This Privacy Policy is updated as of March 1, 2020

Coolpad Technologies Inc. (“Coolpad”) is a Delaware company. It is a subsidiary of Coolpad Group, which includes Yulong Computer Telecommunication Scientific (Shenzhen) Co., LTD. For further information, please see the end of this Privacy Policy.

1. DATA COLLECTION AND USE GENERALLY

This Privacy Policy applies to personally identifiable information (“Personal Information”) Coolpad may collect and use in providing its products or services (“Coolpad Services”).

Coolpad is committed to protecting the online privacy of web visitors, users and customers of all of Coolpad Services (hereafter “user or users”).

This Privacy Policy is designed to advise you about how Coolpad collects, uses, discloses, transfers and stores the Personal Information we collect about you when you visit Coolpad’s website, subscribe to Coolpad Services or otherwise submit information directly to Coolpad.

This Privacy Policy does not apply to the data collection practices of any third parties or any information that you provide directly to third parties, including services or content you access via a Coolpad webpage. Please always check the applicable privacy policy of any third party service providers whose service or content you access, including via a link or related search to Coolpad’s site.

You, the user of Coolpad Services, may provide Coolpad certain Personal Information, as described below, in order that Coolpad is able to provide you certain Services.  Please review and accept the terms of this Privacy Policy before providing your Personal Information to Coolpad and acknowledge the disclosures made herein.  Please note that Coolpad may not be able to fulfill certain requests or provide Coolpad Services without the user’s agreement to the terms of this Privacy Policy or consent to collect certain Personal Information.   Alternatively, your use and/or acceptance of any of the Coolpad Services shall be construed as your acceptance of the terms of this Privacy Policy in full, including, without limitation, the collection, disclosure, transfer, use, management and storage of “Personal Information”, as defined and described below.

From time to time Coolpad may transfer or merge any Personal Information collected off-line to its online databases or store off-line information in an electronic format.

This Privacy Policy covers all “Personal Information” and will remain in full force and effect as long the a user uses any of the Coolpad Services, unless the user has requested otherwise.  This includes a user’s use of a particular Service, feature, function or promotional activity, which terminates, ceases, or is deactivated for any reason, provided the Personal Information remains relevant for other purposes as set forth in Section 4  below.

2. PERSONAL INFORMATION THAT WE MAY COLLECT

In order to provide certain Services or enable certain features in Coolpad’s apps to function, Coolpad may request certain Personal Information from the user.  This includes the user’s submissions to complete registration forms, respond to surveys and polls, purchase or register products, download updates, and similar actions that relate to use of Coolpad Services.

Personal Information is any information that can be used to identify a specific person, and includes your name home or other physical address, online contact information such as an email address, contact preferences, device identifiers such as an IM VoIP identifier, or video chat identifier; screen name or user name where it functions as online contact information; or a telephone number.

Personal Information also includes a Social Security number; a persistent identifier such as a cookie number, an IP address, a processor or device serial number, or a unique device identifier; a photo, video, or audio file; geolocation information, or credit card information.

We may collect information about the content you share with family members. Coolpad will make reasonable efforts to notify you when Personal Information is collected, and, other than incidentally in connection with the other activities described in this Privacy Policy, we attempt to collect Personal Information only when you voluntarily submit it to us through our online forms and questionnaires, SMS text campaigns or through other voluntary on or offline means.

While Personal Information you provide to Coolpad is voluntary, we may not be able to provide you with full use of the features, files and locations that comprise the Coolpad Services if we do not have certain Personal Information about you. The Personal Information the user provides in connection with Coolpad Services is collected and retained in accordance with this Privacy Policy.

Coolpad takes reasonable measures to ensure that the Personal Information we process is accurate, complete, and current, but we depend on you to update or correct Personal Information as necessary. All users of Coolpad Services are required to provide current and accurate Personal Information when prompted and we will reject and delete any entry that we believe in good faith or have verified to be incorrect, false, falsified, or fraudulent, inconsistent with this Privacy Policy or in violation of applicable law.  Coolpad is not required to take any affirmative actions to verify or confirm that any Personal Information submitted to us by third parties is complete and/or accurate, unless required by applicable law.

3. NON-PERSONAL INFORMATION

When users access or use all or any of Coolpad Services, we may also collect “non-Personal Information”. We consider “non-Personal Information” to be information that cannot be used to identify a specific person or which is aggregated. This may include demographic information, such as education level, profession, zip code, or interests. Non-Personal Information may also include technical information or other anonymous data that cannot lead to the identification of a specific person.  

However, if any Personal Information is combined with non-Personal Information, Coolpad will treat it as Personal Information.

We reserve the right to use or disclose non-Personal Information provided it is done so in accordance with the purposes of collection and use as described in this Privacy Policy

Any submissions that users make to any public areas of the Coolpad website such as bulletin boards (“Public Areas”) will be public and are not be considered Personal Information. We do not control, and are not responsible for, the actions of other users of the Coolpad Services or of third parties with respect to any information posted in Public Areas.  Information that users submit to Public Areas may be collected and used by others to send users unsolicited messages and for other purposes, over which Coolpad has no authority to restrict nor any obligation to do so.

4. PURPOSES AND USES OF PERSONAL INFORMATION THAT WE COLLECT

Coolpad collects Personal Information in order:

a) to provide you with a Service or access to an app which you have requested

b) to inform you software or app updates or changes;

c) to help create, develop, operate, and improve our, services or content;

d) to ensure account network security, such as pre-screening potentially illegal content

e) to verify your identity, assist with identification of users, and to determine appropriate services.

f) to notify you of changes to our terms, conditions, and policies;

g) for internal purposes such as auditing, data analysis, and research to improve our services and customer communications.

The Personal Information we collect is used to provide users of the Coolpad Services with any Services which a user may request, to communicate with users, or to allow them to participate in online surveys and publish the results thereof.

We use aggregated non-Personal Information about our users to understand our website’s demographics, such as the geographic distribution of our users, the number of users visiting a certain location, or a combination of these and/or other demographics. We may also use the Personal or non-Personal information we collect to analyze how Coolpad Services are being used, to improve the content of the Coolpad Services, and for marketing and promotional efforts, including direct marketing, so that we may send users of Coolpad Services information about products and services which may be of interest.

If you e-mail us with questions or comments, we may use your Personal Information to respond to your questions or comments, and we may save your questions or comments for future reference. Coolpad may asked for your express consent to being contacted by e-mail, and for permission (either positively or by way of “opt out” procedures) to send you information about products and services that may be of interest to you, and which communications we or our affiliates may send to you.  Upon your consent, you may subscribe by email address to an electronic newsletter about Coolpad Services.  You have the option at any time to change your preferencesor opt out here: https://coolpad.us5.list-manage.com/profile/?u=00514edbe8cf586789cd0ea24&id=3e8b1c7de6&e=fd00aa3b96

5. COOKIES

Coolpad’s website, online services, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help Coolpad better understand user behavior, tell us which parts of the Coolpad Services have been accessed, and facilitate and measure the effectiveness of advertisements and web searches. Coolpad treats information collected by cookies and other technologies as non-Personal Information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information under applicable law, we also treat these identifiers as Personal Information. Similarly, to the extent that non-Personal Information is combined with Personal Information, we treat the combined information as Personal Information for the purposes of this Privacy Policy.

We use cookies and other technologies to remember Personal Information when you access Coolpad Services. If you want to disable cookies, check the features of your computer browser as well as the services offered by your Internet services provider to find out how to disable cookies. Please note some of the Coolpad Services may not be available once cookies are disabled.

As is true of most websites, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit pages, operating system, date/time stamp, and click stream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, and to gather demographic information about our user base as a whole. We reserve the right to use this general information in designing our advertising and marketing services, but we are not obligated to do so. Notwithstanding, we will not use any Personal Information in connection with the design and development of our advertising marketing services in any manner that discloses any of your Personal Information.

In some of our email messages, we may employ a “click-through URL” linked to some portion of the Coolpad Services. When users click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We may track this click-through data to help us determine interest in particular topics and measure the effectiveness of our user communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.

Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to users.

6. DISCLOSURE OF INFORMATION TO THIRD PARTIES

Co-Branded Services and Features

Coolpad Services may also offer co-branded services, such as events and/or promotions with other companies or an affiliate (“Co-Branded Partner”). Such services and features may be hosted on our website and/or on our Co-Branded Partner’s website.

We will ask you to opt in and give your affirmative consent to both the provision of Coolpad Services and to permit our Co-Branded Partners to collect and use your Personal Information for the purpose of registration or your use of the co-branded service or feature, fulfillment of the service or feature, for marketing or administrative purposes. If you wish to opt-out of our co-branded service, you may notify Coolpad and Coolpad will notify its Co-Branded Partner to refrain from further use of your Personal Information for any of these purposes.

Business Transactions Involving Coolpad Services: We may engage in commercial transactions such as buying, selling or combining the Coolpad Services with other businesses. In such cases, we will not share your Personal Information with those other businesses, without disclosing to you Coolpad’s intention to share your Personal Information with its contract partner.  You may request that Coolpad not share this Information or request Coolpad to delete your Personal Information.

You, the user, understand that not sharing such information may prohibit Coolpad and its contracting partner from providing a new service or feature to you.   

If the user has consented to the sharing of Personal Information, the user may later retract or restrict such consent by requesting the contracting partner to refrain from further use or delete Personal Information directly.  Coolpad is not responsible for the actions of the contracting party, other than as provided by applicable law or in this Privacy Policy.

Third Party Advertisers

We may use third-party companies to deliver specific advertisements to users. These companies may collect non-Personal Information about your visits to our website and other use of the Coolpad Services in order to provide advertisements about products and services that may be of interest to you and/or other users. These companies may also aggregate non-Personal Information for use in targeted advertising, marketing research, and other similar purposes. These companies may place their own cookies on your computer. If you want to prevent a third-party advertiser from collecting and using this information, you must visit each third-party advertiser’s website directly and opt-out.

Other Disclosures

We may disclose Personal Information when we are required to do so under applicable law, when we are the subject of a court order, or when any law enforcement authority or regulatory agency which has jurisdiction to do so requests that we provide such Personal Information. We may also disclose Personal Information to the extent necessary to enforce our rights under law or pursuant to any agreement, or when we believe in good faith that disclosing this information is necessary or advisable, including, for example, to protect the rights, property, or safety of ourselves and our employees and other agents, the Coolpad Services, our users, and/or other third parties.

7. CHILDREN

PLEASE SEE OUR CHILRENS DISCLOSURES To Be Updated November 2020.

8. SECURITY OF THE INFORMATION WE COLLECT

The security of all Personal Information is important to us. We maintain physical, electronic, and procedural safeguards to secure Personal Information. However, please remember that there is always some risk in transmitting information electronically prior to our collection, and there are constant security risks associated with being interconnected, as well as criminal and other elements that seek to test electronic security measures and/or retrieve confidential data.

The Personal Information we collect is stored on databases that we control. We use security measures that we deem to be consistent with industry standards, such as firewalls and encryption technology, to protect the Personal Information we collect, We restrict access to Personal Information to employees, contractors and/or other agents who need to know that information in order to operate, develop or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

9. USER GENERATED CONTENT UPLOAD

Registered users that submit content to us agree to have certain Personal Information posted on our website as well as on any other platform on which we operate or provide services, or, if such feature is offered in connection with a Co-Branded Partner, on our Co-Branded Partner’s website. Registered users that upload videos may also be required to submit additional Personal Information. Coolpad may screen videos for content and not posted them if, in our sole and complete discretion, we believe that posting the video is in any way harmful to our interests, the interests of any user, or the interests of any third party.

Any submissions that you may make to any public areas of our website, such as postings to bulletin boards (“Public Areas”) are public and will not be considered Personal Information.

We do not control, and are not responsible for, the actions of other users of the Coolpad website with respect to any information users post in Public Areas. Information that users submit to Public Areas may be collected and used by others to send users unsolicited messages or for other purposes.

10. CONTESTS AND SWEEPSTAKES

Registration may not always be required to enter promotions such as contests and sweepstakes. Or, they may have a separate registration process which requests the user to submit his or her Personal Information. The entry page and/or rules of any contest will provide the specific requirements for the promotion concerned. You may opt-in or out to special offers from our advertisers in connection with many these promotions at the application link or option provided.

11. QUESTIONS OR REQUESTS ABOUT PERSONAL INFORMATION

If you have any questions about this Privacy Policy, the Personal Information Coolpad has about you, the uses Coolpad makes of your Personal Information or wish to submit a request to modify, update, or delete any of your Personal Information which you may have provided us, you may contact us by via e-mail at support@coolpad.com, or via regular mail to:

Coolpad Technologies, Inc.
530 Technology Drive, Suite 100
Irvine, CA 92618
Attention: Customer Support

You may also call us at 1.877.606.5753

If you request that we change any of your information, we will, after verification of the user making the request, respond to acknowledge your request as provided for by applicable law and comply with your request.

Where you are able to opt out of transfer or sharing of you Personal Information, please see the opt out button or other option made available by link to opt out.

Coolpad makes reasonable efforts to ensure that all of your Personal Information stored in our databases will be updated, corrected, changed or deleted, as appropriate, as soon as reasonably practicable. However, we reserve the right to retain in our archival files any information removed from, or changed in, our active service databases. We also maintain archives of web logs, database and other systems. For disaster recover, legal and other non-marketing purposes. We may retain such information to resolve disputes, troubleshoot problems and enforce our Terms and Conditions for any app or service we provide.

12. ABOUT COOLPAD

Coolpad refers to Coolpad Technologies, Inc., a Delaware corporation. Coolpad is a subsidiary of Coolpad Group Limited whose affiliates include Yulong Computer Telecommunication Scientific (Shenzhen) Co., LTD. Each of the foregoing entities is a separate and distinct legal entity, and no entity is authorized to or can accept or receive service of process on behalf of any other entity. No company within Coolpad Group is legally liable for another unless specifically agreed to in writing or such liability is imposed by law.