Copula Website Privacy Policy

In accordance with relevant laws and regulations, we strictly follow the principles of legitimacy, lawfulness and necessity in processing the personal information that you provide, or that is generated, while you use our Products and Services, so that we can provide you with better Products and Services. If you do not agree to provide certain information, you may not be able to use the related Products and Services properly, but your use of other Products and Services will not be affected.

We collect and use your personal information for the following purposes:

1. Enquiries and cooperation communications

When you send us an enquiry or express an interest in cooperation through a contact point on the Website (including the data partnership form) or by email, we collect the name, email address and other contact details you provide, together with your enquiry or proposal, in order to answer your enquiry, contact you, and assess and take the cooperation forward. If you communicate with us on behalf of an organization, this information may include personal information about the organization’s contact person.

2. Website operation and security

To improve the experience of the services we provide and keep our operations secure, we may collect your IP address, browser information and system type.

Where it is necessary for providing the services and we obtain your personal information indirectly from a third party, we will, before collection, require the third party to warrant that the source of the personal information is lawful and compliant and to inform you of the content to be shared, and the information will be provided only after your consent has been obtained in accordance with the law. We will also strictly comply with laws and regulations and with our agreements with the third party in protecting and processing your personal information.

Please understand that the functions and services we provide are constantly being updated and developed. If a function or service not described above collects your information, we will separately explain to you what information is collected, the scope of collection and its purpose through page prompts, interactive flows, website announcements or other means, to obtain your consent.

Under relevant laws and regulations, we do not need your consent to collect and use your personal information in the following cases:

1. Sharing

We treat your information with a high degree of diligence. Except as otherwise expressly provided by laws and regulations, we will not share your information with any company, organization or individual other than Copula without your separate consent. You understand and acknowledge that we may share your personal information with our affiliates and with third parties, such as the authorized partners we work with. Our authorized partners currently include mainly suppliers, service providers and other partners. We send information to suppliers, service providers and other partners that support our business, including by providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customer service, or conducting academic research and surveys.

We share your personal information only for lawful, legitimate, necessary, specific and explicit purposes, and share only the personal information relevant to the services the third party provides. Unless you separately authorize it or laws and regulations provide otherwise, our partners have no right to use the shared personal information for any other purpose. We will sign data protection agreements with third-party partners that require them to take appropriate confidentiality and security measures when processing personal information and set out their responsibilities and obligations for protecting your personal information.

2. Entrusted processing and joint processing

To serve you better, we may, with your consent, entrust the processing of your personal information to third-party partners. We entrust the processing of your information to third-party partners only for lawful, legitimate, necessary, specific and explicit purposes. These partners may include suppliers that provide us with cloud computing and data storage, website technical support and other services. We strictly limit the purposes for which entrusted parties may process information and require them to adopt adequate data security safeguards. If a third-party partner uses your information for a purpose other than those for which we have entrusted the processing to it, it will obtain your consent separately. We entrust these partners with your information on the basis of commonly accepted industry security technologies. Where personal information is entrusted for processing, we will, in accordance with laws and regulations, require the entrusted partners (companies, organizations and individuals), by written agreement or other means, to observe strict confidentiality obligations and take effective confidentiality measures and to process your information only on our instructions and within the scope of the entrustment, and we will supervise their processing of personal information. If you choose to leave your contact details, address or other personal information with a particular third-party partner so that it can contact you, that partner will process your personal information directly. In joint processing, we will likewise sign agreements with our partners that meet the requirements of laws and regulations, and fulfil the related personal information protection obligations.

3. Transfer

We will not transfer your personal information to any company, organization or individual other than Copula, except in the following cases:

4. Public disclosure

We will publicly disclose your personal information only in the following cases:

5. Exceptions to prior consent for sharing, entrusted and joint processing, transfer and public disclosure of personal information

Please understand that in the following cases, your prior authorization and consent are not required for sharing, transferring or publicly disclosing your personal information:

Under the law, sharing or transferring personal information that has been anonymized so that the recipient cannot restore it and re-identify the personal information subject does not constitute external sharing, transfer or public disclosure of personal information, and storing and processing such data does not require separate notice to you or your consent.

Cookies and similar technologies are commonly used on the internet. To keep the Website secure and stable and to improve your browsing experience, we may use cookies or similar technologies to collect and store information about your visits to and use of the Website. We will not use cookies for any purpose other than those described in this Policy.

Clearing cookies: most browsers let users clear cached browser data. You can clear cookie data in your browser settings, but after doing so you may be unable to use functions or services we provide that rely on cookies.

1. Retention period

We retain your personal information only for the shortest period necessary to achieve the purposes described in this Policy, unless laws and regulations provide otherwise. When the retention period expires, or when the purpose of processing has been achieved, cannot be achieved or no longer requires the information, we will delete or anonymize your personal information in accordance with the law. If a retention period required by laws or administrative regulations has not expired, or deletion is technically difficult, we will stop all processing other than storage and the necessary security measures.

2. Storage location

We store within the People’s Republic of China the personal information collected and generated in the course of our operations there. If business needs require us to provide your personal information outside the People’s Republic of China, we will, in accordance with the law, inform you of the overseas recipient, the purposes and methods of processing, the types of personal information involved, and how you can exercise your rights against the overseas recipient, obtain your separate consent, and fulfil the applicable compliance obligations for cross-border transfers of personal information.

We take the security of your personal information very seriously and will endeavor to take reasonable security measures, both technical and organizational, to protect it, so that the personal information you provide is not misused, or accessed, publicly disclosed, used, modified, damaged, lost or leaked without authorization.

1. Security measures

We collect, use, store and transmit user information in line with mature industry security standards and practices, and inform you of the purposes and scope of use of the relevant information through the User Agreement and the Privacy Policy.

Taking into account the Website’s business and how it processes personal information, we will establish personal information protection policies and a security incident response mechanism, and take reasonable and practicable technical and organizational measures, including encryption and access control, to prevent unauthorized access to, or use, disclosure, modification, loss or leakage of, personal information.

We train our employees in data security awareness and skills and strengthen their understanding of why protecting personal information matters. We use access control, identity authentication and permission management, and sign confidentiality agreements with employees and partners who have access to your personal information, setting out their duties and codes of conduct, so that only authorized personnel can access personal information. Anyone who breaches a confidentiality agreement will be held accountable.

Please note that the internet is not an absolutely secure environment. Although we take reasonable and effective security measures and comply with the requirements of laws and regulations, technical limitations and possible malicious acts on the network mean that we cannot guarantee that information will always be absolutely secure. Please keep your introductory file packages safe, provide materials to us only through confirmed contact channels, and avoid sending personal information unrelated to the cooperation.

2. Security incident notification

We will draw up a cybersecurity incident response plan to deal promptly with security risks such as system vulnerabilities, computer viruses, network attacks and intrusions. When an incident that endangers network security occurs, we will immediately activate the plan, take remedial measures and report to the relevant authorities as required.

If a security incident such as the leakage, damage or loss of personal information occurs, we will promptly take remedial measures, identify the cause and do our best to reduce losses.

If a user information security incident occurs, we will, as required by laws and regulations, promptly inform you of the basic facts and possible impact of the incident, the measures we have taken or will take, suggestions on how you can protect yourself and reduce the risks, and our remedial measures for you. We will tell you promptly by push notification, email, letter, text message or other means; where it is difficult to notify each person individually, we will publish an announcement in a reasonable and effective way. We will also report on how we handled the incident as required by the relevant regulators.

The Website and its related services are not intended for minors under the age of 18. If you are under 18, do not use the Website or its related services or provide us with personal information. If we identify or discover that a minor under 18 is using the Website or its related services or has provided us with personal information, we will immediately stop providing the relevant services to them, stop processing their personal information and delete it.

If you become aware of such a case, please tell us through the contact details listed in the “Contact Us” section of this Policy so that we can take these measures promptly.

We attach great importance to your control over your personal information and will do our utmost to protect your rights in it:

1. Accessing and copying your personal information

You have the right to access and copy your personal information, except as otherwise provided by laws and regulations. To exercise this right, you can submit a request through the contact details listed in the “Contact Us” section of this Policy.

2. Correcting or supplementing your personal information

If you find that the personal information we process about you is inaccurate or incomplete, you have the right to have it corrected or supplemented. To exercise this right, you can submit a request through the contact details listed in the “Contact Us” section of this Policy.

3. Deleting your personal information

You can ask us, in accordance with the law, to delete or stop using your personal information through the contact details listed in the “Contact Us” section of this Policy. We will handle your request in accordance with applicable laws and regulations.

In addition, you can contact us through the contact details in this Policy to request deletion of your personal information in the following cases:

If the relevant personal information is held in a backup system and is temporarily difficult to delete, we will stop all processing other than storing it and taking necessary security measures, and will complete deletion when the backup is updated.

4. Withdrawing consent

For processing based on your consent, you can change the scope of your consent or withdraw it through the contact details listed in the “Contact Us” section of this Policy. Once you withdraw consent, we will no longer process the relevant personal information on the basis of that consent. If the personal information is necessary to provide a particular service, we may be unable to continue providing that service. Withdrawing consent does not affect the validity of processing carried out on the basis of your consent before the withdrawal.

5. Transferring your personal information

Where the conditions set by relevant national laws and regulations and by the cyberspace administration authorities are met, if you ask us to transfer your personal information to a personal information processor you designate, we will provide a means of transfer in accordance with the relevant requirements.

6. Restricting or refusing the processing of your personal information

If you wish to restrict or refuse our processing of your personal information, you can contact us through the contact details disclosed in this Policy and make a request. If the personal information is necessary to provide a particular service, restricting or refusing its processing may affect that service.

7. How we respond to your requests

For security, to exercise the rights above you need to submit a written request or otherwise prove your identity. We need to verify your identity before we process your request. In principle we do not charge for reasonable requests, but for repeated requests that go beyond reasonable limits, we may charge a fee to cover our costs as appropriate. We may refuse requests that are needlessly repetitive, require excessive technical effort (for example, developing a new system or fundamentally changing current practice), put the lawful rights and interests of others at risk, or are highly impractical (for example, involving information stored on backup tapes).

Please understand that, in the following circumstances, we will be unable to comply with your requests to exercise the above rights, in accordance with laws and regulations:

We may modify, supplement or update this Policy from time to time and will publish the changes by appropriate means. For material changes, we will also give more prominent notice, such as a website announcement or an email. If you choose to continue using our Products and Services, you must consent again to the revised provisions of this Policy. Please keep yourself informed of revisions to this Policy; if you do not agree to the revised version, you must immediately stop using our Products and Services.

Material changes under this Policy include but are not limited to:

If you have any questions, comments or suggestions about this Policy, you can contact us:

So that we can handle your matter efficiently and reply promptly, you need to submit proof of identity, valid contact details, a written request and relevant evidence; we will process your request after verifying your identity. In general, we will reply within 15 working days.