Updated on August 22, 2024

　　Phoenix Society has formulated this privacy policy to explain how we collect, use, store, share, and transfer your personal information. This privacy policy applies to the processing of your personal information when you use our Chinese website (clubphoenix.cn, hereinafter referred to as "this website") and the Internet services we provide to you through this website (hereinafter collectively referred to as "services").

　　This privacy policy is only applicable to personal information processing activities in the mainland of the People's Republic of China (hereinafter referred to as "Chinese Mainland"), and applicable to the Personal Information Protection Law of the People's Republic of China and other relevant laws and regulations in the mainland of the People's Republic of China (hereinafter referred to as "relevant laws and regulations").

　　Before you start browsing this website or providing us with your personal information, please be sure to carefully read and understand this privacy policy. This privacy policy is closely related to the services you use. We hope that you have carefully read and confirmed that you have fully understood the content stated in this privacy policy before use, and that you can make appropriate choices according to the guidance of this privacy policy. The clauses in this privacy policy that may have a significant impact on your rights have been distinguished in bold font. Please review them carefully. If you do not agree with any content of this privacy policy, you should immediately stop using our services, and we will not be able to provide services to you. Your use of our Internet service means that you have read and agreed that we collect, use, store, share, publicly disclose and protect your relevant information in accordance with this privacy policy. After the update of this privacy policy, we will promptly publish and publicize the latest version on the website for you to check in a timely manner.

　　Please note that we have tried our best to formulate and implement this privacy policy in accordance with the latest laws, regulations, departmental rules, normative documents and the latest national standards in Chinese Mainland. However, due to the possibility of changes and modifications to the aforementioned regulations, it cannot be ruled out that different regulatory departments and personnel may have various interpretations and limitations of the same regulation. In case of any inconsistency or contradiction between the provisions of this privacy policy and the relevant laws and regulations in force in Chinese Mainland at that time, the provisions of the laws and regulations in force in Chinese Mainland at that time shall prevail. We will also process your personal information and protect your personal information rights and interests in accordance with the provisions of the laws and regulations in force at that time.

　　This privacy policy helps you understand the following:

　　1、 Basic definition and scope of application

　　2、 How do we collect and use your personal information

　　3、 How do we use cookie technology

　　4、 How do we entrust the processing, sharing, transfer, and disclosure of your personal information

　　5、 How do we store your personal information

　　6、 Automated decision-making

　　7、 Do not track "signal response

　　8、 Your rights

　　9、 How do we handle information about minors

　　10、 How can your personal information be transferred globally

　　11、 How do we protect your personal information

　　12、 Update to this Privacy Policy

　　13、 How to contact us

　　1、 Basic definition and scope of application

　　(1) Basic Definition

　　Personal information: Personal information refers to various information related to identified or identifiable natural persons recorded in electronic or other forms, excluding anonymized information.

　　Sensitive personal information: Sensitive personal information refers to personal information that, once leaked or illegally used, can easily lead to the infringement of a natural person's personal dignity or endanger their personal and property safety. We will inform you separately and remind you to pay attention before collecting your sensitive personal information.

　　Personal information processor: refers to an organization or individual who independently decides the purpose and method of processing in personal information processing activities.

　　The undefined meanings of relevant terms in this privacy policy shall be consistent with the meanings of relevant laws and regulations such as the Personal Information Protection Law of the People's Republic of China, unless otherwise specified.

　　(2) Scope of application and exceptions

　　This privacy policy applies to the services we provide, but does not apply to products and/or services for which we have independent personal information processing rules. For personal information collected by the aforementioned products and/or services, you will need to refer to the personal information processing rules provided in the product and/or service separately.

　　The services we provide may contain domain links to third-party websites, products, and services. All links containing third-party websites, products, and services are provided for your convenience only. We have no control over such third parties and their linked content, and cannot provide any express or implied warranties regarding the linked content. Such links cannot be considered as our recommendation or authorization of the linked content. These third parties are subject to their personal information processing rules, therefore, before submitting personal information to these third parties, you need to separately review the personal information processing rules notified by the subject.

　　2、 How do we collect and use your personal information

　　We will follow the principles of legitimacy, legality, necessity, and good faith, and for the clear and reasonable purposes described in this privacy policy, collect and use personal information that you voluntarily provide or generate as a result of using our services in a manner that minimizes the impact on your rights. If you provide personal information of anyone other than yourself, you must ensure that they understand how their personal information will be processed and that they have agreed to your disclosure and processing of their personal information to us and our outsourcing service providers.

　　We collect and process your personal information based on your consent in principle. If we want to use your personal information for other purposes or purposes not specified in this privacy policy, or if the processing method and type change, we will inform you in a reasonable manner and obtain your consent again when processing personal information based on your consent.

　　(1) We will collect and use the following types of personal information from you for the following purposes and through the following methods

　　Financing plan communication. When you voluntarily provide us with the email address on this website（ bpchina@hongshan.com ）When sending financing plans, business plans, and other materials, we may collect your name, email address, and other contact information to contact you, as well as the personal information you provide in the email (if any, we recommend that you only include the necessary types of personal information for communication with us in the content sent to the above email).

　　Safety risk control and information statistics. In order to ensure the network security and operational security of this website, we will automatically collect your device information, browser and computer or device type, access time, IP address and other information (which we will collectively refer to as "usage data" in this privacy policy) for verification, to monitor and prevent fraudulent activities, network attacks, and information theft.

　　(2) Reminder on Sensitive Personal Information

　　The information you upload while using our services does not exclude the possibility of sensitive personal information related to you. Please be cautious and pay attention to the provision of your sensitive personal information. You agree that we may process your sensitive personal information for the purposes and in the manner described in this privacy policy.

　　(3) Other lawful reasons except for the same

　　According to relevant laws and regulations, we may collect and use necessary personal information without your authorization and consent in the following situations:

　　Necessary for the conclusion and performance of a contract to which you are a party;

　　Necessary to fulfill our legal duties or obligations;

　　Necessary to respond to sudden public health emergencies or to protect the life, health, and property safety of natural persons in emergency situations;

　　In accordance with the provisions of the Personal Information Protection Law of the People's Republic of China, handle personal information that individuals disclose on their own or other legally disclosed personal information within a reasonable scope;

　　Other circumstances stipulated by laws and administrative regulations.

　　3、 How do we use cookie technology

　　We may use cookie technology to collect your use of Internet services to verify your identity, remember your preferences, customize Internet services according to your access preferences, meet your interests, and improve the quality of Internet services. Generally speaking, you can set your browser to not accept cookies, or adjust the cookie settings when you receive cookie notifications. Please note that if you set your browser to not accept cookies, you may not be able to use some Internet services properly. We promise not to use cookies for any purposes other than those described in this privacy policy.

　　4、 How do we entrust the processing, sharing, transfer, and disclosure of your personal information

　　(1) Entrusted processing

　　In order to provide you with Internet services or achieve the purpose of using the above information, we may entrust other companies and individuals (hereinafter collectively referred to as "third-party service providers" or "entrusted parties") to process your personal information on our behalf, such as analyzing data and providing some Internet services. We will entrust third-party service providers to collect and process your name and other information.

　　We will reasonably review the personal information protection capabilities of third-party service providers entrusted by us to process personal information, sign strict confidentiality agreements or legal documents with them, stipulate the purpose, duration, processing methods, types of personal information, protection measures, and rights and obligations of both parties, require and supervise the entrusted party to strictly comply with this privacy policy, and require the entrusted party to take sufficient organizational or technical measures to protect your privacy and personal information. When the trustee no longer provides services to you, we will delete or notify the trustee to delete your personal information.

　　(2) Sharing

　　Sharing refers to the process in which we provide personal information to other personal information processors, and both parties have independent control over the personal information. Generally, we do not share your personal information with external parties, except in the following situations:

　　Sharing with separate consent: With your separate consent or initiated voluntarily, we will share information within your authorized scope with a third party designated by you;

　　Sharing under legal circumstances: We may share your personal information with external parties in accordance with laws and regulations, litigation dispute resolution needs, or as required by administrative or judicial authorities in accordance with the law.

　　(3) Transfer

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

　　Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

　　When it comes to mergers, acquisitions, or bankruptcy liquidation, if there is a transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this privacy policy. Otherwise, we will require the company or organization to seek your authorization and consent again.

　　(4) Public disclosure

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

　　After obtaining your explicit consent;

　　Legal Disclosure: We may publicly disclose your personal information in the event of legal, procedural, litigation, or mandatory requirements from government authorities.

　　5、 How do we store your personal information

　　Your personal information collected and generated by us in Chinese Mainland will be stored in Chinese Mainland.

　　We only store your personal information for the period necessary for the purposes stated in this privacy policy and within the time limits specified by laws, regulations, and regulatory requirements. We will keep network logs obtained through technical measures such as monitoring and recording network operation status and network security events for no less than 6 months. Unless otherwise agreed by law or relevant regulations, we will retain your personal information for the period necessary for the purpose of providing services, unless you request us to delete it immediately or as otherwise provided by law and regulations.

　　If we terminate the service or operation, we will promptly cease the activity of collecting your personal information, and will comply with relevant laws and regulations to notify you in advance. After terminating the service or operation, we will delete or anonymize your personal information, except as otherwise provided by laws, regulations or regulatory authorities.

　　6、 Automated decision-making

　　We will not use your personal information for automated decision-making.

　　7、 Do not track "signal response

　　Most browsers have a 'Do Not Track' (DNT) feature, which you can activate to prevent monitoring and collection of data about your online browsing activity. Due to the lack of unified standards in relevant laws and regulations on how to interpret DNT signals and how websites and third parties receiving these signals should take action, Phoenix will not respond to DNT signals at this time. But you can control the website's collection and use of your usage data by setting cookies, web beacons, and similar technologies used to collect your usage data on your browser. We will monitor in real-time the introduction and updates of relevant laws and regulations regarding DNT requirements.

　　8、 Your rights

　　As a personal information subject, you have the following rights:

　　(1) View and copy your personal information

　　You have the right to contact our staff at any time to access and copy the personal information you provide to us, subject to compliance with relevant laws and regulations.

　　(2) Correct and supplement your personal information

　　If you find that there are errors in the personal information you provided to us that need to be corrected, or if you need to supplement your personal information, you can contact our staff at any time to respond to your request.

　　(3) Transfer your personal information

　　If you request the transfer of personal information to your designated personal information processor and meet the conditions stipulated by laws and regulations, we will provide you with a means of transfer.

　　(4) Delete your personal information

　　You have the right to contact our customer service personnel at any time to delete your personal information. In the following situations, you can request us to delete your personal information:

　　The processing purpose has been achieved, cannot be achieved, or is no longer necessary to achieve the processing purpose;

　　We have ceased providing services or the retention period has expired;

　　You withdraw your consent;

　　We violate laws and regulations or violate agreements in handling personal information;

　　Other circumstances stipulated by laws and regulations

　　If the retention period stipulated by laws and regulations has not expired, or if it is technically difficult to delete personal information, we will cease processing other than storage and taking necessary security measures.

　　If we decide to respond to your deletion request, we will also request our third-party partners to delete it in a timely manner, unless these entities have obtained your independent authorization separately. However, please be aware that if your public information on Phoenix Club is captured, cached, stored, copied by other users or independent third parties who are not cooperating, associated, or controlled by us, or uploaded or saved by other users on other applications, the relevant information will not be under our control.

　　(5) Change or withdraw consent

　　The services provided by Phoenix Club require some basic personal information to be completed. You may give or revoke your authorization and consent at any time for the collection and use of additional personal information. You have the right to change or withdraw your consent to our processing of personal information. But your change or withdrawal of authorization consent does not affect the personal information processing that we have already carried out based on your consent before the change or withdrawal. We will not refuse to provide services on this grounds, except for processing personal information that is necessary for providing service related functions.

　　(6) In response to your above request

　　You can send an email to bpchina@phoneixclub.cn Exercise your rights in a certain way. To ensure safety, you may need to provide a written request or prove your identity in other ways. We may first require you to verify your identity before processing your request.

　　We will respond to your request within 20 days after confirming your identity. You can contact us through the contact information provided in this privacy policy. For your reasonable requests, we generally do not charge any fees, but for requests that are repeated multiple times or exceed reasonable limits, we will charge a certain cost fee depending on the situation. We may refuse requests that are unnecessarily repetitive, require excessive technical means (such as developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are very unrealistic (such as involving information stored on backup tapes).

　　In the following situations, as required by laws and regulations, we will not be able to respond to your request:

　　Related to our obligations under laws and regulations;

　　Directly related to national security and defense security;

　　Directly related to public safety, public health, and major public interests;

　　Directly related to criminal investigation, prosecution, trial, and execution of judgments;

　　There is sufficient evidence to suggest that you have subjective malice or abuse of power;

　　Responding to your request will result in serious harm to your or other individuals' or organizations' legitimate rights and interests;

　　For the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property, but it is difficult to obtain my authorization and consent;

　　Involving trade secrets.

　　9、 How do we handle information about minors

　　We do not collect personal information from minors, and the target audience of the website is not minors.

　　10、 How can your personal information be transferred globally

　　In principle, the personal information we collect and generate in Chinese Mainland will be stored in Chinese Mainland.

　　If you need to provide your personal information overseas, we will perform necessary legal obligations in accordance with the provisions of relevant laws and regulations, including but not limited to (if involved) conducting data exit security assessment, signing personal information exit standard contracts with overseas recipients or conducting personal information security certification, and inform you of the identity of the overseas recipient, contact information, processing purpose, processing method, type of personal information, and how you exercise your legal rights to the overseas recipient, and obtain your consent to ensure that your above information is adequately and equally protected in Chinese Mainland.

　　11、 How do we protect your personal information

　　We have implemented a series of data security technology and organizational measures to help protect your personal information from leakage, loss, abuse, or unauthorized access or disclosure.

　　Please understand that the Internet environment is not 100% secure, and we will try our best to ensure the security of any information you send us. After the unfortunate occurrence of a personal information security incident, we will promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you in accordance with the requirements of laws and regulations. We will promptly inform you of the relevant situation of the event by sending an email (if you have provided relevant contact information). When it is difficult to inform individual information subjects one by one, we will adopt a reasonable and effective way to issue announcements. At the same time, we will proactively report the handling of personal information security incidents in accordance with regulatory requirements. If your legitimate rights and interests are damaged, we will bear corresponding legal responsibilities.

　　12、 Update to this Privacy Policy

　　We may update this privacy policy from time to time.

　　We will not restrict your rights under this privacy policy without your explicit consent. We will post any changes made to this privacy policy on the relevant page (website homepage - bottom - legal).

　　For changes in personal information processors, processing purposes, processing methods, types of personal information processed, retention periods, data subject rights, etc., we will notify you of the changes through email or by posting notices in relevant areas on our website.

　　Any updates to this privacy policy will take effect from the date specified therein.

　　13、 How to contact us

　　If you have any questions about this privacy policy, please feel free to contact us at the email address below:

       bpchina@phoneixclub.cn