Effective date: August 24, 2023
I. How We Collect and Use Your Personal Information
II. How We Share, Transfer, and Disclose Your Personal Information
III. Cookies and Similar Technologies
IV. Legal Basis for Processing Your Personal Information
V. How We Protect and Retain Your Personal Information
VI. Your Rights as a Data Subject
VII. Processing of Minors’ Personal Information
VIII. Changes to this Policy
IX. How to Contact Us and Lodge Complaints or Reports
I. How We Collect and Use Your Personal Information
(1) Personal Information We Collect
The GitMind Chat AI Assistant may collect and use your personal information in the following business scenarios and for the purposes outlined below:
1.1 Login: When you log in to the GitMind Chat AI Assistant, it is considered that you agree to register an account. If you choose to log in with an email, you need to provide your email address.
1.2 Payment and Settlement. After placing an order to purchase any product or service of GitMind Chat, you can choose to use payment services provided by third-party payment institutions (such as Paddle, etc., referred to as “payment institutions”). GitMind Chat needs to provide payment institutions with information such as your order number, transaction amount, and transaction details to confirm your payment instruction and complete the payment.
1.3 Issuing Invoices. If you request an invoice, you need to provide the following information: invoice title, taxpayer identification number, recipient’s email address, and additional information based on your invoicing needs, such as buyer information.
1.4 Message Notifications. We may send announcements related to its products and services through email or other means when necessary. These announcements may be closely related to your rights and obligations, and you may not be able to opt-out of announcements related to GitMind Chat’s products and services.
1.5 Customer Service and After-sales Support. When seeking service support while using GitMind Chat products or services, GitMind Chat will verify your identity and purchased products or services (if applicable) based on your account and order information. This verification is done by examining your software information, device information, as well as the content of emails, screenshots, or documents to identify issues and provide solutions.
1.6 Surveys and Questionnaires. We may collect information from surveys and questionnaires you participate in, including your responses to the survey questions. Additionally, information you provide through various means such as LiveChat, sending emails, or leaving comments on the websites, including your contact name, company name, phone number, email address, and your inquiries.
II. How We Share, Transfer, and Disclose Your Personal Information
GitMind Chat will not share your personal data with any company, organization, or individual outside of GitMind Chat, except for the following circumstances:
1.1 Sharing with Explicit Consent: With your explicit consent, GitMind Chat may share your personal data with third parties.
1.2 Sharing as Required by Law: GitMind Chat may share your personal data with relevant third parties as required by laws, regulations, or mandatory government requests or judicial decisions.
1.3 Sharing with Authorized Partners: For the purpose of fulfilling specific goals stated in this Policy, certain services of GitMind Chat may be provided by third-party partners. In such cases, GitMind Chat may share some of your personal data with these partners to enhance customer service and user experience. GitMind Chat will only share your personal data for lawful, legitimate, necessary, specific, and explicit purposes, and will share only the information necessary to provide the services. Third-party partners of GitMind Chat are not authorized to use the shared personal data for any other purposes. For example, with your permission, GitMind Chat may provide advertising and analytics service partners with information about the effectiveness of their advertisements, but without disclosing your personal identity. Alternatively, GitMind Chat may aggregate, anonymize, or de-identify this information to ensure that individual identification is not possible.
GitMind Chat will not transfer your personal data to other companies, organizations, or individuals, except under the following circumstances:
2.1 With your explicit authorization or consent beforehand.
2.2 To comply with legal requirements, legal procedures, or mandatory government requests or judicial decisions.
GitMind Chat will only disclose your personal data under the following circumstances:
3.1 With your explicit consent.
3.2 GitMind Chat may publicly disclose and share de-identified big data analysis information that has undergone statistical processing and does not contain personally identifiable content, in cooperation with relevant third parties.
III. Cookies and Similar Technologies
To ensure the proper operation of the website, GitMind Chat collects, identifies, and stores small data files called “Cookies” on your computer. These Cookies help recognize specific devices or browsers and enhance your browsing experience. GitMind Chat may place its own Cookies (first-party Cookies) or third-party services integrated on our website may place Cookies on your device (third-party Cookies). However, the use of these technologies will not be employed for purposes other than those stated in this Policy. Cookies may include device information, user access time and date, and user activity information on our website. They are used for the following purposes:
1.1 Functional Purposes: We may set cookies or anonymous identifiers for authentication and security purposes to confirm secure logins to the service, prevent theft, fraud, and other unlawful activities. These technologies also help improve service efficiency, enhance login and response speed.
(2) Web Beacons and Pixel Tags In addition to cookies, GitMind Chat also uses web beacons, pixel tags, and other similar technologies on the website. For example, emails sent by GitMind Chat to you may contain URLs that link to content on the GitMind Chat online service. If you click on such a link, GitMind Chat will track the click to help understand your preferences and improve the online service.
(3) Do Not Track Many web browsers have a Do Not Track feature that sends Do Not Track requests to websites. Currently, major internet standard organizations have not established policies to regulate how websites should respond to such requests. However, if your browser has Do Not Track enabled, we will respect your choice.
IV. Legal Basis for Processing Your Personal Data
We will not process your personal data without a legal basis. The specific legal basis depends on the scenario and type of personal data collected. We typically collect and use your personal data in the following situations:
- To fulfill a legitimate and valid contract between you and us.
- To fulfill legal obligations as defined by law.
- We may collect or use your personal data based on our legitimate interests (or the legitimate interests of third parties). These interests may include operating our company, pursuing legitimate business interests such as responding to your inquiries, improving our products or services, marketing, inspection, and preventing illegal activities. We may also have other legitimate interests and will inform you at the appropriate time.
- With your consent. If you have any doubts about the legal basis for collecting and using your personal data, or need further information, please contact us through the detailed contact information provided under the “How to Contact Us and Complaint Channels” heading. The legal basis for collecting or using personal data will depend on the specific circumstances of the collected personal data and when it was collected.
- Processing publicly available information you disclose or other legally disclosed personal data.
- Conducting news reporting, public opinion monitoring, and other activities for public interest within a reasonable scope, and processing personal data accordingly as necessary by law.
- Other situations as stipulated by applicable laws and regulations.
Please understand and note that, for the situations listed in 1, 2, 3, 5, and 6 above, we do not need your consent to collect and use your personal data.
V. How We Protect and Store Your Personal Information Control Over Your Information:
When you provide personal data to us through registration or other means, GitMind Chat and its parent company, Wangxu Technology Co., Ltd., will not sell or rent your personally identifiable information to others. GitMind Chat will not use or share the personal identifiable information you provide to us in ways unrelated to the content mentioned above without your prior knowledge and permission. Your permission is always respected, and we will not share your information with any third parties that are not representatives of GitMind Chat and do not adhere to our confidentiality policies.
(1) Storage Location
We will store your personal data within Hongkong and comply with the laws and regulations of your jurisdiction.
(2) Storage Period
We will strictly comply with the relevant laws and regulations of China and your country and retain your personal data for the shortest period necessary to fulfill the purposes of our products and services. After the necessary period, we will delete or anonymize your personal data. If it is technically impossible to delete or anonymize the information (e.g., your personal data is stored in backup archives), we will securely store your personal data and avoid further processing until it can be deleted or anonymized. Once deletion is possible, we will immediately delete or anonymize the information.
(3) Security Measures
The security of your personal data is crucial to us. We will strictly comply with relevant laws and regulations and implement reasonable and feasible measures recognized by the industry to protect your personal data, to prevent unauthorized access, disclosure, use, modification, and to prevent information damage or loss. Moreover, we use industry-standard security measures to protect the personal data you provide from unauthorized access, public disclosure, use, modification, data damage, or loss. We have established an access control mechanism to ensure that only authorized personnel can access personal data. We regularly hold security and privacy protection training courses to enhance employees’ awareness of the importance of protecting personal data. To prevent security incidents, we have established a security team led by the operations department and formulated sound warning mechanisms and emergency plans. In the event of a personal data security incident, we will promptly inform you in accordance with the requirements of laws and regulations, and inform you of the basic situation and potential impact of the security incident, the disposal measures we have taken or will take, suggestions for you to prevent and reduce risks, and remedial measures for you. We will inform you of the relevant situation through telephone, notifications, etc.
VI. Your Rights as the Subject of Personal Data
You have the following rights regarding the protection of your personal data. You can email us at email@example.com to exercise these specific rights.
(1) Right to Inquire and Copy
Except as otherwise provided by law or specific confidentiality obligations we have, you have the right to inquire about your personal data at any time.
(2) Right to Transfer
You have the right to request a copy of your personal data processed by us, and in compliance with legal or regulatory requirements, we will provide you with a means to transfer it to other personal data processors of your choice or take other measures to assist you in achieving data transfer.
(3) Right to Correct or Supplement
Your personal data If you intend to correct, update, or supplement your personal data, you can email us at firstname.lastname@example.org to exercise this right.
(4) Right to Delete
Your personal data Please note that not all of your personal data can be deleted when exercising the right to delete. We will only delete when the conditions for deletion stipulated by laws and regulations are met. When deletion of personal data is technically difficult, we will stop processing other than storage and take necessary security measures.
(5) Right to Change the Scope of Consent or Withdraw Consent
For personal data obtained based on your consent, you have the right to change the scope of your consent or withdraw your consent, such as by disabling relevant system functions or canceling your account.
Once you withdraw your consent, we will no longer process personal data obtained based on your consent, and we may not be able to provide services corresponding to this part of personal data. Withdrawing your consent will not affect the legality of any processing actions taken before your withdrawal or the legality of processing your personal data based on statutory grounds.
(6) Right to Cancel Your Account
You can complete the account cancellation by logging in to the app: My – Settings – Account Cancellation, or by contacting us through the official contact information provided by us. We will complete the cancellation or negotiate with you within fifteen working days after receiving your request to confirm the account cancellation.
You are aware and understand that the act of canceling your account is irreversible. After you cancel your account, we will delete or anonymize relevant information about you, but exceptions apply as stipulated by laws and regulations or when deletion is technically difficult. At the same time, all content created by this account before cancellation will be synchronized with the account cancellation and cannot be restored.
(7) Right to Limit Processing
According to applicable laws and regulations, you have the right to limit or refuse us from processing your personal data in certain circumstances.
(8) Right to Interpretation and Explanation
If you have any questions about this policy or any doubts about the processing of your personal information, you can email us at email@example.com to exercise this right.
(9) Right to Complaint and Lawsuit
You have the right to lodge a complaint with the personal data protection regulatory authority in the place where you frequently reside or where the incident occurred,or submit the dispute to the Hong Kong International Arbitration Centre (HKIAC) for arbitration in accordance with its arbitration rules. If you are within the European Union, you can exercise your complaint rights through the following website: For detailed contact information of data protection authorities in the European Economic Area, Switzerland, and certain non-European countries, please visit http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm
(10) How We Respond to Your Requests
To ensure the security of your personal data, we may require you to provide a written request or verify your identity, and we will respond within 15 working days after confirming your identity. If we are objectively unable to reply based on objective reasons, we may extend the response time with your consent, and we will reply within the extended deadline. For your reasonable requests, we generally do not charge a fee, but for multiple repeated requests or requests that clearly exceed reasonable limits, we may charge you a reasonable fee based on administrative costs. For information unrelated to you, information repeatedly requested without reasonable grounds, or requests that may pose a risk to the rights and interests of others, we may refuse and explain the reasons.
In addition, if you are exercising rights on behalf of others, you should provide proof of your identity and authorization for yourself and others. If you, as a close relative of the deceased, request to query, copy, correct, or delete the personal data of the deceased, you may need to provide materials such as proof of your identity, death certificate of the deceased (including an effective judgment of declaration of death), proof of the relationship between you and the deceased, your legitimate interest claim, a will (if necessary), and opinions or authorization from other close relatives (if necessary) through online or offline means, depending on the actual situation.
VII. How We Process Children’s Personal Data
We attach great importance to the protection of children’s personal data. If you are a minor under 14 years of age or are recognized as a child under applicable laws and regulations (such as children under 13-16 years of age according to the GDPR and the laws of EU member states), we recommend that you have your parents or guardians carefully read this Policy and use our services or provide information to us under the premise of obtaining consent from your parents or guardians.
For cases where we collect personal data of children with the consent of parents or legal guardians, we will only use or disclose this information when allowed by law, with explicit consent from parents or legal guardians, or when necessary for the protection of children.
If it is proven that a child has registered and used our products or services without obtaining the consent of a guardian, the guardian can contact us, and we can delete the child’s personal data promptly based on negotiation results.
VIII. Changes to This Policy
(1) We may update this Policy from time to time to provide you with better services in response to legal, technological, or business developments. At the same time, we will revise this Policy in a timely manner based on factors such as legal regulations, national policies, and updates to GitMind Chat products and services. These revisions are an indivisible part of this Policy and have the same legal effect as this Policy. If applicable laws require substantive revisions and your consent, we will comply with legal requirements. However, without your explicit consent, we will not restrict any of the rights you are entitled to according to this Policy.
IX. How to Contact Us and Complaint Channels
If you have any questions or concerns about this Policy, or if you need to report or complain about actions that do not comply with this Policy, please contact us through the following methods:
Company Name: WANGXU TECHNOLOGY (HK) CO., LIMITED
Address: Room 1101, 11th Floor, Raffles Plaza Office Building, 2163 Nanhai Avenue, Nanshan Street, Nanshan District, Shenzhen
We will respond to your requests within fifteen working days or the period required by law and regulations.