Last updated: Oct. 18, 2021

Shanghai Heading Information Engineering Co., LTD. (registered address: No. 1588 Lianhang Road, Pujiang Town, Minhang District, Shanghai, hereinafter referred to as "we" or "Heading") is the operator of Heading's series of products, we attach great importance to the protection of users (hereinafter referred to as "you") personal information and privacy. In your use of Heading products/services, we will collect, use, save and share your related personal information. In order to present your use of our products/services and our processing of your personal information, we have formulated this Legal Notice and Privacy Policy (hereinafter referred to as the "Policy"), and we promise to process your personal information in strict accordance with this policy.

We hereby remind you that:
This privacy policy applies to all products and services of Heading (hereinafter referred to as "Heading Series products/Services"), Including but not limited to Heading official website and Heading cloud, Heading public number, Heading small program, HeadingSaaS product/service page and client, Heading intelligent hardware and some of the Heading functions/services as a third-party service integrated in the Heading affiliated company ( See the terms of definition) and/or other third party intelligent hardware, software or services. If the products or services of our affiliated companies (the scope of which is detailed in the definition section) use the products or services provided by Heading but do not set independent terms of use and privacy policy, this policy also applies to the products or services.
Before you use Heading series of products/services, please be sure to read this policy carefully and fully understand the contents of the terms, including but not limited to the terms that exempt or limit our liability. You know and confirm that when you check that you have read and agree to this policy, it means that you agree to our processing of your personal information in accordance with this policy. If you do not agree to the terms of this policy, you should stop using the relevant services of Heading products, which will not affect your use of the basic services of Heading products.

This policy will help you understand the following:
 1. Definitions

2. General Use Restrictions
 3. How do we collect and use your Personal Information
 4. How do we use Cookies 5, How we store your Personal Information

 6, How we share, transfer, publicly disclose your Personal Information
 7, How we protect your Personal Information
 8, How you manage your Personal Information
 9, How we handle the personal information of minors
 10, How this policy is updated
 11, how to contact us

1. Definitions

1, Heading: refers to the single or combined name of Shanghai Heading Information Engineering Co., LTD., which develops and provides Heading products and services, and the related affiliated companies established now or in the future.

2, Heading series of products/services: It refers to the HeadingSaaS series of products/services developed and serviced by Heading to help customers improve operational efficiency and profitability in the new retail era.

3, merchant/user: refers to the natural person, legal person or other organization that registers the Heading series products/services account or uses the Heading series products/services.

4. Personal information: refers to all kinds of information recorded by electronic or other means that can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or in combination with other information.

5. Sensitive personal information: refers to personal information that, once leaked, illegally provided or abused, may endanger personal and property safety, easily lead to personal reputation, physical and mental health damage or discriminatory treatment. This privacy policy also includes: network trace, precise location information, transaction records.

6. Deletion of Personal information: refers to the act of removing personal information from the system involved in the realization of daily business functions, so that it can not be retrieved and accessed.

2. General restrictions on use

1, we retain all rights, title and interests in the Heading series product/service information, which belongs to our copyrighted works. We grant you a non-exclusive, non-transferable, limited personal license to use and display our information only on your personal computer or mobile device, and only for the purpose of your interaction with us. Except as otherwise provided in this Policy, you do not have the right to copy, download, display, perform, reproduce, distribute, modify, edit, change or enhance any of our Information in any way. If you violate any of these Terms, this limited license automatically terminates without notice. Upon termination of this License, you must immediately delete and destroy all downloaded and printed information. You have no right, title or interest in any of our Information (and do not own copyright, trademark or other intellectual property rights).

2. You agree not to create a "frame" or "mirror" of any information on or available through us on any other server or Internet-based device without our prior written authorization. You also agree that you will not use any automated device, algorithm or program, or any similar manual means to access, copy or monitor any part of us or the material in it, copy or circumvent our navigational structures, or obtain any information that we did not knowingly provide.

3. You may not:

(1) attempt to gain access through hacking, password cracking, or any other improper means;

(2) test, scan, or detect vulnerabilities in this website; or

(3) Trace, attempt to trace, reverse query or disclose information relating to any feature or content of our other users or any other system, network or server associated with the Site.

(4) Use the Site for any purpose that is illegal or in violation of these terms, or to induce activity that is illegal or infringes our rights.

4. We do not regularly monitor the content or other activities you post on the Site, but we reserve the right to do so. However, if we become aware of inappropriate use of the Site or any of its services, we will, in our sole discretion, respond in any manner we deem appropriate. You acknowledge that we have the right to report to law enforcement any possible violation of the law, as well as reports we receive about such conduct. If required, we will fully cooperate with law enforcement authorities in their investigation of any suspected illegal Internet activity.

3. How do we collect and use your Personal Information

When you use our products and/or services, we need/may need to collect and use your personal information includes the following two types:

In order to provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide the relevant information, you will not be able to use our products and/or services normally;

In order to provide you with expanded functions of our products and/or services, you may choose to authorize the information we collect and use. If you refuse to provide it, you will not be able to normally use the relevant extended functions or achieve the functional effects we intend to achieve, but it will not affect your normal use of our products and/or services.

(1) How we collect and use your personal information in basic functions

1. The personal information you provide to us directly and that we collect

Please note that if you provide the personal information of others, please ensure that you have obtained the authorization of the relevant subject.

(1) Consumer role

When you are not creating a store or conducting online transactions in a merchant's store, your user role is consumer.

(2) Merchant role

When you are using Heading series products/services for business activities, your user role is the merchant.

2. Information we collect from third parties

(1). Consumer role

(2) Merchant roles

3. Message push
 When you use Heading series products/services, we will collect your device identification code through [Gepush SDK, Xiaomi push SDK, Huawei push SDK, oppo push SDK, Meizu push SDK, Tencent SDK, vivo Push SDK, etc.]. We collect the above information to help you immediately receive the message of Heading series products/services push. If you do not provide the above information, we will not be able to provide services to you normally.

4. Provide product or service information display
(1) Equipment information: According to your specific operation in software installation and/or use, Receive and record information about the device you use (including device model, operating system version, device Settings, unique device identifier, device environment and other software and hardware characteristics information), device location information (including your authorized GPS location and WLAN access point, Bluetooth and base station and other sensor information).
(2) Service log information: When you use the products or services provided by our website or client, we will automatically collect your detailed use of our services and save it as a service log, including browsing, click to view, search query, favorite, add to shopping cart, transaction, after-sales, follow to share information, release information, etc. As well as IP address, browser type, telecom operator, language used, date and time of access.
Note that individual device information, service log information is information that does not identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it with personal information, during the combined use, such non-personal information will be regarded as personal information, and we will anonymize and de-identify such information unless authorized by you or otherwise provided by laws and regulations.
(3) In order to provide you with information display, search and push services that are more convenient and more in line with your individual needs, we will extract your preferred characteristics according to your device information and service log information, and produce indirect portraits of people based on the feature labels for display, push information and possible commercial advertisements. If you do not want to accept the commercial advertisements we send to you, you can unsubscribe or close by SMS prompt reply or other means provided by us. When you use our in-site search services, we also provide you with options that are not tailored to your personal characteristics.

5. Help you complete the order and order management

When you sell/order specific goods and/or services in our products and/or services, we will generate an order for you to sell/purchase the goods and/or services through the system. In the process of order management, we may apply to open the relevant rights of your location information (geographical location), camera/camera, photo album and storage, which is used to realize the identification of goods and/or services or the collection by scanning code and the setting management function of related hardware equipment; In the order process, we will collect the name of the consignee, the delivery address, the consignee's contact phone number, and the order will contain the purchased goods and/or service information, the specific order number, the order creation time, the amount to be paid, We collect this information to help you successfully realize the transaction, to ensure the security of your transaction, to inquire order information, to provide customer service and after-sales service and other purposes that we explicitly inform you.
You may order goods and/or services for others, and you will need to provide the aforementioned personal information of the actual purchaser.
In order to facilitate you to understand and query order information and manage order information, we will collect the order information generated when you use our services for display to you and facilitate your order management.
You can fill in/select additional information including other contact numbers and delivery time to ensure the accurate delivery of goods or services.

6. Customer service and dispute handling

When you contact us or make an application for dispute settlement, in order to protect your account and system security, we need you to provide your mobile phone number, ID card information, business license, etc., to verify your identity. If you do not provide the above information, you will not be able to effectively contact customer service or handle disputes, but it will not affect your normal use of our services.
In order to contact you, help you solve the problem as soon as possible or record the solution and result of the relevant problem, we may collect your communication/call records with us, your account information, order information, the information you provide to prove the relevant facts, and the contact information you leave. If you do not provide the above information, the problem you put forward to us may not be timely and effectively handled, but it will not affect your normal use of our services.

(2) Others

1. Use of personal information beyond the scope of authorized consent

If we use Personal information for other purposes not specified in this Policy, if we use personal Information collected for a specific purpose for other purposes, or if we proactively obtain your Personal Information from a third party, we will obtain your prior consent.

2. Personal Information we collect indirectly

If we obtain your personal information indirectly from a third party, we will explicitly ask the third party in writing before collection to collect personal information after obtaining your consent in accordance with the law, and inform you of the content of the shared information, and sensitive information needs to be clearly confirmed by you before providing it to us. And require the third party to make a commitment to the legality and compliance of the source of personal information. We will use no less protective means and measures for the protection of indirectly obtained personal information than we do for the protection of directly collected personal information.

3. Specific features and services

(1) When you participate in questionnaire survey, reward exchange and other activities through the Heading series of products/services official website/small program and other platforms, you may need to take the initiative to submit your or others' name, gender, phone number, identity information, home address and other specific personal sensitive information. If you choose not to provide this kind of information, you may not be able to participate in the relevant specific activities normally, but it does not affect your use of Heading series products/services in other functions. Once you submit the above information, it means that you have known and agreed that we will use the information for related activities.

(2) When you publicly release information and make comments through the Heading series of products/services official website/small program and other platforms, we may judge whether you can enjoy the corresponding functional rights according to your login situation and network log information. Please note that the information you publicly release may involve personal information or even personal sensitive information of you or others. Please consider more carefully whether you share or even publicly share relevant information when using our services. If the information you publicly post involves the personal information of children, you should obtain the consent of the guardian of the corresponding child before Posting.

(3) After your express authorization or consent, we will collect or obtain your geographical location (GPS), camera, microphone, photo album permission information, etc., but the above information or permission will not be turned on or authorized by default, and the collection or acquisition of the above information or permission is for the realization of specific functions or services. Even if we obtain these sensitive information or permissions through your authorization, we will not collect such information from you when the relevant functions or services are not required.

4 Make exceptions with authorized consent

You fully understand and agree that we do not need your consent to collect and use your personal information under the following circumstances:

(1) related to our performance of obligations under laws and regulations;
(2) those related to national security and national defense security;
(3) those relating to public security, public health or major public interests;
(4) those relating to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and execution of judgments;
(5) for safeguarding the life, property and other major legitimate rights and interests of you or other individuals, but it is difficult to obtain the consent of the person;
(6) Personal information that you disclose to the public on your own;
(7) Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
(8) as necessary for the signing and performance of relevant agreements or other written documents with you;
(9) necessary to maintain the safe and stable operation of the products or services provided, such as detecting and disposing of faults of the products or services;

(10) other circumstances stipulated by laws and regulations.
Please be aware that, in accordance with applicable law, if we take technical measures and other necessary measures to process personal information so that the receiving party of the data cannot re-identify a specific individual and cannot be recovered, or we may conduct de-identified research, statistical analysis and prediction of the collected information for the purpose of improving the content and layout of the Heading series of products/services, To provide product or service support for business decisions, and to improve our products and services (including the use of anonymized data for machine learning or model algorithm training), the use of such processed data need not be separately notified to you and obtain your consent.

5. If we stop operating the Heading series of products/services, we will promptly stop the activities of continuing to collect your personal information, notify you of the notice of cessation of operations in the form of one-by-one service or announcement, and delete or anonymize the personal information held by us related to the closed business.

Iv. How do we use cookies and similar technologies

(I) Cookies

In order to ensure the normal operation of the website, provide you with an easier access experience, and recommend content that you may be interested in, we will store cookies and Flash cookies on your computer or mobile device. Or other local storage provided by your browser (or associated application) that typically contains identifiers, site names, and some numbers and characters (collectively, "cookies"). With the help of cookies, websites are able to store data such as your preferences.

If your browser or browser add-on services allow, you may modify your acceptance of cookies or decline our cookies. However, if you do so, it may affect your safe access to our website in some circumstances and may require you to change user Settings each time you visit our website.

(2) Cookie similar technology

In addition to cookies, we will also use website beacons, pixel tags, Etags and other similar technologies on the website.

For example, an email we send you may contain an address link to the content of our website. If you click on the link, we will track the click to help us understand your product or service preferences so that we can proactively improve the customer service experience. A website beacon is typically a transparent image embedded in a website or email. With the help of a pixel tag in an email, we can tell if the email is open. If you do not want your activity to be tracked in this way, you can unsubscribe from our mailing list at any time. An ETag (Entity tag) is an HTTP protocol header that is passed behind the scenes between an Internet browser and an Internet server and can be used in place of a Cookie. ETag can help us avoid unnecessary server load, improve service efficiency, save resources and energy, at the same time, we may use ETag to record your identity, so that we can better understand and improve our products or services. Most browsers provide users with the function of clearing the browser cache data. You can perform the corresponding data clearing operation in the browser Settings function. Note, however, that if ETag is disabled, you may not be able to enjoy a relatively better product or service experience.

3. Use of third-party application toolkits

In order to provide you with more diversified services more efficiently, we may adopt the software development kit provided by a third party in the website/small program of Heading series of products/services. This kind of tool Kit is usually called SDK (Software Development Kit), which refers to a collection of development tools used to create application software for a specific software package, software framework, hardware platform, operating system, etc. The SDKS we use include:

A. Amigo

SDK purpose: data statistical analysis

Type of personal information collected: device information, user access information, log information

Privacy policy links: https://www.umeng.com/page/policy

B. Baidu statistics

SDK purpose: data statistical analysis

Type of personal information collected: device information, user access information

Privacy policy links: https://tongji.baidu.com/web/help/article?id=330&type=0&castk=LTE%3D

We will strictly monitor the above software development kits (SDKS) for obtaining information and do our best to protect data security.

5. How do we store your Personal Information

We will keep your Personal information for the shortest period necessary for the purposes set forth in this Privacy Policy and required by laws and regulations. After the expiration of the foregoing period, we will delete or anonymize your personal information.

We store your Personal information in China. If we need to transfer your personal information outside of China, we will separately seek your consent and comply with relevant laws and regulations.

6. How do we share, transfer and publicly disclose your Personal information

(I) Sharing

We will not share your personal information with companies, organizations and individuals other than Heading Series product/service providers, except in the following cases:

1. Sharing under legal circumstances

We may share your personal information in accordance with laws and regulations, litigation, dispute resolution needs, or as required by administrative and judicial authorities in accordance with the law.

2. Share your personal information with explicit consent

With your express consent, we will share your personal information with other parties.

3. When you choose to share it

To purchase goods or services through the Heading series products/Services official website, we will share the necessary information related to the transaction in your order information with the relevant goods or services providers according to your choice, in order to achieve your transaction and after-sales service needs.

4. Share with affiliated companies

In order to facilitate us to provide you with products and services based on the Heading account, recommend information that you may be interested in, identify abnormalities in member accounts, and protect the personal and property safety of the Heading affiliated companies or other users or the public from infringement, your personal information may be shared with our affiliated companies and/or their designated service providers. We will only share the necessary personal information, and be bound by the purpose stated in this privacy policy, if we share your personal sensitive information or affiliated companies change the purpose of the use and processing of personal information, will again seek your authorization and consent.

5. Share with authorized partners

In order to better optimize the products/services we provide, we may share your information with authorized partners, we will only share your information for the legal, legitimate, necessary and clear purposes stated in this Privacy Policy, we will anonymize and de-identify such information, so that it will not identify individuals. Authorized partners will only have access to the information necessary for them to perform their duties.

(2) Transfer

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

1. Transfer with express consent: After obtaining your express consent, we will transfer your personal information to other parties;

2. In the case of merger, acquisition or bankruptcy liquidation of Heading series products/service providers, or other circumstances involving merger, acquisition or bankruptcy liquidation, such as the transfer of personal information, we will require the new companies, organizations and individuals holding your personal information to continue to be bound by this policy. Otherwise, we will require the company, organization and individual to re-ask you for authorization.

(3) Public disclosure

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

1. With your explicit consent or based on your active choice, we may publicly disclose your personal information;

2. If we determine that you have violated laws and regulations or seriously violated the Heading series products/services related agreement and rules, or to protect the personal and property safety of Heading series products/services users or the public from infringement, we may disclose your personal information in accordance with laws and regulations or with your consent, Including but not limited to the relevant violations and the measures that Heading has taken against you.

(4) Exceptions to obtaining prior authorized consent when sharing, transferring or publicly disclosing personal information

In the following circumstances, the sharing, transfer, and public disclosure of your personal information do not require your prior authorization and consent:

1. Related to national security and national defense security;

2. those related to public security, public health or major public interests;

3. related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and execution of judgments;

4. for the protection of your or other individuals' life, property and other major legitimate rights and interests, but it is difficult to obtain the consent of the person;

(5) Personal information that you disclose to the public on your own;

6. Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

Please be aware that, in accordance with applicable law, if we take technical measures and other necessary measures to process personal information so that the recipient of the data cannot re-identify a specific individual and cannot recover it, the sharing, transfer or public disclosure of such processed data does not require further notice to you and your consent.

Vii. How do we protect your Personal Information

1. We have taken reasonable and feasible security measures in line with industry standards to protect your information and prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information. For example, when exchanging data between your browser and the server, it is protected by SSL protocol encryption; At the same time, we provide HTTPS protocol for safe browsing of Heading series products/services websites; We will use encryption technology to improve the security of personal information; We use trusted safeguards to protect personal information from malicious attacks; We deploy access control mechanisms to ensure that only authorized personnel have access to personal information; And we conduct security and privacy training courses to enhance employees' awareness of the importance of protecting personal information.

2. We have the industry's advanced data security management system with data as the core and around the data life cycle, and improve the security of the entire system from multiple aspects such as organization construction, system design, personnel management and product technology. At present, our important information system has passed the evaluation of network security level protection level 3 or above.

3. The Internet is not an absolutely safe environment, when using Heading series products/services, we strongly recommend that you do not use the non-Heading recommended communication mode to send your information. You can establish contact and share with each other through our services. When you create exchanges, transactions or sharing through our Services, you can choose who you communicate, trade or share with, as a third party that can see your transaction content, contact information, exchange information or share content and other relevant information.

When using Heading series products/services for online transactions, you inevitably have to disclose your personal information, such as contact information or contact address, to the counterparty or potential counterparty. Please protect your personal information properly and only provide it to others when necessary. If you find that your personal information, especially your account or password, has been leaked, please contact the Heading customer service immediately, so that we can take appropriate measures according to your application.

Please note that the information you voluntarily share or even publicly share when using our services may involve personal information or even personal sensitive information of you or others. Please consider more carefully whether you share or even publicly share relevant information when using our services.

Please help us keep your account secure by using a complex password. We will do our best to keep any information you send us secure. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access to information, public disclosure, tampering or destruction, resulting in damage to your legitimate rights and interests, we will bear the corresponding legal responsibilities.

4. In the event of an unfortunate personal information security incident, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce risks, and the remedial measures for you. We will inform you of the incident by email, letter, telephone, push notification and other means. When it is difficult to inform the personal information subject one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

5. Although we have taken reasonable and feasible security measures in line with industry standards to protect your information, we still cannot guarantee the security of your personal information when it is communicated through insecure channels. Therefore, you should take positive measures to ensure the security of your personal information, such as changing your password regularly and not disclosing your account number, password and other personal information to others.

6. You already know and understand that the personal information protection measures provided by us are only applicable to Heading series products/services, once you browse or use other websites, services and content resources, we may not be able to protect any personal information you submit on websites or platforms other than ours, Regardless of whether users log in or browse the above websites based on our links or guidance.

8. How do you manage your Personal information

(1) You have the following rights with respect to your personal information

1. You have the right to access or correct your personal information

If you want to exercise the right to access or correct your personal information, you can access or correct it yourself in the following ways:
 (1) Account information: If you wish to access or correct the mobile phone number, personal information, change your password, etc. bound to your account, you can perform such operations by visiting the Heading Series products/services webpage.
(2) Search information: You can access or clear your search history, view and modify interests and manage other data in the Heading series of products/services and related websites.

2. You have the right to delete your personal information

You have the right to ask us to delete your personal information in the following circumstances:

(1) we collect and use personal information in violation of laws and regulations or agreements with you;

(2) If we share or transfer your personal information with a third party in violation of laws and regulations or the agreement with you, we will immediately stop the sharing or transfer and notify the third party to delete it in a timely manner;

(3) If we publicly disclose your personal information in violation of laws and regulations or the agreement with you, we will immediately stop the public disclosure and issue a notice requiring the relevant recipient to delete the relevant information;

(4) You no longer use our products or services, or you cancel your account, or we terminate our services and operations.

3. You have the right to change the scope of your consent

You can change the scope of your authorization for us to continue to collect personal information or withdraw your authorization by deleting the information, turning off the relevant functions in the device's own operating system (such as storage, telephone, GPS geolocation, microphone, camera), or making privacy Settings in the Heading series product/service website or software. You can also withdraw your full authorization for us to continue to collect your personal information by cancelling your account. Please understand that each business function requires some basic personal information to complete. After you withdraw your consent or authorization, we cannot continue to provide you with the corresponding services for withdrawing your consent or authorization, and we will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the processing of personal information previously carried out based on your authorization.

4. You have the right to cancel your account

You can log in to the Heading series product/service account, click on you need to cancel the account, after you confirm to delete your account information, we will delete the personal information related to your account. Your cancellation of the above account behavior is irreversible, we will stop providing you with products or services, no longer collect your personal information, you will not be able to enjoy the rights and interests or assets related to the above account.

(2) Responding to your above requests

If you are unable to exercise your rights according to the above methods, you may contact us using the contact information set out in this Privacy Policy. For security purposes, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before we process your request.

For your reasonable request, we do not charge a fee in principle, but for repeated requests that exceed a reasonable limit, we will charge a certain cost fee depending on the situation. For those requests that are unreasonably repeated, require too much technical means, bring risks to the legitimate rights and interests of others, or are very impractical, we may refuse.

(3) Exceptions to response circumstances

In the following circumstances, we will not be able to respond to your request:

1. Related to our fulfillment of obligations under laws and regulations;

2. directly related to national security and national defense security;

3. directly related to public security, public health, or major public interests;

4. directly related to criminal investigation, prosecution, trial and enforcement of judgments;

(5) where we have sufficient evidence that the subject of personal information has subjective malice or abuse of rights;

6. In order to protect the life, property and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the consent of the person;

7. Responding to the request of the personal data subject will cause serious damage to the legitimate rights and interests of the personal data subject or other individuals or organizations;

8. Involving trade secrets;

9. Other circumstances prohibited by laws and regulations.

9. How do we handle minors' personal information

In the e-commerce activities, we assume that you have the corresponding capacity for civil conduct. If you are a minor, we ask you to ask your parents or guardians to read this Privacy policy carefully, and to use our services or provide information to us with the consent of your parents or guardians.

In cases where personal information of minors is collected with the consent of parents or guardians to use our products or services, we will only use, share, transfer or disclose this information as permitted by laws and regulations, with the express consent of parents or guardians, or as necessary to protect minors.

10. How to update this policy

(a) Our Privacy Policy may change from time to time. We will not limit your rights under this Privacy Policy without your express consent. We will post any changes we make to this Policy on a dedicated page.

(2) For major changes, we will also provide more prominent notice (including that we will notify by way of publicity on the Heading series products/services website or provide you with pop-up tips). The material changes referred to in this policy include but are not limited to:

1. Significant changes to our service model. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;

2. We have significant changes in terms of control, etc. For example, changes in information controllers caused by mergers and acquisitions;

3. The main object of personal information sharing, transfer or public disclosure has changed;

4. Significant changes in your rights to participate in the processing of personal information and the way in which they are exercised;

5. Changes in our departments responsible for handling personal information security, contact methods and complaint channels;

6. The personal information security impact assessment report indicates that there are high risks.

Your continued use of the Site/Applet after we have made such amendments and posted a notice of change constitutes your understanding of and acceptance of the revised policy.

11. How do I contact us

If you have any questions about this Privacy Policy or the protection of your personal information, you may send your written questions, comments or suggestions to the Customer Service Department at the following address:

Company name: Shanghai Heading Information Engineering Co. LTD

Registered address: No. 1588 Lianhang Road, Pujiang Town, Minhang District, Shanghai

Common office address: No. 1588 Lianhang Road, Pujiang Town, Minhang District, Shanghai

Or you can also contact the customer service department through the following telephone:

Contact number: 021-54325000

Normally, we will respond within 15 working days. If you are not satisfied with our reply, especially if our personal information processing behavior has harmed your legitimate rights and interests, you can also complain or report to the regulatory departments of Cyberspace, telecommunications, public security and industry and commerce, and you can also seek a solution by filing a lawsuit with the court with jurisdiction in the place where the defendant is domiciled.