Privacy Agreement

Global Tone Communication Technology Co., Ltd. (hereinafter referred to as "GTCOM" or "We", meaning Global Tone Communication Technology Co., Ltd. and its affiliated companies in the Privacy Policy Protection Statement) attaches great importance to the protection of users' personal information and privacy rights, therefore, we have developed the Privacy Policy covering how to collect, store, use, share and protect users' information. We wish to clearly introduce to you how we handle your personal information through our Privacy Right Protection Statement (hereafter referred to as "the Privacy Policy"); the Privacy Policy is closely related to using of the products and/or services provided by GTCOM, please read and fully understand the Privacy Policy and make your choice accordingly before using all the products and/or services provided by GTCOM. When we ask you to provide personal information, you can refuse. However, please understand that certain personal information provided by you is required by many of our products and/or services in order to provide services to you. Based on the above characteristics, if you refuse to provide personal information, we will not be able to perform or fully perform relevant service contents to you, or if this involves an existing product you are using, then we may have to suspend or cancel your right of use. In case of the above conditions, we will inform you in time.

Chapter 1 Scope of Application of the Privacy Policy

The Privacy Policy applies to all products and services (including all of our products or services and those of our affiliated companies without an independent privacy policy) on the GTCOM platform, but some specific privacy policies will also apply to certain specific products and/or services, we will make explanations before providing you with these specific products and/or services.

The privacy policies for the above specific products and/or services constitute part of the Privacy Policy, in case of any inconsistency with the Privacy Policy, the privacy policies for the above specific products shall prevail.

Unless otherwise expressly stated in the Privacy Policy, the Privacy Policy does not apply to circumstances where a third party provides the products and/or services to you independently through access of our products and/or services, for example, the products or websites displayed to you in the search results, the websites that may contain our services, or other sites linked to in our services. Please note: When you use third-party products and/or services, if you provide your personal information to that third party, your information shall be applied to the privacy policy of the third party or similar policies; we are not liable to any improper use or disclosure of your information by any third party.

Chapter 2 Information Collected

In order to provide you with better and more personalized products and services, you agree that we collect the following information:

1.Information provided by you

1)The user account name, mobile phone number, or email address provided by you when you register the GTCOM account and the password you created.

2)When you use the specific products or services (such as applying for payment, buying products or services, navigating, creating a personal homepage, and publishing articles), in order to provide you with the products and services, in addition to the information provided upon registration, you also need to provide us with further information such as your real name, gender, date of birth, ID card number, common address, bank card, portrait and profile. If you do not use specific products and services, you are not required to provide relevant information.

3)Certain personal information (such as your race, religion, personal health, and medical information) may be considered as sensitive personal information due to its specificity. If the contents and information (such as photos of your social activities) provided, uploaded or released by you voluntarily when using our products and/or services may disclose sensitive personal information. Please be careful with it.

2.Information collected during your use of the products or services

We may collect information about your use of products and/or services (including usage modes), such information may include:

1)Registration information: including the user name and nickname that you set upon registration, as well as personal or company information that you may propose to fill in, including the name, company name, ID card number, email address, residential address, fax, and phone number.

2)Device information. In order to provide better products and/or services and to improve the user experience, we will collect device attribute information (such as your hardware model, operation system version, device configuration, unique device identifier, international mobile device identity code IMEI, network device hardware address MAC, and advertising identifier IDFA), device location information (such as location information obtained through GPS, Bluetooth or WIFI signals), device connection information (the type of browser, telecom operator, and the language used) as well as the device status information (such as the device sensor data, and device application installation list). For information collected from your various devices, we may associate it so that we can provide you with a consistent service on those devices. We may associate your device information or phone number with your GTCOM account.

3)Log information. When you use our products and/or services, our server will automatically record some information, such as your usage of our products and/or services, IP address, URL of the accessed service, the type of browser, the language used, information about downloading, installing, or using mobile applications and software, information that communicates with communication software, and date, time, duration and browsing information of accessed service.

4)Location information. When you use our products and/or services with positioning functions, when you turn on the device's positioning function and use related services that we provide based on the location, we may collect and process information about your actual location so that you can get related services without manually entering your own geographic coordinates. We will use a variety of technologies to locate, these technologies include IP addresses, GPS, and other sensors that can provide relevant information (for example, it may provide us with information on nearby device, Wi-Fi access points, and base stations). You can turn off the positioning function to stop the collection of your geographic location information, but then you may not be able to get relevant services or functions, or you may not achieve the desired effects of relevant services.

5)Unique application number. Certain products and/or services contain unique application numbers, when you install, activate, update, uninstall the related products and/or services or when these products and/or services communicate regularly with us (such as software updates), the system will send this number, with information related to the installation (such as operating system type and application version number), to GTCOM.

6)Local storage. We may use browser network storage and other mechanisms (including HTML5) and application data caching to collect information on your device and store it locally.

7)Cookie and tools such as anonymous identifier. The main functions of cookie include facilitating your use of our website products and/or services, as well as helping us count the number of independent visitors. By using cookie technology, we can provide you with more thoughtful personalized services and allow you to set your specific service options.

When you use our products or services, we will send cookie to your device. When you interact with services that we provide to cooperative partners (such as advertising and/or promotion services, and service functions that may be displayed on other sites but provided by us), we allow cookie or anonymous identifiers to be sent to our server.

You can choose to deny cookie by means of modifying the browser settings, however, some functions of our products and/or services depend on them, if you deny or delete cookie, you may not be able to log in or use the services or functions depended on cookie but provided by us.For the above data, we will also conduct encryption to ensure security of the information.

3.Information transmitted from the third-party.

In order to provide you with more optimized services and meet your personalized demands, we can receive your personal information or other information from our affiliated companies or cooperators in accordance with laws and regulations or your authorization.

Chapter 3 Use of Information

For various purposes as below, the information collected will be processed by virtue of a variety of legal reasons and permissions, including obtaining your consent, balancing legal interests, signing and performing contractual obligations and performing legal liabilities.

1.Provide and improve products and services.

We use the information collected to offer and improve the products and services provided by us and our affiliated companies, cooperative partners and other trusted third-party suppliers, service providers and agents, and conduct necessary business operations, such as operating products or providing services, evaluating, maintaining and improving performance of the products or services, participating in market research activities related to our products and services, developing new products or services, and providing customer support.

For improving the products and services provided by us and our affiliated companies, cooperative partners and other trusted third-party suppliers, service providers and agents, we may also make statistics and analysis of product usage. In the meantime, we may share this statistical information with the public to display the overall using trend of our services, but this statistical information will not include any of your identity information.

2.Provide personalized products and services

We may combine your information in services (including personal information) to better satisfy your personalized needs (for example, to let you receive more personalized featured contents).

You agree to authorize us and our affiliated companies, alliance members or other cooperative partners to share necessary information so that we can generally improve degree of personalization of products and services provided for you.

3.Communicate with you and personalize communication contents

We may provide you with contents of your possible interest by using the information we collected, including, but not limited to, sending you information about products and services, or displaying personalized third-party promotion information to you by system, or sharing information with affiliated companies, cooperative partners and other trusted third-party suppliers, service providers and agents of GTCOM with your consent so that they can send you information regarding their products and services.

We may also send you important notices by using this information, for example, amendment to relevant GTCOM terms, conditions and policies. Because this information is critical to your communication with us, we suggest that you receive and read such information.

4.Protect legitimate interests

We may use your information for identity verification, customer service, security, fraud detection and credit analysis to prevent, detect and investigate frauds, acts against security, illegalities or breaches against our agreements, policies or rules in order to protect the legitimate interests of you, other customers, us or our affiliated companies, cooperative partners and other trusted third-party suppliers, service providers and agents as well as the general public.

5.Other purposes with your permission & How you access and update your information

Whenever you use our products and/or services, we will do everything possible to guarantee your access to the information in your account. In the event that this account registration information is incorrect, we will try our best to provide ways for you to rapidly update or delete such information in the account (unless we must retain this information by reason of legitimate business or laws). In case of accessing, updating, correcting and deleting the foregoing information, we may request you for identity authentication to secure the information in your account.

Chapter 4 Information Transfer, Sharing and Disclosure


Unless under the following circumstances, without your consent, we will not share your personal information with any of our cooperative partners or other third parties:

1)We may make your personal information available to cooperative partners and other third parties to implement the core functions you need or provide you with the services you need;

2)For purposes of maintaining and improving our services, we may share your information with third parties (such as communication service providers sending e-mails or giving notifications on behalf of us) to help us provide you with more targeted and more perfect service;

3)We will share the information with a third party, such as a cooperative partner, by whom we are entrusted with promotion, however, we will only provide this entrusting party with information regarding promotion coverage and effectiveness and will not provide any information that can be used to identify you, for example, name, phone number or e-mail; or we will sum up this information so that it will not be used to identify you individually. For example, we can inform this entrusting party of how many people have read its promotion information or purchased its commodity after reading this information, or we can provide them with statistical information that cannot identify individuals so as to help them understand its audiences or customers.

4)To the extent permitted by laws and regulations, for purposes of complying with law and protecting the interests, property or security of us and our affiliates or cooperative partners, you or other customers or the public against harm, for example, to prevent frauds and other illegal activities and reduce credit risks, we may exchange information with other companies and organizations. However, this exchange excludes information disclosed by way of selling, renting, sharing or otherwise for purposes of earning profits by violating the undertakings made in the Privacy Policy.

5)Assisting in settling a dispute or controversy between you and others on your legitimate demand;

6)Providing your information at the legitimate request of your guardian;

7)Providing the information in accordance with a Single Service Agreement concluded with you (including an electronic agreement signed online and relevant platform rules) or other legal instruments;

8)Providing based on academic researches;

9)Providing based on public interests conforming to laws and regulations.

We will only share your information for legitimate, proper, necessary, specific and explicit purposes. We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share information, and request them to handle the information as per our instructions, the Privacy Policy and any other relevant confidentiality and security measures.


1)With continuous development of our business, we may conduct merger, acquisition, asset transfer or similar transactions and your information may be transferred as part of such transactions. We will request the new company or organization holding your information to continue to be bound by the Privacy Policy; otherwise we will request this company or organization to obtain your consent on authentication.

2)We will transfer your information to other parties after obtaining your explicit consent.


We will only disclose your information on conditions that security measures conforming to industrial standards are taken under the following circumstances:

1) Information designated by you is disclosed in a disclosure manner explicitly consented by you based on your demand;

2) Where your information must be provided in accordance with requirements of laws and regulations, mandatory administrative law enforcement or judicial requirements, we may disclose your information pursuant to the required information type and disclosure manner. Subject to the conditions prescribed by laws and regulations, in case that we receive a request for disclosing above information, we will request the receiving party to issue legal instruments related thereto, such as a summons or survey letter. We firmly believe that information requesting us to provide should be as transparent as possible to the extent permitted by law. All requests have been under careful scrutiny by us to ensure that they have legal ground and that the data is only limited to that obtained by the law enforcement department with legitimate rights for particular investigation purposes.

Chapter 5 Information Access and Control

You can access and manage your personal information obtained by us on personal setting of our platform or do the same by contacting us.

1.In the event that you agree us to use your personal information, you are entitled to revoke this agreement at any time;

2.You can access and query your personal information at any time;

3.You can update, supplement and correct your personal information at any time;

4.You can request to delete your personal information at any time;

5.You can, at any time, alter by setting personal information, or revoke by contacting us, the authorization that you grant to us to use and share your personal information.

Definition of personal information. It means the information that can be used alone or in combination with other information to identify the identity of a particular natural person or to reflect the activity of a particular natural person, which is recorded by means including, but not limited to, of electronics.

Chapter 6 Updates to Privacy Policy

1.Our privacy policy may be amended from time to time.

2.Without your explicit consent, we will not limit the rights you shall enjoy under the Privacy Policy. We will post any amendment to the Privacy Policy on particular pages. If you choose to use our products or services continuously, it means that you agree to be bound by the updated Privacy Policy and its relevant policies.

3.In addition, we will provide a more conspicuous notification for major amendments (including, we will give a notice by way of website announcement for some certain services, specifying specific amendments to the Privacy Policy).

4.Major amendments referred in the Privacy Policy include, but are not limited to:

4.1.Major changes in our service model. For example, the purpose for processing user information, the type of user information handled, and the use of user information;

4.2.Major changes in our control rights, equity structure and organizational structure. For example, change of owners due to business adjustment, bankruptcy and merger;

4.3.Changes in the main objects of user information sharing, transfer or public disclosure;

4.4.Major changes in your rights to participate in the processing of user information and the way of exercising such rights;

4.5.Changes in the department in charge of user information security, contact information, and complaint channels;

4.6.A high risk shown in user information security impact assessment report.

Contact Us

If you would like to make a complaint and report about network information security, or have any questions, concerns or suggestions about the Privacy Policy and your information, or any questions about this Statement or GTCOM's privacy measures, please contact our coordinators.