence, we will direct you to read this policy and obtain relevant personal information about you based on your acceptance of this policy. If you do not agree to provide personal information, you will not be able to use all or part of Mass Intelligence's features and services, or to obtain more personalized features, or to participate in certain activities, or to receive notifications from us, etc.

Volkswagen Intelligence will only collect your personal information when the following circumstances arise:

When you register for a Volkswagen Intelligence account, we collect your account nickname, gender, password, password protection options, email address, cell phone number, and birth/age information. If you log in to Volkswagen Intelligence by other means of association, we may request your personal information from the associated third party, and we may still ask you for personal information that we request but that the third party is unable to provide. This information is collected to help you create a Volkswagen Intelligence account, and if you refuse to provide this information, it will affect your ability to register to use Volkswagen Intelligence. When you register to use Volkswagen Intelligence, we will verify your real name, if you refuse to provide the relevant information, Volkswagen Intelligence will not be able to provide services to you.

When you send Mass Intelligence and use the location-based services provided by Mass Intelligence, we collect your location information and device information. This information is collected in order to provide you with check-in information sharing services, or to provide you with more accurate and personalized services and protect your account security. Volkswagen Intelligence guarantees that no other irrelevant information will be collected when your device uses the location services.

When you use the search services provided by Volkswagen Intelligence, we will collect your keyword information, search history, device information, and in order to provide efficient search services, some of this information will be temporarily stored in your local storage device. Here, you should note that your keyword information cannot identify you individually and is not your personal information, so we have the right to use it for other purposes; only if your search keyword information is linked to other information about you and can identify you individually, we will treat your search keyword information as your personal information, together with your search history, for the duration of the combined use in accordance with this policy. Only if your search term information is linked to other information that identifies you personally, then we will treat your search term information as your personal information during the period of combined use, together with your search history, in accordance with this policy.

Name, ID number, occupation, and related identification information is collected to complete your identification. Mass Intelligence will maximize the protection of this private information about you, if you do not provide this information, we will not be able to provide the relevant services. For some accounts involved in the dissemination of public information, such as real-name official accounts, we will force the collection of ID information of the main responsible person to ensure the maintenance of public communication order. Except for such cases, Mass Intelligence generally does not compulsorily collect user ID information.

When you participate in marketing activities related to Mass Intelligence, we collect information such as your name, school name, mailing address, contact information, and bank account number. This information is the basis for you to receive transfers or gifts, and if you refuse to provide this information, we will not be able to transfer or issue gifts to you.

Mass Intelligence collects information about the specific location of your device if you wish to obtain information about your city. No other information about your device will be included in the information collected by Mass Intelligence.

When you use a service provided by a third party in Mass Intelligence, you need to allow the third party to collect your order information, payment information, etc. If you refuse to allow the third party to collect such information when providing the service, it may result in your inability to use the third party's service in Mass Intelligence.

Based on the effective protection of your information, we will de-identify the information we collect from you in order to protect the security of your information. We would like you to understand and accept that on the premise of de-identifying your information collected and not disclosing your personal information, Mass Intelligence has the right to analyze and commercially exploit the de-identified information.

When you log in third-party apps through Volkswagen Smart, the third party may obtain your personal nickname, avatar and other information through Volkswagen Smart. If you refuse to provide such information to the third party, you can turn it off in the relevant settings of Volkswagen Intelligent, the path of turning it off: Volkswagen Intelligent PC-me-Management Center-My Apps-Delete Third Party Apps.

Mass Intelligence may collect your personal information without your consent or authorization when it involves national security and interests, social public interests, relevant activities related to crime investigation, or when it involves the safety of your life and property or that of others but your timely authorization cannot be obtained under special circumstances, as well as when it is able to obtain it from other lawful and open channels or in other cases as stipulated by laws and regulations.

Under certain special circumstances, Volkswagen Intelligence may ask you to provide paper copies of relevant certificates and other information. If you provide such paper-based information as requested, Mass Intelligence will properly process your information and promptly inform you within 30 days of receiving your paper-based information.

In addition, if Volkswagen Intelligence obtains your personal information outside of the above scenarios, Volkswagen Intelligence will obtain your express consent again and fully explain the application scenarios and the content and scope of the information obtained from you before obtaining your express consent.

Use of cookies and web beacons:

Cookies can help websites recognize registered users and count the number of users, and are often used by websites to determine whether a user who has completed registration has logged in. Volkswagen Intelligent promises that the research of cookie information will only be used for the purpose of improving the quality of service/product and optimizing the user experience. At the same time, if you do not want your personal information to be retained in cookies, you can configure your browser to either "reject cookies" or "notify you when a website sends a cookie", and you should be aware that, given that Mass Intelligence's service is You should be aware that, given that VWI's services are enabled by the support of cookies, disabling cookies may affect your access to VWI or prevent you from obtaining full access to VWI's services. When you do not disable cookies, you may be prompted as to whether you want to retain user information the next time you access this site in order to simplify login procedures (e.g., one-click login).

Mass Intelligence uses web beacons in the same way and for the same purpose as cookies.

Use of personal information:

In order to provide you with better services or products, Volkswagen Intelligence will use your personal information in the following circumstances:

  1. In accordance with the requirements of relevant laws and regulations;
  2. According to your authorization;
  3. According to the relevant terms of service of Mass Intelligence, application license and use agreement.

In addition, you are aware and agree that, to the extent permitted by current laws and regulations, Volkswagen Intelligence may use your non-sensitive personal information for marketing purposes, including, but not limited to, the following: Volkswagen Intelligence may use the information provided by you to display or provide you with advertisements and promotional materials in the Volkswagen Intelligence Platforms, to notify you of, or to recommend to you, information about Volkswagen Intelligence's services or products, and other such information that it believes may be of interest to you in light of your use of the services or products of Volkswagen This also includes information that you choose to share when you take an action such as authorization, for example, when you add a new friend, add a new landmark to your newsfeed, or use VW's contact import tool.

Protection of personal information and security measures:

1. Mass Intelligence will make every reasonable effort to protect the personal information of users that we obtain, and the personal information will be protected by a specialized data security department. In order to prevent unauthorized access, copying, modification, transmission, loss, destruction, processing or use of users' personal information in an accidental and unauthorized manner, Mass Intelligence has taken and will continue to take the following measures to protect your personal information:

  1. Our web services adopt encryption technologies such as Transport Layer Security Protocol and provide browsing services via https and other means to ensure the security of user data during transmission.
  2. Personal information of users is encrypted and stored by adopting encryption technology and isolated by isolation technology.
  3. When personal information is used, such as the display of personal information and the calculation of personal information, we use a variety of data desensitization techniques, including content replacement and encryption and desensitization, to enhance the security of personal information in use.
  4. Setting up a strict data use and access system, adopting strict data access authority control and multiple identity authentication technology to protect personal information and avoid data being used in violation of the law.
  5. Adoption of specialized data and technical security audits, setting up of log audits and behavioral audits, among other measures.

2. Other security measures taken to protect personal information

  1. Manage and regulate the storage and use of personal information by establishing a data classification and grading system, data security management standards, and data security development standards.
  2. Establish a special data security department, responsible for security emergency response organization, to promote and safeguard personal information security.
  3. Strengthening security awareness. We also organize security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

3. Notification of personal information security incidents

  1. In the event of a security incident related to personal information, Volkswagen Intelligence will report the incident to the appropriate competent authorities in the first instance, and will promptly investigate the problem and carry out emergency measures.
  2. Send a notification to the full volume of users to remind them to change their passwords, or reach out to them by various means such as phone calls and SMS to make them aware of it, and operate and publicize it on the Mass Intelligence public operation platform to stop data leakage.

Despite having taken reasonable and effective measures as described above, and having complied with the standards required by relevant laws and regulations, Mass Intelligence is still unable to guarantee the security of your personal information when it is communicated through unsecured means. Therefore, users should take active measures to ensure the security of their personal information, such as changing their account passwords on a regular basis and not disclosing their account passwords and other personal information to others.

You are aware that the personal information protection measures provided by Mass Intelligence are only applicable to the Mass Intelligence Platform. Once you leave Mass Intelligence and browse or use other websites, services and content resources, Mass Intelligence has no ability and obligation to protect any personal information submitted by you on websites other than Mass Intelligence, regardless of whether your access to or browsing of the said websites is based on the links or guidance of Mass Intelligence.

There is always a risk of information leakage in the network environment. When there is an accident, force majeure or other circumstances that lead to the leakage of your information, Mass Intelligence will endeavor to control the situation and promptly inform you of the cause of the incident, the security measures taken by Mass Intelligence, and the security measures that you can take on your own initiative, and so on.

Storage of personal information:

Mass Intelligence will take appropriate security measures and technical means to store and protect your personal information against loss, misuse, unauthorized access or disclosure, alteration or destruction. Your personal information is stored in password-controlled servers located in China and access to them is restricted. When you need cross-border information transfer services, Mass Intelligence will default you to continue to use servers in China.

Volkswagen Intelligence will store your personal information for different periods of time according to different levels of personal information, and the storage period is strictly in accordance with the law and relevant regulations, with a minimum period of not less than 6 months. We will store your personal information in accordance with the period stipulated in the Network Security Law and the Electronic Commerce Law. We will delete or anonymize your personal information after the legal retention period.

If you terminate your use of the Volkswagen Intelligence software and services, we will stop collecting and using your information, unless otherwise required by law or regulation. If we cease to operate, we will stop collecting and using your personal information. We will delete or anonymize the information after 6 months of the user's cancellation.

We allow access to personal information only to third parties, such as Volkswagen Intelligence employees, who have a need to know the information and who are required to fulfill appropriate confidentiality obligations.

Volkswagen Intelligence will clearly notify users and obtain their consent if it involves the transmission of personal information outside the country.

Sharing, transfer, and public disclosure of personal information:

1. We treat your information with a high degree of diligence. We do not share or transfer identifiable personal information to third parties unless you have given us your prior authorized consent. We may share and transfer de-identified personal information and ensure that the third party sharing the information cannot re-identify the natural person subject of such information. We may share your personal information with third parties under certain conditions, but we will only share personal information that is necessary and the third parties are bound by the purposes stated in this policy. We will require third parties to protect your personal information and to comply with applicable laws, regulations and regulatory requirements. If a third party wishes to change the purposes for which personal information is processed, it will again seek your authorization.

You consent to us sharing information with the following types of third-party authorized partners:

(1) We may share your information with business partners in order to fulfill certain functions. Some of our services will be provided by authorized partners. We may share some of your personal information with our partners to provide better customer service and user experience. We share this information only to fulfill the purposes stated in this policy. For example, when third-party software or device systems are used in conjunction with Volkswagen Intelligence products or services to provide you with location-based services, Volkswagen Intelligence may collect your location information and device information based on your authorization and settings for the system location (such as) Hardware model, operating system version number, International Mobile Equipment Identifier (IMEI), network device hardware address (MAC)), and provide them to the aforementioned partners after de-identification, and under special circumstances, they may also contain contact information that you have filled in separately. If you refuse the collection and use of such information, you will need to configure the system of your device or turn off the software that provides the service, and it is not possible to automatically or manually configure Volkswagen Intelligence to turn off the relevant service. We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and only the personal information that is necessary to provide the service. Our partners are not authorized to use the shared personal information for any other purpose.

(2) We may share de-identified or anonymized information with our advertising partners for the purpose of programmatic ad push. Without your authorization, we will not share your personally identifiable information (meaning information that identifies you, such as name or email address, by which you can be contacted or identified) with service providers that serve ads. However, we may share your anonymized user profile with ad service providers to help them increase the effective reach of their ads without identifying you personally. For example, only after an advertiser agrees to abide by our ad delivery practices may we tell advertisers how effective their ads were or how many people viewed their ads or installed apps after seeing an ad, or provide these partners with statistical information that is not personally identifiable (e.g., "Female, 25-29 years old, located in Beijing ") to help them understand their audience or customers. You may refuse to allow us to push programmatic ads to you, without affecting your use of other services.

(3) We may share your information with third parties to help you participate in marketing and promotional activities. When you choose to participate in the relevant marketing activities organized by us, depending on the needs of the activities, you may provide us with your name, mailing address, contact information, bank account number. With your express consent, we may share this information with third parties so that we can engage them to provide services to you in a timely manner.

2. We investigate the data security environment of companies, organizations and individuals with whom we share personal information, enter into strict confidentiality agreements with them, and require them to handle personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

3. As we continue to develop our business, we and our affiliates may engage in mergers, acquisitions, asset transfers, or similar transactions, and your personal information may be transferred as part of such transactions, we will notify you prior to the transfer, and we will either continue to protect, or require the new controller to continue to protect, your personal information in accordance with the laws and regulations, and to a standard no less stringent than the one required by this Privacy Policy.

4. We will not share, transfer, or publicly disclose your personal information to any company, organization, or individual other than the Company and its affiliates without your permission, except in the following circumstances:
(1) obtaining your prior expressly authorized consent;
(2) You share, transfer, or disclose to a third party on your own;
(3) Directly related to national security, national defense security, public safety, public health, and public interest;
(4) The disclosure or provision of personal information is made in accordance with applicable laws and regulations, the requirements of legal procedures, mandatory administrative and judicial requirements, or the personal information provided to the public is directly related to the investigation, prosecution, trial, and execution of judgment of a crime. In the aforementioned cases, we will provide/disclose your personal information based on the type and manner of personal information we are required to provide or disclose. Subject to laws and regulations, when we receive a request for disclosure of information as described above, we will require that the requesting party must produce appropriate legal documents, such as a subpoena or letter of inquiry. We will scrutinize all requests carefully to ensure that they have a legal basis and that the requested data is limited to data that the administrative and judicial authorities have a legal right to obtain for specific investigative purposes;
(5) Within the scope permitted by laws and regulations, necessary to protect the legitimate rights and interests of other users of Volkswagen Intelligence, the Company, its affiliates, and its controlling companies, including life and property, or to maintain the safe and stable operation of the products or services, such as detecting, preventing, and dealing with fraudulent and other unlawful activities, as well as reducing credit risks, etc.; however, this does not include Disclosure or provision of personal information to the public for profit in violation of the commitments made in this policy;
(6) The Company shall file a lawsuit or arbitration against the User to protect its legal rights and interests;
(7) In the event of a merger, demerger, acquisition, transfer of assets or similar transaction involving the transfer of personal information, the Company will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy, or else the Company has the right to require that company or organization to re-obtain your authorized consent;
(8) Collecting personal information from lawful publicly disclosed information, such as lawful news reports, government information disclosure and other channels;
(9) When de-identifying personal information contained in the results of academic research for the purpose of academic research, or for an academic research organization that is necessary to carry out statistical or academic research in the public interest, and when providing the results of academic research or descriptions to the public, the personal information contained in the results is de-identified;
(10) Other cases stipulated by laws and regulations.

5. You should understand that, in the course of using the services of Volkswagen Intelligence, you may send your personal information such as photos, identity information and location information to specific people, and you may also share your personal information such as photos, location information and identity information to unspecified people based on the services of Volkswagen Intelligence. If your personal information becomes known to others as a result of such active sharing or disclosure, Volkswagen Intelligence shall not be responsible for it.

Once you have completed your Mass Intelligence account registration and performed reasonable and necessary identity verification, you may access, modify, and delete the personal information you have submitted to Mass Intelligence. In general, you may access, modify, and delete the information you submit at any time.

Mass Intelligence always puts the protection of your personal information in the first place, and at the same time, Mass Intelligence values your concern for your personal information. For your personal information, you can check, modify and delete it online through cell phone clients and other means.

You have the right to update or correct your personal information on your own, or authorize Volkswagen Intelligent Customer Service to update or correct your information. Before you update and correct your information, we will first verify your identity, and you will be able to correct and update your information only after your identity is verified.

If you have any comments or suggestions about this policy or its functions relating to the collection, use, storage and protection of your personal information, you can provide feedback or complaints through the Volkswagen Intelligence function page, or the Volkswagen Intelligence customer service channel, and Volkswagen Intelligence will respond to you with feedback information at the first time of receiving your comments and suggestions.

You can prevent Volkswagen Intelligence from obtaining your personal information by turning off some of the features of Volkswagen Intelligence, and after turning off some of the features, we will not be able to provide you with the appropriate services.

You can independently request to cancel your Volkswagen Intelligence account to ensure that Volkswagen Intelligence no longer collects your personal information. You can cancel your account through the mobile client. Before you cancel your account, Volkswagen will verify your personal identity, security status, frequently used devices and other information. The act of canceling your account is an irreversible act. Once you cancel your account, Mass Intelligence will instantly delete all information about your account and ensure that such information will not be leaked, and you will not be able to access Mass Intelligence's services through your canceled account.

If we terminate our services or operations, we will give you at least thirty days' notice and delete or anonymize your personal information upon termination.

Special protection of minors' personal information:

If you are a minor under the age of 18, you should read and decide whether to agree to this Personal Information Protection Policy under the supervision and guidance of your parents or other guardians before using the "Volkswagen Intelligence" software and related services, and the Company will protect the personal information of minors in accordance with relevant national laws and regulations.

If you are a child under the age of 14, we must ask your parent (guardian) for consent to collect your personal information. If you wish to use our services, please inform your parents, who should go to the "Teen Mode" in Mass Intelligence and learn more about the Mass Intelligence Children's Personal Information Protection Policy.

Revision of the personal information protection policy:

1. In order to provide you with better service and as our business develops, this policy will be updated. However, we will not reduce your rights under the Personal Information Protection Policy currently in force without your express consent.

We will issue an updated version on our website and mobile and remind you of the update of the relevant content through website announcements or other appropriate means before it takes effect, so that you can keep abreast of the latest personal information protection policy.

2. For major changes, we will also provide a more prominent notice (we will explain the specific changes to our personal information protection policy by means including, but not limited to, emails, SMS, private messages, or special notices on the browsing page).

Significant changes referred to in this policy include, but are not limited to:
(1) Significant changes in our service model. For example, the purpose of processing personal information, the type of personal information processed, and how personal information is used;
(2) Significant changes in our ownership structure, organizational structure, etc. For example, changes in ownership due to business restructuring, bankruptcy and mergers and acquisitions, etc;
(3) Changes in the primary recipients of personal information to be shared, transferred or publicly disclosed;
(4) Significant changes in your right to participate in the processing of personal information and the manner in which you exercise it;
(5) In the event of a change in the department responsible for handling the security of personal information, contact information and complaint channels;
(6) When the personal information security impact assessment report indicates a high risk.

Dispute Resolution:

When any dispute arises between you and Mass Intelligence due to the implementation of this Policy, the two parties shall first negotiate an amicable settlement; if no settlement can be reached through negotiation, both parties shall have the right to file a lawsuit with a court of competent jurisdiction in accordance with the Registration Agreement.

If you have any questions about this Personal Information Protection Policy, please contact us at: E-mail: xs#dzzn.com(# change @)

We will solve your problem in a timely manner.