I How We Collect and Use Your Personal Data

Personal data refers to all kinds of information related to identified or identifiable natural persons as recorded by electronic or other means, excluding information after anonymization.

1. Basic Functions That Require Collecting and Using Your Personal Data

The purpose of collecting personal data is to provide you with products and/or services while we ensure that we comply with applicable relevant laws, regulations and other normative documents. Specifically, for the following occasions, you need to agree to provide the following types of information, so that we can safely and effectively realize this basic function. Otherwise, you may not be able to enjoy the corresponding services.

(1) Product/Service Information Displaying

When you browse our websites, in order to display our products and/or services to you, we may collect your IP address, device-related information you use to access the website (such as the type of browser used, operating system information), language used or country, accessing date and time, etc.

2. Additional Features That Require the Collection and Use of Your Personal Data

In order to enable you to better enjoy more functions and enhance your user experience, our websites may support one or more of the following additional features (please confirm whether the website you visit has the following additional features ). We may collect and use your personal data when you use the following additional features. If you do not provide these personal data, you can still use the aforementioned basic functions. However, you may be unable to use additional features that can bring you more excellent services. These additional features include:

(1) Customer Support

When you contact us for support, we may collect the information about your use of our services, including information about our products that you own, your contact information and other necessary information you share with us, so that we can provide customer support and solve your problem.

• Marketing and Promoting

We may provide or promote marketing information for our products and services to you after obtaining your authorization using the contact information, such as your phone number or email address. You can choose to opt out of receiving marketing messages at any time.

3. We Obtain Your Personal Data from a Third Party

Under some circumstances, we may obtain your personal data from a third party as allowed by laws .

If the personal data processing activities we need to carry out for our business development exceed the scope of your original authorization and consent given at the time of data submission to third-party service providers, we will obtain your explicit consent before processing your personal data. In addition, we will strictly comply with relevant laws and regulations and require third-party service providers to ensure the legitimacy of the information they provide.

4. Non-personal Data We Collect

We may also collect other information that cannot directly or indirectly identify specific individuals and is not personal data under locally-applicable laws. Such information is referred to non-personal data. For example, the statistical data generated when you use a specific service, such as the user’s operational behavior (including click, page jumps and browsing time). The purpose of collecting the aforementioned information is to improve the services we provide to you. The type and amount of information  collected depends on how you use our products and/or services. We will summarize such information to help us provide customers with more useful information and understand which parts of our website, products and services customers are most popular among customers. Concerning this Policy, aggregated data is considered non-personal data. If we combine non-personal data with personal data for use, such information will be regarded as personal data.

II Cookies and Other Technologies

Technologies such as cookies, tags, and scripts are used by Brightway and our Third Party Service Providers. These technologies are used to analyze trends, manage the site, track users’ browsing on the website and to gather demographic information about our user base as a whole.

Log Files: As true of most websites, we gather certain information and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically-collected data to other information we gather about you.

Advertising: We partner with our Third Party Service Providers to either display advertising on our website or to manage our advertising on other sites. Our Third Party Service Provider may use technologies such as cookies to provide you with advertising based upon your browsing activities and interests. We will obtain your prior explicit consent and involve a clear affirmative action before providing this advertising service to you.

Local Storage: We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content and preferences. Third parties with whom we partner to provide certain features on our sites or to display advertising based upon your web browsing activity also use HTML5 or Flash cookies to collect and store information. Various browsers may offer their own management tool for removing HTML5 LSOs.

III How We Share, Transfer and Publicly Disclose Your Personal Data

1. Share

During our cooperation with partners, we will follow the following principles:

• Lawful Principle: We will comply with the lawful principle in all data processing activities.
• Proper and Minimum Necessity Principle: The use of data must have a proper purpose and should be limited to the necessary extent to achieve this purpose.
  (3) Security and Prudence Principle: We will carefully evaluate the purpose of our partners’ use of data, comprehensively assess their security protection capabilities, and require them to comply with the legal agreement of cooperation. We will strictly carry out security monitoring on the software development kit (SDK), application program interface (API) and other information obtained by partners to protect data security.

Generally, we will not share your personal data, except for the following cases:

1. After obtaining your explicit consent, Brightway will share the information within your authorization with the third party designated by you.
2. Part of our products and services are provided by third-party service providers, with whom we need to provide some of your personal data, such as IT services, customer support services, email sending services, courier services, after-sales services, marketing promotions, statistical analysis and other similar services to ensure that they can provide services for us. Some data sharing with third parties will be carried out through Application Program Interface (API) and Software Development Kit (SDK). The SDKs of different third parties may vary, and they generally include third-party account login, sharing, third-party payment, manufacturers’ push, statistics, etc. We will conduct strict security testing on the third party and implement data protection measures. Before you enter the third-party page for the first time, the third-party service provider will display the relevant agreements and privacy statements. Please read these agreements and privacy statements carefully.

If we share your personal data with these third parties, we will rely on encryption and other means to ensure your information security. For companies and organizations with whom we share personal data, we will reasonably review their data security environment, sign strict data processing agreements with them, require the said third parties to take adequate protection measures for your information, and strictly comply with relevant laws, regulations and regulatory requirements.

3. When we deem it necessary or appropriate, we shall: (a) comply with locally applicable laws and regulations; (b) comply with legal procedures; (c) respond to requests from public institutions and government authorities, including those outside your country of residence; (d) fulfill our terms and conditions; (e) protect our operations, businesses and systems; (f) protect the rights, privacy, security or property of ours and/or other users, including you; and (g) seek available remedies or limit the damages we may be required to provide.
4. We disclose your personal data to Brightway’s subsidiaries or affiliates to conduct business activities regularly.

2. Transfer

In principle, we will not transfer your personal data to any company, organization or individual. Should it be necessary to do so, we will transfer it in accordance with applicable laws, and inform you of the purpose of the transfer, the personal data involved, the transferee, etc.

Information transfer may occur under the following circumstances:

1. Transfer based on your explicit consent: after obtaining your explicit consent, we will transfer your personal data to other parties.
2. In case of merger, acquisition or bankruptcy liquidation, should personal data transferring be involved, we will require the new company or organization holding your personal data to continue to be bound by this statement. Otherwise, we will require the said company or organization to ask you for authorization and consent again.

3. Publicly Disclose

In principle, we will not publicly disclose your personal data. Should public disclosure be really necessary, we will inform you in advance of the purpose of this public disclosure, the type of information disclosed and the content of personal sensitive information that may be involved, obtain your explicit consent and perform relevant obligations in accordance with locally applicable laws.

We will only publicly disclose your personal data under the following circumstances:

1. After your explicit consent is obtained.
2. Legal disclosure: we may publicly disclose your personal data in compliance with local laws, legal procedures, litigation or mandatory requirements of government authorities.

4. Information That Does Not Require Consent

We may share anonymous information with third parties (such as advertisers on our websites) in the form of aggregation for commercial purposes; we may share with them general usage trends of our services, such as the number of customers in a specific group who buy certain products or engage in certain transactions.

To dispel doubt, we may collect, use or disclose your personal data without your consent as expressly permitted by local data protection laws (e.g. to comply with subpoenas). Besides, we may disclose your information without your consent when we may believe it is necessary to protect our rights, protect your safety or the safety of others, conduct fraud investigations or respond to government requests.

IV How We Store and Protect Your Personal Data

1. Where We Store Your Personal Data

Your personal data is stored on the server according to the region where you live.

2. Storage Period

We retain personal data for a period for the sake of information collection described in this Policy, or we do so in compliance with locally applicable relevant legal requirements. After fulfilling the purpose of personal data collection, or after we confirm your application of deletion or cancellation, or after we terminate the operation of corresponding products or services, we will stop retaining personal data and delete or anonymize it. If it is for public interest, scientific, historical research or statistics, we will continue to retain relevant data based on applicable laws, even if further data processing is irrelevant to the original purpose.

3. Protection Measures

We promise to ensure the security of your personal data. In order to prevent unauthorized access, disclosure or other similar risks, we have implemented reasonable physical, electronic and management measures and processes to protect the information we collect. We will take all reasonable measures to protect your personal data.

We classify your data according to importance and sensitivity and ensure that your personal data is protected at the highest security level. We guarantee that employees and third-party service providers who provide products and services to you by accessing these information have strict contractual confidentiality obligations. If they fail to fulfill these obligations, they will be subject to disciplinary punishment or termination of cooperation. All in all, we regularly review information collection, storage and processing practices, including physical security measures, to prevent unauthorized access and use.

We will take all feasible measures to protect your personal data. However, you should be aware that the Internet is not always safe. Therefore, we cannot guarantee the security or integrity of any personal data during two-way transmission through the Internet..

V Your Rights

According to the applicable laws and regulations of your country or region, you are entitled to relevant rights on any of your personal data (hereinafter referred to as “the Request”) held by us. Most laws require that requests made by individuals should comply with specific requirements, and this Policy requires that your request should meet the following circumstances:

1. Through our special request channel, and for the sake of protecting your information security, your request should be in writing (unless oral application is explicitly recognized by local laws).
2. You should provide sufficient information so that we can verify your identity and ensure that the requester is the subject or a legally authorized person of the requested information.

We have the right to refuse to deal with meaningless/repeated requests, requests for unreasonable technical work, requests that violate the privacy of others, extremely unrealistic requests and requests that do not need to be granted under local law. We may also refuse your request if we believe that some aspects of your request may prevent us from legally using the data for the above-mentioned anti-fraud and security purposes.

Once we have sufficient information to confirm that we can process your request, we will respond to your request within the time specified by applicable data protection laws.

Specifically, you can contact us via privacy@navee.tech to exercise the following rights:

1. Accessing Your Personal Data

Concerning personal data that we have collected and processed, you can gain the access via privacy@navee.tech.

2. Copying Your Personal Data

Based on your requirements and locally applicable laws and regulations, we can provide a record of your personal data we have collected and processed for free. If you make other requests for relevant information, we may charge you a reasonable fee based on relevant applicable laws and the actual management cost.

3. Correcting Your Personal Data

If you believe that any information we hold about you is incorrect or incomplete, you may request correction or addition of personal data for use.

4. Erasing Your Personal Data

According to your locally applicable laws and regulations, you may have the right to ask us to delete your personal data. We will make evaluation according to your request. If the corresponding provisions are met, we will take corresponding steps, including technical means, to deal with it. When you have deleted relevant information or have done so with our assistance, due to applicable laws and security technologies, we may not be able to delete the corresponding information from the backup system immediately. We will safely store your personal data and exempt it from any further processing until the backup can be cleared or anonymization is realized.

5. Withdrawal of Consent

You may withdraw your consent by submitting a request, including the collection, use and/or disclosure of your personal data in our possession or under our control. You can withdraw your consent directly via privacy@navee.tech. We will process your request within a reasonable time after you make your request, and will no longer collect, use and/or disclose your personal data thereafter.

Please note that according to the scope of information you authorize us to process, your withdrawal of consent may result in you not being able to enjoy some services of us. However, your decision to withdraw your consent or authorization will not affect the previous personal data processing based on your authorization.

6. Rights under GDPR

If you are Europe Union user under GDPR, you can exercise the following rights:

1. The right to obtain from us the erasure of your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.
2. The right to obtain from us the restriction of processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.
3. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
4. The right to receive your personal information in a structured, commonly used format and transmit the information to another data controller.

If you are Europe Union user under GDPR, Brightway will provide systematic approach to managing personal data that deeply engages our people, management processes and information systems by applying a risk management methodology. According to the GDPR, for instance, (1) Brightway set up a Data Protection Officer (DPO) in charge of data protection, and the contact of DPO is dpo@navee.tech; (2) Brightway designate a representative in Europe, and the contact of representative is representative@navee.tech; (3) procedure like data protection impact assessment (DPIA).

7. Rights under CCPA/CPRA

If you are a California resident and the California Consumer Privacy Act of 2018 (hereinafter referred to as “CCPA”) or the California Privacy Rights Act (hereinafter referred to as “CPRA”) does not recognize an exemption that applies to you or your Personal Information, you have the right to:

1. Request we disclose to you free of charge the following information covering the 12 months preceding your request:

(1) the categories of personal information about you that we collected;

(2) the categories of sources from which the personal information was collected;

(3) the purpose for collecting personal information about you;

(4) the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

(5) the specific pieces of personal information we collected about you.

2. Request we delete personal information we collected from you, unless CCPA/CPRA recognizes an exemption.
3. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA/CPRA.
4. Have the right to opt out of certain uses and disclosures of your personal information. Where you have consented to Brightway’s processing of your personal information, you may withdraw that consent at any time and opt out of further processing by contacting Brightway. In order to provide our services to you, we will ask you to provide personal information necessary to provide those services to you. If you do not provide your personal information, we may not be able to provide you with our products or services. Even if you opt-out, we may still collect and use non-personal information regarding your use of our products.

We aim to fulfill all verified requests within 45 days pursuant to the CCPA/CPRA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

VI Minors

We believe that it is the responsibility of parents to supervise children’s use of our products and services. However, our policy does not require access to personal data of minors and we do not send any promotional materials to such groups.

Brightway will not seek or attempt to receive any personal data from minors. If parents or guardians have reason to believe that minors have submitted personal data to Brightway without their prior consent, please contact us to ensure that such personal data is deleted and that minors cancel their subscription to any applicable Brightway services.

VII Transfer of Personal Data between Countries

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies (which are in the communications, social media, information technology, and cloud businesses) or Third Party Service Providers, we shall do so in accordance with the applicable laws.

Your personal information will only be transferred or accessed in countries/regions outside your jurisdiction to provide you with products or services, perform the agreement between you and us, or for other purposes agreed by you. For example, we have to transfer your personal information outside of your jurisdiction to perform repair, return, and exchange services. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards.

VIII Contact Us

If you have any comments or questions about this Policy, or if you have any questions about our collection, use or disclosure of your personal data, please contact us at the address below and mention the “Privacy Policy”. We have a professional team to solve your problems when you have any issue concerning your rights and questions related to personal data. If your question itself involves more important matters, we may ask you for more information. If you are not satisfied with the response you have received, you can refer the complaint to the relevant regulatory authority of the jurisdiction. If you consult us, we will provide information on possible applicable complaint channels according to your actual situation.

Email address: privacy@navee.tech

Tel.: 0512-68790047

Website: https://naveetech.com/

IX Update of This Privacy Policy

We will regularly review this Policy and may update it to reflect changes in our information practices. If we make significant changes to this privacy policy, we will notify you by email (to the email address specified in your account) or on all search websites or through mobile devices so that you can understand the information we collect and how we use it. Such policy changes will apply from the effective date specified in the notice or on the website. We recommend that you check this page regularly for the latest information on our privacy practices. If you continue to use products and websites or other services, you will be deemed to accept the updated privacy policy. When we collect more personal data from you or we hope to use or disclose your personal data for new purposes, we will obtain your consent again.

This Policy takes effect from the date of updating.

Last updated: 5 December, 2023