XR-Oasis Websites Privacy Policy

Our Privacy Policy was updated on May 1st, 2024.

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

 

About us

 

Nanjing XR-Oasis Technology Ltd. (南京元域绿洲科技有限公司) ("XR-Oasis", "we", "our", or "us"), take your privacy seriously. This Privacy Policy is designed with your needs in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, while ensuring that ultimately, you have control of your personal information provided to XR-Oasis.

 

About this Privacy Policy

 

This Privacy Policy applies to all XR-Oasis websites that reference or link to this Privacy Policy. This Privacy Policy explains how XR-Oasis collects, uses, discloses, processes, and protects any personal information that you give us or that we collect from you, when you use XR-Oasis Websites (including but not limited to https://www.xr-oasis.com, collectively, “XR-Oasis Websites”). If an XR-Oasis product provides a separate privacy policy, the separate privacy policy will receive priority application, while anything that is not specifically covered shall be subject to the terms of this Privacy Policy. Furthermore, how specific products and services collect and process your personal information may also vary depending on the model, service version, or region. You should refer to the separate privacy policy for further details.

 

Under this Privacy Policy, “personal information” means information that can be used to identify directly or indirectly an individual, either from that information alone or from that information combined with other information XR-Oasis Websites has access to about that individual, except as otherwise specifically provided by applicable laws in your region. We will use your personal information strictly in accordance with this Privacy Policy. Where the context requires, personal information shall also include sensitive personal data or information, as may be categorized under applicable law.

 

“Applicable Data Protection Laws” mainly refer to the laws and regulations related to personal information protection in China (Personal Information Protection Law, Data Security Law, Civil Code, Cybersecurity Law) and their supporting implementation rules, national standards, and regulatory requirements (for the avoidance of doubt, excluding the laws of Hong Kong Special Administrative Region, Macao Special Administrative Region and Taiwan).

 

The terms used in this Privacy Policy shall be interpreted in accordance with the Applicable Data Protection Laws unless otherwise agreed. 

 

You are aware and understand that some of the services we provide to you may require the processing of your sensitive personal information, which will be marked in bold to alert you. We will only process your sensitive personal information based on your consent, to provide you with the services you need or to fulfill our legal obligations, and such processing activities will not adversely affect your rights and interests. We will take security and technical measures in accordance with the law that is commensurate with the level of risk associated with the sensitive personal information in question, to prevent unauthorized access and the leakage, alteration, or loss of personal information.

 

In this Privacy Policy, we will disclose to you the matters necessary for the processing of your sensitive personal information (including, but not limited to, the purpose and manner of processing and the types of sensitive personal information, etc.) in accordance with the law, and will remind you again in the form of a pop-up window or on a separate page and ask for your individual consent (unless otherwise provided by the Applicable Data Protection Laws).

 

How we can help you

 

1. What information do we collect and how do we use it

1.1 What information we collect

We will ask you to provide personal information that is necessary for us to provide our services to you. We will only collect the information that is necessary for specified, concrete, explicit, and legitimate purposes and shall ensure that the information is not further processed in a manner that is incompatible with those purposes. If we use your personal information for other purposes not set out in this Privacy Policy, or collect or use your personal information for other specific purposes, we will inform you in a reasonable manner and re-obtain your consent before collection or use.

 

 

1.1.1 Information you provide to us

When you click on “Contact Us” and “Learn More” on XR-Oasis Websites, we need you to reserve your cell phone number, name, age, gender and other relevant information (the personal information submitted is subject to the information displayed on the page). Please be aware that the personal information you submit or send by clicking “Contact Us” or “Learn More” is for the purpose of allowing us to contact you and respond to your requests. If we obtain your personal information outside of the above scenarios, we will ask for your express consent again and fully explain the application scenarios and the content and scope of the information we obtain about you before obtaining your express consent, unless otherwise stipulated by the Applicable Data Protection Laws.

If you only browse the website, you do not need to provide the aforementioned information.

 

 

1.1.2 Information that we automatically collect during your use of XR-Oasis Websites

We automatically collect certain information when you use XR-Oasis Websites. We may collect information about your use of our services or your behavior.

When you visit XR-Oasis Websites, we may automatically record information including, by way of example, your operating system, internet protocol (IP) address, access times, browser type and language, and other websites you visited prior to visiting XR-Oasis Websites.

If you use your cell phone number to log in to your account and have copied the SMS verification code, we will need to access your clipboard to read the SMS verification code information contained therein and prompt the user with an option to paste in the appropriate content to enhance your experience with the product. However, we will only upload the content of your clipboard to our server if we locally recognize that it belongs to our instructions and the user chooses to paste it, otherwise, we will not upload other information of your clipboard to our server. Some cell phones and other end devices may indicate that an application (app) is reading the clipboard, but this system alert cannot distinguish whether or not it is collecting clipboard information, and false positives cannot be ruled out. Therefore, if you notice similar alerts, please contact us so that we can localize the problem.

We may also document information related to your use of web beacons, cookies, locally shared objects (LSOs), and similar technologies described in our Cookie Policy. We may correlate any information we collect about your use of these methods with the information you provide to us and any other information we collect about you in accordance with this Privacy Policy.

Any personal information we collect automatically is necessary for us to provide you with a particular service, and the specific types of information collected depend on how you interact with us. If the information we collect automatically is sensitive personal information, we will ask for your prior consent.

 

 

1.1.3 Unless you have opted out of our processing by deletion, withdrawal of consent, or otherwise, we will use your personal information during your use of XR-Oasis Websites to the extent that it complies with Applicable Data Protection Laws and is directly or reasonably related to the purposes stated in this Privacy Policy. For example, to analyze and commercially exploit your personally identifiable information after it has been de-identified, or to use your self-disclosed information to the extent reasonably possible.

 

 

1.1.4 How we use cookies

When you visit the XR-Oasis Websites, we may use technology to send one or more cookies or anonymous identifiers to your device in order to collect and identify information about your visit to, and use of, XR-Oasis Websites. We promise not to use cookies for any purpose other than those described in this Privacy Policy. If your browser or browser add-on service allows it, you may modify your acceptance of cookies or reject our cookies, but if you do so, in some cases it may interfere with your ability to securely access the XR-Oasis Websites and may require you to change your user settings each time you visit the XR-Oasis Websites.

 

 

 

2. How we share, transfer, and publicly disclose your personal information

 

Except for the following cases, XR-Oasis Websites will not share your personal information with any third party without your consent:

 

 

2.1 Entrusted Processing

 

In order to improve the efficiency of information processing, we may entrust a third party to process your personal information on our behalf. For third parties with whom we entrust the handling of personal information, we will sign an agreement with them, requiring them to handle personal information in accordance with the agreement, this Privacy Policy, and the requirements of Applicable Data Protection Laws. For third parties with whom we share personal information, we will assess the legality, legitimacy, and necessity of the information they collect, investigate their data security environment, and require them to process personal information in accordance with this Privacy Policy and the requirements of Applicable Data Protection Laws.

 

 

2.2 Sharing information for security and analyzing statistics

Analysis of visits to XR-Oasis Websites: in order to analyze the use of our services and improve your experience, we may use statistical data about your visits to XR-Oasis Websites, which is difficult to combine with other information to identify your personal identity.

 

2.3 If we need to transfer your personal information due to merger, demerger, dissolution, bankruptcy, etc., we will notify you of the name and contact information of the recipient and request the recipient to handle your personal information in accordance with this Privacy Policy. If the recipient changes the original purpose and method of processing, it shall obtain your authorization and consent in accordance with the law (except as otherwise provided by Applicable Data Protection Laws). If we terminate our services or operations, we will give you at least thirty days’ notice and delete or anonymize your personal information after the termination of services or operations.

 

 

2.4 Public disclosure of personal information

We will not publicly disclose your information unless we have your consent. However, in accordance with laws, regulations, rules, other normative documents, mandatory administrative or judicial requirements, or in the event that we must provide your personal information, we may disclose your personal information to administrative or judicial organizations based on the type of personal information requested and the manner of disclosure. When we receive a request for disclosure, in compliance with laws and regulations, we require that they must produce the corresponding legal documents, we only provide administrative or judicial authorities for specific investigative purposes and have the legal authority to obtain the data. The documents we disclose are protected by encryption measures, as far as permitted by laws and regulations.

 

 

2.5 We have the right to process (including collecting, using, entrusting processing, sharing, transferring, and publicly disclosing) your personal information without your authorized consent under the following circumstances:

  1. Necessary for the conclusion and performance of a contract to which you are a party;
  2. Necessary for the fulfillment of our statutory obligations;
  3. In accordance with laws and regulations and national standards, we share, transfer, and publicly disclose your personal information;
  4. Necessary to respond to public health emergencies, or to protect the life, health, and property of natural persons in emergency situations;
  5. To implement news reporting, public opinion monitoring, and other behaviors in the public interest, and to process your personal information within a reasonable scope;
  6. Directly related to national security and national defense security;
  7. Directly related to public safety, public health, and significant public interests;
  8. Directly related to crime investigation, prosecution, trial, and judgment execution;
  9. For the purpose of safeguarding your or other individuals’ life, property, and other significant legitimate rights and interests but it is difficult to obtain my consent, except for cases expressly prohibited by laws and regulations;
  10. To collect your personal information from legitimate public disclosure of information, such as from legitimate news reports, government information disclosure, and other channels or your disclosure to the public. According to the law, the sharing and transfer of personal information processed by de-identification and ensuring that the recipient of the data is unable to recover and re-identify the subject of the personal information does not fall under the act of sharing, transferring, and publicly disclosing personal information externally, and the processing of this type of data will be conducted without having to notify you separately and obtain your consent;
  11. Other cases stipulated by laws and administrative regulations.

  12. You know and agree that in order to facilitate us to provide you with consistent services based on the unified account system of XR-Oasis and its affiliates, identify account anomalies, protect users’ personal and property safety from infringement, and facilitate you to carry out unified management, you know and agree that your personal information may be shared within the products of XR-Oasis and its affiliates to the extent necessary, but please rest assured that we will only share information to the extent necessary and reasonable, and only to the extent necessary. However, please be assured that we will only share information to the extent necessary and reasonable and process it only for the purposes mentioned above. If we need to share your sensitive personal information or if our affiliates need to change the purpose of use or processing of your personal information, we will ask for your authorization and consent again. We will endeavor to ensure that our affiliates take no less stringent security measures than those committed to in this Privacy Policy and comply with any other security requirements we may impose to safeguard your personal information.

 

 

3. How we store your personal information

 

Except for the following cases, this website will not store your personal information without your consent:

 

 

3.1 Storage location

We store your personal information collected and generated during our domestic operations in the People’s Republic of China in accordance with laws and regulations. If the business changes in the future, we may need to transfer your personal information to other countries or regions. These countries or regions may have different data protection laws or may not even have such laws. In such cases, we will ensure that your personal information is protected to the same level as within the People’s Republic of China in accordance with Applicable Data Protection Laws, inform you of the necessary matters, implement the corresponding compliance procedures in accordance with the law, and ask for your individual consent (unless otherwise stipulated in the Applicable Data Protection Laws).

 

 

 

3.2 Storage period

With respect to the personal information you submit during your use of XR-Oasis Websites, for the purpose of following up on the introduction, and launching of trial services such as the products of XR-Oasis, we will continue to store your personal information until the end of the aforementioned services, and then delete it within one hundred and eighty (180) days after the end of the services, except when you have agreed to the retention of such data and receive more information in the future, or when the retention of specific information is otherwise stipulated by laws and regulations. We will delete or anonymize your information. If we cease to operate the services on this website, we will stop collecting your personal information in a timely manner and delete or anonymize the collected personal information, unless otherwise provided by laws, regulations, or normative documents. However, we will change the storage time of information in the following cases:

  1. Required by laws, regulations, and other relevant provisions;
  2. Requirements stipulated by court decisions, rulings, or other legal procedures;
  3. Compulsory requirements of relevant administrative authorities;
  4. When we are reasonably sure that it is necessary to comply with laws and regulations and other relevant provisions;
  5. Uses that are reasonably necessary for the implementation of the relevant service agreement or this Privacy Policy, the protection of the public interest of society, the protection of the personal and property safety or other legitimate rights and interests of our customers, us, or our affiliates, other users, or employees;
  6. When the situation of ceasing operation of our products or services occurs, we will take, for example, email, letter, telephone, push notification, announcement, and other forms of notification to you, and delete or anonymize your information within a reasonable period.

 

 

4. How we protect your personal information

We retain your personal information only for as long as necessary for the purposes described in this Privacy Policy and for as long as required by law and regulation. We use a variety of security technologies and procedures to protect against the loss, improper use, unauthorized access, or disclosure of information, as described below:

 

 

4.1 Secure Data Transmission

In terms of secure data transmission, we adopt SSL encrypted transmission technology to protect data during its transmission and use proper protection mechanisms to prevent data from being maliciously attacked; in addition, we will also adopt security measures such as AES encryption algorithm or SHA256 hash algorithm for sensitive information.

 

4.2 Data Access

In terms of security control of data access and use, we have implemented a strict data rights control mechanism to monitor the behavior of those who can handle your personal information to avoid data being accessed in violation of the law and unauthorized use. We also monitor the entire process of the data life cycle to prevent your personal information from unauthorized access, public disclosure, use, modification, human or accidental damage or loss. However, please understand that due to technological limitations and possible malicious cyber tactics, while we endeavor to protect the security of information, it is not always possible to guarantee absolute security. Although we have provided comprehensive security precautions to the extent possible, it is still possible that a third party may circumvent our security measures and gain access to our database, find your personal information, steal or modify it. We assume that you are aware of this risk and agree to assume it when you use the services and provide personal information to this website. We do not assume any legal responsibility for any legal disputes arising from this.

There are always various risks of information leakage in the network environment. When there are unexpected events, force majeure, and other circumstances that lead to the leakage of your information, we will try our best to control the situation and promptly inform you of the cause of the event, the safety measures we have taken, and the safety measures you can take on your own initiative. We will formulate an emergency response plan and immediately activate the emergency response plan when a user information security incident occurs to prevent the impact and consequences of these security incidents from expanding. Once a user information security incident has occurred, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation and possible impact of the security incident, the disposal measures that we have taken or will take, the suggestions that you can take on your own initiative to prevent and minimize the risks, and the remedial measures for you. We will promptly inform you of the relevant situation of the incident in the form of push notifications, emails, letters, SMS, and related forms, and when it is difficult to inform you one by one, we will take reasonable and effective ways to publish announcements. At the same time, we will also report the disposition of user information security incidents in accordance with the requirements of relevant regulatory authorities.

Please understand that the personal information protection measures we provide are only applicable to this website. Once you leave the XR-Oasis Websites and browse or use other websites, services, and content resources, we have no ability and obligation to protect any personal information submitted by you on websites other than the XR-Oasis Websites, regardless of whether or not your access to or browsing of the said websites is based on links or guidance from the XR-Oasis Websites.

 

 

5. Your rights

 

5.1 You have the relevant statutory rights (to the extent permitted by applicable laws and regulations) in relation to the personal information we hold about you and may request access, rectification, or deletion of the data we process about you as well as changes to the scope of your authorized consent and the right to obtain a copy of the personal information. To exercise any of your rights, or if you have any questions, complaints, comments, or suggestions regarding your data subject rights, you may contact us using the contact details provided in this Privacy Policy. For security purposes, we may ask you to verify your identity before processing your request. In principle, we will verify your user identity and respond to your request within 15 business days of receiving your request.

 

 

 

5.2 Early Notification of Discontinuation of Products and Services

 

This website would like to accompany you all the time. If we are forced to stop the operation of this website due to special reasons, we will notify you on the main page of the products and/or services or other appropriate ways to reach you in accordance with the requirements of laws and regulations, stop collecting your personal information, and delete or anonymize your personal information in our possession in accordance with the law.

 

 

5.3 We will refuse your request in the following cases:

  1. There may be a conflict with the fulfillment of obligations under laws and regulations;
  2. Conflicts with national security and national defense security;
  3. Conflict with public security, public health, or significant public interests;
  4. Conflicts may arise with criminal investigation, prosecution, trial, and execution of judgment;
  5. There is sufficient evidence that the user has subjective malice or abuse of rights;
  6. For the purpose of safeguarding the life, property, and other significant legitimate rights and interests of users or other individuals but it is difficult to obtain my authorized consent;
  7. Respond to your request will lead to users or other individuals, organizations, the legitimate rights, and interests of serious harm;
  8. Involving trade secrets.

 

 

6. Scope of Application of the Privacy Policy

This policy applies to this website. Please note that this Privacy Policy does not apply to the following:

  1. Information collected through third-party services (including any third-party websites) that are accessed through our services;
  2. Information collected through other companies or organizations that serve advertisements on our services;
  3. Information collected by third parties who help us with advertising.

Your use of these third-party services (including any personal information you provide to these third parties) will be subject to the terms of service and privacy policies of these third parties (and not this Privacy Policy), as set forth in the third party’s terms and conditions. Please protect your personal information and provide it to third parties only when necessary.

 

 

 

7. How this Privacy Policy is Updated

We may revise the terms of this Privacy Policy from time to time, and we will not reduce your rights under this Privacy Policy without your express consent.

When this Privacy Policy is updated, we will issue an updated version on this website and remind you of the update through a notice on this website or by other appropriate means so that you will be aware of the latest version of this Privacy Policy.

For material changes, we will also provide a more prominent notice (we will indicate the specific changes to this Privacy Policy by means including, but not limited to, email, text message, private message, or a special alert on the viewing page). Material changes referred to in this Privacy Policy include, but are not limited to:

  1. A material change in our service model. For example, the purpose of processing personal information, the type of personal information processed, and how personal information is used;
  2. Significant changes in our ownership structure, organizational structure, etc. That results in changes in the entity that collects and processes your personal information, such as changes in ownership due to business restructuring, bankruptcy and mergers and acquisitions, etc.;
  3. Changes in the main targets of sharing, transferring, or public disclosure of personal information;
  4. Significant changes in your rights to participate in the handling of personal information and the manner of exercising such rights;
  5. Changes in the department responsible for handling the security of personal information, contact information and complaint channels;
  6. When the security impact assessment report of personal information indicates that there is a high risk.

By continuing to use the XR-Oasis Websites, you agree to this Privacy Policy (including any updates).

 

8. How to contact us

If you have any questions, comments, or suggestions about this Privacy Policy, you can contact us in the following ways, and we will normally reply within 15 working days:

 

Email: mobile.products@xr-oasis.com

Phone: (025) 5888 3730

 

Contact Address: 16F, Block A, Kunpeng Building, Jiangbei New District, Nanjing City, Jiangsu Province (江苏省南京市江北新区鲲鹏大厦A座16F)If you are not satisfied with our response, if you believe that our personal information handling behavior has harmed your legitimate rights and interests, you can also seek a solution by going to the Nanjing Arbitration Commission in Nanjing.