Privacy

This policy only applies to the products or services of Yingxin Commercial Services. Latest update date: [2022.08.01]

This policy will help you understand the following:

1、 How do we collect and use your user information

2、 How do we use cookies and similar technologies

3、 How do we share, transfer, and publicly disclose your user information

4、 How do we protect your user information

5、 Your rights

6、 How do we handle children's personal information

7、 How your user information is stored and transferred globally

8、 How to update this policy

9、 How to contact us

We deeply understand the importance of user information to you and will do our best to protect the security and reliability of your user information. We are committed to maintaining your trust in us, adhering to the following principles, and protecting your user information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of selective consent, the principle of minimum sufficiency, the principle of ensuring security, the principle of subject participation, and the principle of openness and transparency. At the same time, we promise to take corresponding security measures in accordance with mature industry security standards to protect your user information.

Please read and understand this privacy policy carefully before using our products (or services).

1、 How do we collect and use your user information

（1） The information we collect and use during your use of our products or services

We will only collect and use your user information for the business functions described in this policy. The purpose of collecting user information is to provide you with products or services. You have the right to choose whether to provide this information, but in most cases, if you do not provide it, we may not be able to provide you with the corresponding services or respond to the problems you encounter:

When you use our services, we allow you to collect information that you provide to us on your own or that is necessary to provide services to you, including: personal identification information, phone number, device information, log information, IP address, location information, order information, etc.

For the user information we collect, we will use it to provide you with booking car/house viewing, leaving messages to find cars/houses, financial services, financial and tax/license services, media/express/business travel services.

The above information you provide will continue to authorize us to use it during your use of this service. When you stop using the push service, we will stop using and delete the above information.

We guarantee that the collected user information will be de identified or anonymized in accordance with the law. Information that cannot be used alone or in combination with other information to identify a natural person's personal identity is not considered personal information in the legal sense. If we combine non personal information with other information to identify your personal identity, or use it in conjunction with your personal information, we will process and protect such information as your personal information in accordance with this privacy policy during the combined use period.

In order to better operate and improve our technology and services, or due to changes in business strategy, when the collection, use, or processing of user information required for the products or services we provide exceeds the scope mentioned above, or when we intend to use the collected user information for other purposes not specified in this privacy policy, or when we intend to use information collected for specific purposes for other purposes, we will notify you within a reasonable period of time after obtaining the user information or before processing the user information, and obtain your authorization and consent.

（2） The situation where additional business functions collect and use your personal information

1. User Information Storage

1.1. Upload information function. When you need to take photos with a camera and upload personal documents, certificates and other materials to the platform, we will request you to enable the information storage function to upload the documents and certificates for the platform's follow-up processing.

1.2. Complaint and suggestion function. When you use the complaint and suggestion function to upload photos, we will request you to enable the information storage function to upload photos of the complaint or suggestion, so that the platform can understand and follow up on your feedback.

2. Photo/Camera

2.1. Upload Information Function: When you need to use a camera to take photos and upload personal documents, certificates, and other materials to the platform, we will request your authorization to take photos and select the ID and certificate images for uploading, which will facilitate the platform's follow-up processing.

2.2. Complaint and suggestion function. When you use the complaint and suggestion function to upload photos, we will request that you authorize photo permissions and select the feedback photos for submission, which will facilitate the platform's follow-up and processing.

You understand and agree that the above additional services may require you to grant access to your camera on your device in order to collect and use the information related to these permissions. Please note that by granting any permission, you authorize us to collect and use relevant personal information to provide you with corresponding services. Once you close any permission, it means that you have cancelled the authorization. We will no longer continue to collect and use relevant personal information based on the corresponding permission, nor will we be able to provide you with the services corresponding to that permission. However, your decision to disable permissions will not affect the information collection and use previously conducted based on your authorization.

（3） Exceptions to obtaining authorization and consent

Please understand that according to laws, regulations, and relevant national standards, we do not need your authorization or consent to collect and use your user information in the following situations:

1. Directly related to national security and defense security;

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

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

4. 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 consent;

5. The user information collected from you is publicly disclosed to the general public by yourself;

6. Collecting your user information from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels;

7. Necessary to sign or fulfill the contract according to your requirements;

8. Necessary for maintaining the safe and stable operation of software and related services, such as discovering and handling software and related service failures;

9. The personal information controller is a news organization and is necessary for conducting legitimate news reporting;

10. Academic research institutions conduct statistical or academic research based on public interest, and when providing results of academic research or descriptions to external parties, they de identify the personal information contained in the results.

11. Other circumstances stipulated by laws and regulations.

2、 How do we use cookies and similar technologies

（1） Cookie

To ensure the normal operation of the website, we will store small data files called cookies on your computer or mobile device. Cookies typically contain identifiers, site names, as well as some numbers and characters. With the help of cookies, websites can store your visit preference data.

We will not use cookies for any purposes other than those stated in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer, and most web browsers have a feature to block cookies. But if you do so, you will need to personally change the user settings every time you visit our website.

（2） Website beacons and pixel tags

In addition to cookies, we also use other similar technologies such as website beacons and pixel tags on our website. For example, the email we send you may contain a click URL that links to the content of our website.

If you click on the link, we will track this click to help us understand your product or service preferences and improve customer service. A website beacon is typically a transparent image embedded in a website or email. By using pixel tags in emails, we can determine whether the email has been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.

（3） Do Not Track

Many web browsers have a Do Not Track function, which can issue Do Not Track requests to websites. At present, the major Internet standards organizations have not established relevant policies to specify how websites should respond to such requests. But if your browser has enabled Do Not Track, then all of our websites will respect your choice.

3、 How do we share, transfer, and publicly disclose your user information

（1） Sharing

We will not share your user information with any other company, organization, or individual, except in the following circumstances:

1. Sharing with explicit consent: With your explicit consent, we will share your user information with other parties.

2. We may share your user information with external parties in accordance with laws and regulations or mandatory requirements of government regulatory authorities.

3. Sharing with our affiliated companies: Your user information may be shared with our affiliated companies. We will only share necessary user information and are bound by the purposes stated in this privacy policy. If the affiliated company wants to change the purpose of processing user information, it will seek your authorization and consent again.

4. Shared with authorized partners: Some of our services will be provided by authorized partners solely for the purposes stated in this policy. We may share some of your user information with our partners to provide better customer service and user experience. We will only share your user information for legal, legitimate, necessary, specific, and clear purposes, and will only share user information necessary for providing services. In order to better operate and improve technology and services, you agree that we and authorized partners may use the collected information for other services and purposes in compliance with relevant laws and regulations.

The following lists specific authorized partners and provides a link to the privacy policy of the third party. We recommend that you read the privacy policy of the third party:

(1) SDK Name: Firebase SDK

Third party entity: Google

Usage purpose: Used for users to log in to the APP and push messages

Shared information: device and application information (device model, operating system version, application version, application identifier, etc.); User behavior information (user operations, interactions, page visits, etc. within the application); Network connection information (including network types such as Wi Fi, mobile data, etc.); Identity identifiers (which may include device identifiers, advertising identifiers, etc., used to distinguish different users and devices).

(2) SDK Name: Google Gmail SDK

Third party entity: Google

Usage purpose: Used for users to log in to the APP and push messages

Shared information: user authorized email data access, automated email sending

We will sign strict confidentiality agreements with companies, organizations, and individuals with whom we share user information, requiring them to handle user information in accordance with our instructions, this privacy policy, and any other relevant confidentiality and security measures.

（2） Transfer

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

1. Transfer with explicit consent: With your explicit consent, we will transfer your user information to other parties;

2. When it comes to mergers, acquisitions, or bankruptcy liquidation, if there is a transfer of user information, we will require the new company or organization holding your user 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.

（3） Public disclosure

We will only publicly disclose your user information in the following situations:

1. After obtaining your explicit consent;

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

（4） Exceptions to obtaining prior authorization and consent for sharing, transferring, or publicly disclosing information

Please understand that according to laws, regulations, and relevant national standards, we do not need your authorization or consent to share, transfer, or publicly disclose your user information in the following situations:

1. Directly related to national security and defense security;

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

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

4. 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 consent;

5. Information that you disclose to the public on your own;

6. Collected from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels.

4、 How do we protect your user information

（1） We have implemented industry standard security measures to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable and feasible measures to protect your personal information.

（2） Our data security capabilities:

We have always been committed to protecting the security of your personal information.

We take various security measures, such as access control systems, monitoring systems, encryption, anonymity or pseudonymization, employee training, etc., to protect your personal information from unauthorized access, use, disclosure, modification, damage or loss, and other forms of illegal processing.

（3） We have developed a business continuity plan to ensure the continuous provision of services; Our information security policies and procedures are designed strictly in accordance with international standards, regularly reviewed and updated, and ensure the effectiveness of our security management architecture and measures through regular third-party security audits. In the event of a personal information breach, we will activate emergency plans, take effective measures to prevent the situation from escalating, and promptly notify relevant regulatory agencies and you.

（4） We will take all reasonable and feasible measures to ensure that unrelated personal information is not collected. We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless an extension of the retention period is required or permitted by law.

（5） The Internet is not an absolutely secure environment, and most email, instant messaging and other communication methods are not encrypted. We strongly recommend that you do not send personal information through such methods. Please use a complex password to help us ensure the security of your account.

（6） The Internet environment is not 100% secure. We will try our best to ensure or guarantee the security of any information you send us. If our physical, technological, or management protective facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, which damages your legitimate rights and interests, we will bear corresponding legal responsibilities.

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 through email, letter, phone, push notifications, etc. When it is difficult to inform individual information subjects one by one, we will adopt reasonable and effective methods to publish announcements.

At the same time, we will proactively report the handling of personal information security incidents in accordance with regulatory requirements.

5、 Your rights

According to relevant laws, regulations, standards on personal information protection, as well as common practices in other countries and regions, we guarantee that you exercise the following rights over your personal information:

（1） Accessing your personal information

You have the right to access your personal information, except for exceptions provided by laws and regulations. If you want to exercise your data access rights, you can access them yourself through the following methods:

User Information - If you wish to access or edit personal profile information in your account, or set notification methods, you can do so by accessing the "My" app.

If you are unable to access these personal information through the above link/method, you can send an email to technical@fi855.com . We will reply to your visit request within 15 days. For other personal information generated during your use of our products or services, as long as we do not require excessive investment, we will provide it to you.

（2） Correct your user information

When you discover errors in the user information we process about you, you have the right to request us to make corrections. You can submit a correction request through the methods listed in "(1) Accessing Your User Information". If you are unable to correct these user information through the above link, you can contact us at any time using our web form or by sending an email to technical@fi855.com . We will reply to your correction request within 15 days.

（3） Delete your user information

In the following situations, you can request us to delete user information:

1. If our handling of user information violates laws and regulations;

2. If we collect and use your user information without your consent;

3. If our handling of user information violates our agreement with you;

4. If you no longer use our products or services, or if you cancel your account;

5. If we no longer provide you with products or services.

We will evaluate your deletion request and take appropriate steps to process it if it meets the relevant regulations. When you make a deletion request to us, we may require you to verify your identity to ensure the security of your account. After you delete information from our service, due to applicable laws and security technologies, we may not immediately delete the corresponding information from the backup system. We will securely store your information until the backup can be cleared or anonymized.

（4） Change the scope of your authorized consent

Each business function requires some basic user information to be completed (see "Part One" of this policy). You may grant or revoke your authorization and consent at any time for the collection and use of user information. You can operate it yourself by sending an email to at any time technical@fi855.com We will reply to you within 15 days

After you withdraw your consent, we will no longer process the corresponding user information. Please also note that revoking your authorization may result in certain consequences, such as us being unable to continue providing you with corresponding services or specific functions. However, your decision to revoke your consent will not affect the user information processing based on your authorization.

（5） User Information Subject Account Cancellation

You can cancel your previously registered account at any time and apply for cancellation within the app

You can operate it yourself by sending an email to at any time technical@fi855.com We will reply to you within 15 days; After account cancellation, we will cease to provide you with products or services and delete your personal information as per your request, as otherwise provided by laws and regulations

After canceling the account, we will cease to provide you with products or services and, at your request, delete or anonymize your information, except as otherwise provided by laws and regulations. This may also result in you losing access to the data in your account, please proceed with caution.

（6） User information subject obtains a copy of user information

You have the right to obtain a copy of your user information, which you can do on your own by sending an email to at any time technical@fi855.com We will reply to you within 15 days

On the premise of technical feasibility, such as data interface matching, we can also directly transmit a copy of your user information to a third party designated by you according to your requirements.

（7） Constrained information system automatic decision-making

In certain business functions, we may make decisions solely based on non manual automated decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us, and we will also provide appropriate remedies.

（8） In response to your above request

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 provide a response within 15 days. 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. Please understand that due to security concerns, requirements of relevant laws and regulations, or technical limitations, we may not be able to respond to some of your requests, such as the following situations:

1. Related to the fulfillment of legal and regulatory obligations by user information controllers;

2. Directly related to national security and defense security;

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

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

5. The user information controller has sufficient evidence to indicate that the user information subject has subjective malice or abuse of rights;

6. For the purpose of safeguarding the significant legitimate rights and interests of the user information subject or other individuals, such as life and property, but it is difficult to obtain their consent;

7. Responding to the request of the user information subject will result in serious damage to the legitimate rights and interests of the user information subject or other individuals or organizations;

8. Involving trade secrets.

6、 How do we handle children's personal information

We attach great importance to the protection of children's personal information, and our products, websites, and services are mainly aimed at adults. Children should not create their own user accounts without the consent of their parents or guardians. Although local laws and customs define children differently, we consider anyone under the age of 14 as a child.

For cases where we collect user information from children with the consent of parents or guardians, we will only store, use, or publicly disclose this information as permitted by law, with the explicit consent of parents or guardians, or as necessary to protect children. Otherwise, we will endeavor to delete the relevant data as soon as possible.

Due to the limitations of existing technology and business models, it is difficult for us to proactively identify children's personal information. If you find that we have collected children's personal information without your knowledge or without obtaining verifiable consent from guardians in advance, you can contact us in a timely manner, and we will try our best to delete it in a timely manner. If we discover the aforementioned situation ourselves, we will also delete it in a timely manner, except for those required by law to be retained.

7、 How your user information is stored and transferred globally

In principle, user information collected and generated within the Kingdom of Cambodia will be stored within the Kingdom of Cambodia. We will only retain your user information for the period required for the purposes and purposes stated in this policy and for the shortest period of time as stipulated by laws and regulations. After exceeding the aforementioned retention period, we will delete your user information or anonymize it in accordance with applicable laws and regulations. Unless otherwise provided by laws and regulations, or for the purpose of public interest, scientific and historical research, or with your separate authorization and consent, we may need to retain relevant data for a longer period of time.

Due to our global resources and servers providing products or services, this means that with your authorized consent, your user information may be transferred to or accessed from overseas jurisdictions in the country/region where you use the products or services.

Such jurisdictions may have different data protection laws, or even no relevant laws in place. In such cases, we will ensure that your user information receives sufficient and equal protection within the territory of the People's Republic of China. For example, we may request your consent for cross-border transfer of user information, or implement security measures such as data de identification before cross-border data transfer.

8、 How to update this policy

Our privacy policy may change. Without your explicit consent, we will not reduce the rights you are entitled to under this privacy policy. We will post any changes made to this policy on this page.

For significant changes, we will also provide more prominent notifications. The significant changes referred to in this policy include but are not limited to:

1. Our service model has undergone significant changes. Such as the purpose of processing user information, the type of user information being processed, and the way in which user information is used;

2. We have undergone significant changes in ownership structure, organizational structure, and other aspects. Changes in ownership caused by business adjustments, bankruptcy mergers and acquisitions, etc;

3. The main objects of user information sharing, transfer or public disclosure have changed;

4. There has been a significant change in your right to participate in user information processing and the way you exercise it;

5. When the responsible department, contact information, and complaint channels for handling user information security change;

6. When the user information security impact assessment report indicates the presence of high risks.

We will also archive the old version of this policy for your reference.

9、 How to contact us

If you have any questions, comments, or suggestions regarding this privacy policy, please contact us through the following methods:

E-mail: technical@fi855.com

Phone:+855 86 652 748

Normally, we will reply within 15 days.