Kunming Spring City Golf & Lake Tourism Real Estate Development Co., Ltd. places great importance on the protection of your personal information. This 'Privacy Policy' (hereinafter referred to as 'the Policy') has been put together in compliance with relevant Chinese laws, regulations, and standards. Its purpose is to clarify how we collect, process, and protect your personal information, and how you can uphold your legitimate rights and interests.
This policy will help you understand the following:
1. How we collect and use your personal information
2. How we use cookies and other similar technologies
3. How we store your personal information
4. How we delegate proccessing, share, transfer, and publicly disclose your personal information
5. How we protect your personal information
6. Your rights
7. How we handle personal information of children
8. How this policy is updated
9. How to contact us
This policy applies to both our official website and our services. We may collect and use your relevant information when you use our website or engage with our services. Please ensure you have carefully read and fully understood the contents of this policy before using our platform and/or services, and make decisions you deem appropriate according to the guidance in this policy. Any parts of this policy involving your sensitive personal information are highlighted in bold and italic font to draw your attention.
Unless specified otherwise, if you disagree with this policy or its updates (of which we will notify you in a timely manner), it may impact your ability to use or continue using our platform and/or services in a normal manner.
If you have any questions or concerns about this policy or related matters, please don't hesitate to get in touch with us using the contact information provided in "Section 9: How to Contact Us".
1.How We Collect and Use Your Personal Information
1.1. Circumstances and Types of Personal Information Collected
1.1.1. Improving Your Service Experience
We may collect the following personal information to provide a better service experience:
- Log Information: We automatically record detailed usage data when you use our products or services. This includes your IP address, browser type, telecommunications provider, language used, date and time of access, the web pages you visit, any errors in the application, and other system activity information.
- Device Permissions: To provide a convenient, high-quality service, we may need to access certain permissions on your device. Below are the device permissions we may access, and why we need them. You can choose to revoke these permissions at any time, but doing so may disrupt some of the platform's functionalities.
（1）Device Information: We collect information related to the device you use to access the platform, such as the device model, settings, and unique device identifiers. This is based on the permissions you grant during the installation and use of the platform.
（2）Camera: We require access to your camera to take photos for platform-related tasks, such as capturing images for business verification materials or facial photographs.
1.1.2. Customer Service
When you contact our customer service department, we ask for necessary personal information to verify your identity and ensure the security of your account. To enable efficient communication, promptly address your issues, and document the solution and outcome, we may store your communications with us. This includes account information, any additional information you provide to substantiate your claims, and your contact details like phone number or email address.
1.1.3. Additional Services
To enhance our services, we may carry out surveys, solicit feedback, or conduct other marketing research activities to understand your preferences and intentions. If you decide to participate, you may be asked to provide personal information, such as your name, gender, age, preferences, and hobbies.
1.1.4. Obtaining Your Personal Information from Third Parties
We may indirectly collect your personal information from third parties. This only occurs when: we have confirmed that the third party has obtained your explicit consent to share the data with us, or when the third party is legally permitted or required to disclose your personal information to us.
We ensure that third parties confirm the legality and compliance of the personal information they provide. If a third party fails to comply, we will explicitly require them to assume the relevant legal responsibilities.
We review the extent of consent given to the third party for handling the personal information, including the purpose of use, and whether the individual has given consent for the transfer, sharing, public disclosure, or deletion of their personal information.
We use the personal information obtained from third parties to provide you with services and to maintain the accuracy of our records. If our use of this information extends beyond the consent given to the third party, we will seek your explicit consent, either directly or through the third party, within a reasonable timeframe of receiving the personal information or before using it.
Please note, the types of personal information collected in the situations mentioned above do not correspond directly with the types of personal information we collect. Personal information collected in one situation may also be collected in other situations.
1.2. Exceptions to Consent Requirement
Within the limits permitted by law, we may collect and use your personal information under the following circumstances without obtaining your explicit consent. Furthermore, we may not respond to your requests for correction/modification, deletion, account cancellation, consent withdrawal, or information requests:
1.2.1. When it's necessary to establish or execute a contract with you, or to conduct necessary human resource management in compliance with legally established labor regulations and legally agreed upon collective contracts.
1.2.2. When it's necessary to fulfill our legal responsibilities or obligations.
1.2.3. When it's necessary to respond to sudden public health incidents, or in emergencies that require protecting the life, health, and property safety of individuals.
1.2.4. When carrying out news reporting, public opinion supervision, and other actions in the public interest, and handling personal information within a reasonable scope.
1.2.5. When processing personal information that individuals have voluntarily made public or other personal information that has been legally released, within a reasonable scope as stipulated by the "Personal Information Protection Law", except when it significantly impacts personal rights and interests.
1.2.6. Other circumstances as prescribed by laws and administrative regulations.
2.How We Use Cookies and Similar Technologies
To enhance your browsing experience and recommend content that may be of interest to you, we use Cookies and similar technologies, such as pixel tags/beacons and scripts (collectively referred to as "Cookies"). These Cookies allow us to store information about visits and visitors, and by analyzing this data, we can provide improved and more personalized services. If you click 'agree' when presented with the Cookies notice, you are consenting to our use of Cookies to deliver our services. You have the option to adjust your acceptance level of Cookies or to refuse our Cookies entirely, but please note that refusing Cookies may prevent you from using certain services or features that rely on Cookies.
3.How We Store Your Personal Information
All your personal information is securely stored on servers located within the People's Republic of China (excluding Hong Kong, Macau, and Taiwan for the purposes of this policy). This information is protected within controlled facilities. We categorize your data based on its significance and sensitivity, ensuring an appropriate level of security for your personal information. Our employees, who may need to access this information to provide you with services, are bound by stringent confidentiality obligations. Additionally, we have specific access control measures in place for data storage to prevent unauthorized access and use.
During your use of our services, we will persist in storing your personal information. The duration of this storage will not exceed the period necessary to provide you with our services. Once you cease using our services, we will delete or anonymize your information, unless laws and regulations dictate a different retention period for certain information, or if it's necessary to protect our legal rights (e.g., in consideration of the statute of limitations).
If we discontinue our platform's operations, we will delete or anonymize your personal information within a reasonable period, in accordance with applicable laws. If we cannot undertake such measures (for example, if your information is stored in backup archives), we will securely store your personal information in accordance with legal requirements, and we will refrain from any further processing until deletion is possible.
4.How We Delegate Processing, Share, Transfer, and Publicly Disclose Your Personal Information
4.1. Delegation of Processing
We may entrust external service providers to process your personal information to implement certain services or features we provide to you. For example, some platform features may be provided by external service providers, and we may hire professional data processing service agencies to provide technical support for data analysis for our platform.
For companies, organizations, and individuals to whom we delegate the processing of personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information according to our instructions, this policy, and any other relevant confidentiality and security measures.
4.2. Sharing (referring to providing personal information to other entities who can determine the purposes and means of its processing)
We typically do not share your personal information with any other entities, except in the following circumstances:
4.2.1. We may share your information with our affiliated companies. We will only share necessary information and will be bound by the objectives stated in this policy. If affiliated companies want to change the purpose of processing or the method of processing, we will seek your consent again.
4.2.2. We may share your information with our authorized partners, such as our service providers (including companies assisting in system platform processing, operational management teams of related properties, property management teams, logistics companies, etc.), to ensure the smooth provision of our products and/or services, as well as the purposes listed in "Section 1: How We Collect and Use Your Personal Information". However, we will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share information necessary to achieve the aforementioned purposes. Our partners are not allowed to use the shared information for any other purpose.
4.2.3. We may share your personal information externally when required by laws and regulations, for dispute resolution in legal cases, or in response to obligatory demands from administrative and judicial authorities. We will notify you of such information sharing, unless otherwise mandated by law or administrative regulations.
If we need to share your information with other companies, organizations, and individuals beyond the above situations, we will seek your consent separately.
For companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information according to our instructions, this policy, and any other relevant confidentiality and security measures.
4.3. Transfer
We will not transfer your personal information to any company, organization, or individual, except in the following situations:
4.3.1. We may transfer your personal information to other parties with your explicit consent.
4.3.2. In the event of mergers, acquisitions, dissolution, or bankruptcy liquidation, if a transfer of personal information is involved, we will inform you. The new company or organization receiving your personal information will be required to adhere to this policy. If they cannot commit to this, we will require them to seek your consent again.
4.4. Public Disclosure
We will only publicly disclose your personal information under the following circumstances:
4.4.1. With your explicit consent.
4.4.2. Based on legal requirements: We may publicly disclose your personal information in response to laws, legal procedures, litigation, or mandatory requirements from government authorities.
5.How We Protect Your Personal Information
We place a high premium on the security of your personal information. For instance, we utilize technologies such as encryption and anonymization to enhance the security of personal information. We employ trusted protection mechanisms to guard against malicious attacks on personal information and implement access control mechanisms to prevent unauthorized access. Additionally, we conduct training courses on security and privacy protection.
The measures we adopt aim to provide a level of security protection commensurate with the risks associated with processing your personal information. We strive to take reasonably practicable measures to avoid collecting unnecessary personal information. While no method of internet transmission or electronic storage is 100% secure—thus we cannot guarantee absolute security of personal information—we are committed to implementing appropriate technical and organizational protective measures to safeguard your information from theft, loss, misuse, and any unauthorized access, duplication, collection, use, disclosure, alteration, or destruction.
In the unfortunate event of a personal information security incident, we will, in line with legal requirements, promptly inform you. This will include the basic details of the security incident and potential impacts, the remedial measures we have taken or plan to take, suggestions for you to independently mitigate and reduce risks, and the remedial measures available to you. We will communicate such information promptly through emails, letters, phone calls, push notifications, etc. If it proves challenging to notify each subject of personal information individually, we will make an effective and reasonable public announcement. Also, we will report the handling of personal information security incidents to regulatory authorities as required.
6.Your Rights
6.1 Accessing Your Personal Information
Unless otherwise dictated by applicable laws and regulations, you have the right to access your personal information at any time by logging into your account. You can also exercise this right by contacting us using the contact information provided in "Section 9: How to Contact Us."
6.2 Correcting and Supplementing Your Personal Information
If you find any inaccuracies or incomplete data in the personal information we hold about you, you have the right to request corrections or supplements. You can make these changes by logging into your account, or you can exercise this right by contacting us using the methods outlined in "Section 9: How to Contact Us."
6.3 Deletion of Your Personal Information
In the following circumstances, you have the right to request the deletion of your personal information. You can exercise this right by contacting us using the methods outlined in "Section 9: How to Contact Us":
6.3.1. If our handling of personal information is in violation of laws or regulations;
6.3.2. If we have collected or used your personal information without your consent;
6.3.3. If you have withdrawn your consent after initially agreeing to our collection and use of your personal information;
6.3.4. If our processing of personal information breaches our agreement with you;
6.3.5. If you no longer use our products or services, or you have cancelled your account;
6.3.6. If we have ceased providing our products or services to you;
6.3.7. If the objective for processing your personal information has been met, cannot be met, or is no longer necessary;
6.3.8. If the retention period for your personal information has expired.
Should we decide to comply with your deletion request, we will also instruct any entities that have received your personal information from us to promptly delete it, unless otherwise required by laws and regulations, or if these entities have obtained independent authorization from you.
Please note that after you remove information from our platform, we may not immediately delete the corresponding information from our backup system. Instead, we will delete this information during the next backup update.
6.4. Modifying the Scope of Your Consent or Revoking Your Authorization
Within the scope of your authorization for us to collect and process your personal information, you have the ability to change the extent of your authorization or to withdraw your authorization altogether by altering your settings.
Please understand that each business function requires certain essential information to operate. If you revoke your consent or authorization, we will no longer be able to provide you with the services tied to the revoked consent or authorization, and we will cease processing the corresponding information. However, your decision to revoke consent or authorization will not retroactively impact any information processing carried out based on your prior authorization.
6.5. Deactivating Your Account
You can log into your account to deactivate it yourself. Alternatively, you can use the contact methods provided in "Section 9: How to Contact Us" to request account deactivation.
6.6. Accessing a Copy of Personal Information
You can log into your account to retrieve a copy of your personal information.
If technically feasible and in compliance with regulations set by the national cyberspace authorities, we can also transmit a copy of your personal information directly to a third party specified by you upon your request.
You can also use the contact methods provided in "Section 9: How to Contact Us" to request this.
6.7. Requesting an Explanation of This Policy
You can request an explanation or clarification of this policy by using the contact methods provided in "Section 9: How to Contact Us".
6.8. Restricting Automated Decision-making by the Information System
For certain business functions, we may make decisions based solely on non-human automatic decision-making mechanisms, such as information systems and algorithms. If these decisions significantly impact your legal rights and interests, you have the right to request an explanation and can refuse decisions made purely by automated means. We will provide a method for appeal, provided it does not infringe our trade secrets, other users' rights and interests, or the public interest.
6.9. Responding to Your Requests
For security reasons, you may need to provide a written request or verify your identity in another way. We may ask you to verify your identity before processing your request.
We will respond to your request within fifteen (15) days. If you're unsatisfied or have any questions, you can use the contact methods provided in "Section 9: How to Contact Us".
Generally, we do not charge fees for reasonable requests. However, for repeated requests or those exceeding a reasonable limit, we may charge certain administrative costs. If your request is technically challenging to implement, not required by law, or if responding would result in a violation of legal or administrative regulations, we may decline your request and provide our reasons.
7.How We Handle Children's Personal Information
Our platform, products, and/or services are primarily intended for adults. Children should not create their own user accounts without the consent of a parent or guardian. We do not intentionally collect personal information directly from children. When we do collect personal information from children, it is with the guardians' consent, and we only use or disclose this information when legally permitted, when consent has been given by the guardians, or when it's necessary for the child's protection. We consider anyone under the age of 14 to be a child. If we discover that we've collected personal information from a child without verified parental consent, we aim to delete the relevant data as quickly as possible.
8.Updates to This Policy
We may periodically update this policy to reflect legal, technological, or business developments. However, we will not diminish the rights you have under this policy without your explicit consent. We will post the most recent version of the privacy policy on this page. You can check the "Last Updated Date" at the top of this policy to see when it was last revised.
If there are significant changes to this policy, we will notify you in an appropriate manner. If you continue to use our services after this policy has been updated, it implies that you have fully read, understood, and accepted the revised privacy policy. These changes to the privacy policy will come into effect from the date specified in the notification. If you disagree with the updated privacy policy, you should stop accessing or using our platform.
Significant changes referred to in this policy include, but are not limited to:
8.1. Major changes in our service model, such as changes in the purpose of processing personal information, the types of personal information processed, or the methods of using personal information.
8.2. Significant changes in our ownership structure or organizational structure, such as changes in ownership due to business adjustments or bankruptcy mergers.
8.3. Significant changes in the primary parties to whom personal information is shared, transferred, or publicly disclosed.
8.4. Major changes in your rights regarding the processing of personal information and how these rights can be exercised.
8.5. Changes in the department responsible for managing personal information security, including changes in contact information and complaint channels.
8.6. When a personal information security impact assessment report indicates a high risk.
9.How to Contact Us
You can reach us via the following methods:
Phone: (86) 871-67671188
Email: frontoffice@springcityresort.com
We will promptly review the issue in question and respond within fifteen (15) days after verifying your identity.
If you are not satisfied with our response, or if you believe that our handling of your personal information has infringed upon your legal rights, you can negotiate a resolution with us. If the negotiations are unsuccessful, you agree to submit the dispute to the jurisdiction of the People's Court at our location, to be resolved under the laws of the People's Republic of China (excluding Hong Kong, Macau, and Taiwan regions).