Nanjing LinkWiFi Network Technology Co., Ltd.(hereinafter referred to as “the Company”) and its affiliates (including without limitation, Shanghai Zenmen Technology Co., Ltd. and its affiliates, hereinafter referred to as “We”) attach great importance to the protection of personal information and privacy of users, so we have formulated a privacy policy covering how to collect, store, use, share and protect user information, ways provided by us for you to access, update, delete and protect these information. We hope to, through this privacy protection statement (hereinafter referred to as “this privacy policy”), give you a clear introduction of our approach to deal with your personal information and other information.
This privacy policy closely relates to your use of WiFi Master Key products and/or services. Before use of any WiFi Master Key products and/or services, please fully read and thoroughly understand WiFi Master Key Privacy Policy (especially those content bold underlined), ensure you are fully aware of our rules for dealing with your personal information (defined as below) and other information, and make an appropriate choice accordingly. If you disagree to any content of this privacy policy, that means you choose to waive the use of WiFi Master Key products and/or services, and you should immediately stop using WiFi Master Key products and/or services. By using any WiFi Master Key product and/or service, you agree to and completely understand all the content of this privacy policy.
1. Thank you for using and trusting WiFi Master Key. We will keep devoted to providing more secure and reliable services for you.
2. All the products and services on the WiFi Master Key platform (including all the products or services of WiFi Master Key and products or services of WiFi Master Key affiliates without a separate privacy policy) are subject to this privacy policy, while certain products and/or services will also be subject to a specific privacy policy.
3. The aforesaid privacy policy for certain products and/or services forms a part of this privacy policy, and if there is any consistency with this privacy policy, the privacy policy for certain products and/or services shall prevail.
4. Unless otherwise stated herein, this privacy policy is not applicable to provision of products and/or services for you by any third party that has accessed via our products and/or services, e.g. products or websites displayed to you in search results, websites that might contain any third-party services, or other websites linked in your services. Please note, if you use any third-party products and/or services and provide your personal information and other information to that third party, your information should be subject to the privacy statement or similar policy of that third party, and we bear no legal liability for any improper use or disclose of your information by that third party.
[Personal Information] Personal information refers to all kinds information that is recorded by electronic or other means and can, alone or combined with other information, identify a specific natural person or reflect activities of a specific natural person.
We will collect and use your personal information and other information for the following purposes only:
Our products and/or services include some specific business functions and additional functions. Our products and/or services include some core functions, which contain functions required for free Internet access, functions required for improving our products and/or services, and functions required for ensuring hotspot connection security. We might collect, save and use the following formation about you to realize these functions. If failing to provide relevant information, you might not be entitled to our products and/or services.
Therefore, in order for us to provide you with better and more personalized products and services, you agree that we can collect the following information:
We might collect information generated when you are using products or services (including way of use). Such information includes:
1) [Device Information]. To provide better products and/or services and improve user experience, we might collect device attribute information (e.g. your hardware model, operating system version, device configuration, unique device identifier, international mobile equipment identification IMEI, network device hardware address MAC, advertising identifier IDFA, etc.), device location information (e.g. location information acquired via GPS or WIFI signal), device connection information (browser type, telecom operator, language) and device status information (e.g. device sensor data, device application installation list). With regard to information collected from any of your devices, we might connect them so that we can provide consistent services for these devices. We might connect your device information or phone number with your WiFi Master Key account for convenience of maintaining consistency of follow-up services.
2) [Log Information]. When you are using WiFi Master Key products and/services, including without limitation, hotspot security check, WiFi security insurance, etc., our server might automatically record some information, such as your use of our products and/or services, IP address, service access URL, browser type, language, information about download, installation or use of any mobile application or software, and service access date, time, length, URL, etc. Please note, the aforesaid information excludes any of your personal information or other information, and also excludes any content that you have sent or shared by using any relevant application, service or website.
3) [Location Information]. When you enable the device positioning function and use our relevant free network connection service provided based on location or any third-party merchant service, we might collect and deal with information about your actual location at that time so that you can acquire the relevant merchandise or preferential push service in a timely manner with no need to manually enter your geographic coordinates. We will use a variety of techniques for positioning, including IP address positioning, GPS positioning and other sensors that can provide relevant information (such as information that might provide nearby devices, WiFi access points and base stations for WiFi Master Key). You can, by closing the positioning function, stop collecting your geographical location information; however, you might not be able to acquire the relevant service or function, or not be able to achieve the effect that would be achieved if the relevant service were available.
All of the foregoing data and information will be collected in an anonymous manner. Meanwhile, we will also encrypt information to ensure security.
We might acquire other information about you out of a reasonable need to provide services and improve service quality, including relevant information you have provided when contacting customer service, questionnaire response information you have sent to us when you are participating in a questionnaire survey or have creative advertising needs, and relevant information acquired by us when you are interacting with our affiliates or partners. With regard to information collected from any of your devices, we might connect them so that we can provide consistent services for these services, such as assisting you to use your WiFi Master Key account for one-click login to the service platform of an affiliate or partner. We might combine information from a specific service with information from other services by use of cookies that create and maintain unique identifiers, pixel tags and similar techniques so as to provide more precise push services, personalized content and advices for you.
1) When registering or logging into a WiFi master key account, you must provide an account name and mobile phone number.
2) If you use any specific products or services provided on the WiFi Master Key platform, to satisfy your product or service needs, after obtaining your consent, the relevant information will be provided, according to the products or services you have chosen:
In the case of using [Hotspot Connection], [Hotspot Registration], [Notice] or [Discovery] services, to provide you with the most accurate, secure and surrounding hotspot information as well as timely and precise news services, you need to enable GPS location information. If not using relevant services, you may choose to close them, and after such closing, you will be unable to use relevant services, which however, will not affect your use of networking services of WiFi Master Key.
In the case of using [Recruitment] services, according to the employer’s requirements, you might need to fill in your real name and mobile phone number. If you decide not to provide such information, this will not affect your use of networking services of WiFi Master Key.
In the case of using [Wallet] services, to provide you with convenient payment services and red envelope functions, you might need to provide your real name, ID card information, bank card information, mobile phone number reserved with the bank and GPS location. If you do no use such services and decide not to provide such information, this will not affect your use of networking services of WiFi Master Key.
In the case of using [Download] services, we need to be permitted to access, modify/delete the contents of the system storage unit. If you decide not to provide such information/permission, this will not affect your use of networking services of WiFi Master Key.
In the case of using [Quick Login] services, in order to help you to quickly login to WiFi Master Key, we will help you to send SMS messages to operators, receive SMS messages from operators and read SMS/MMS messages from operators after you have obtained your consent. If you decide not to provide such information/permission, this will not affect your use of networking services of WiFi Master Key.
In the case of using [WiFi Security Insurance] services, you might need to provide your mobile phone number, frequently used address and ID card information to ensure the insurance company will make timely review on your application for claims. If you decide not to provide such information, this will not affect your use of networking services of WiFi Master Key.
Please note, if you choose not to use any specific products or service, then you are not required to provide relevant information.
To enhance system security when you are using our products and/or services, more accurately prevent fishing hotspot fraud and protect your account or transaction security, we provide security services including without limitation, hotspot security check, WiFi security check, etc.; we will also collect your common software for analysis on free and secure hotspot connection, recommend high-quality free hotspots to you through network traffic monitoring, and find out any possible risks. Please note, the foregoing data and information excludes any of your personal sensitive information, and excludes an content that you have sent or shared by using any other application, service or website.
1. For your more convenience or better experience of using WiFi Master Key, the following additional functions might collect and use your personal information and other information. If you fail to provide personal information or other information, you may still use WiFi Master Key, provided, however, that you might not be able to use these additional information that can bring better experience for you or you might be required to repeat some information when using certain services. These additional functions include:
(1) Personalized recommendation function based on location information: we will collect your instant location information (we only collect your geographical location at that time, but will not combine your location information of every period to determine your trajectory) to determine your location, and automatically recommend merchandise or services available for purchase in your region (e.g. recommending the nearest optional WiFi hotspot to you).
(2) Additional function based on camera: you can use this additional function for taking pictures and code scanning.
(3) Additional function based on image upload: you can upload your photo as an image on WiFi Master Key.
2. The foregoing additional functions might need you to open your geographical location (location information), camera, photo gallery and microphone access permissions to us in your device so as to realize the collection and use of information involved in these functions. You may also decide to open or close these permissions at any time. Please note, by opening these permissions, you authorize us to collect and use these personal information and other information to realize the foregoing functions; by closing permissions, you cancel such authorization, and we will no longer continue to collect or use these personal information or other information about you, and will not be able to provide you with the foregoing functions corresponding to such authorization. Your decision to close permissions will not affect your previous dealing with personal information or other information based on your authorization.
[Third-Party Information] To jointly provide you with products/services or improve the quality and personalization of products/services, or out of such reasonable needs as consideration to security of products/services, we will, according to laws and regulations, or based on your authorization, receive personal information and other information about you from affiliates, alliance members, partners and other trusted third-party suppliers, service providers or agents, and you understand and agree, we will bear no legal liability for any collection or provision behavior of that third party.
1. We will, according to laws, regulations and this privacy policy, and for purpose of realizing our product and/or service functions, make lawful use of personal information and other information collected.
2. After collection of personal information and other information about you, we will conduct de-identification on data by technical means in accordance with laws and regulations, and the user of information so de-identified cannot be identified therefore. Please understand and agree, under such circumstance, we will be entitled to use those de-identified information; and on the premise of not disclosing personal information and other information about you, we will be entitled to analyze the user database and use it for commercial purpose.
3. [Use Authorization] Please note, with regard to all the personal information and other information provided when you are using our products and/or services, unless you have deleted the same or have rejected our collection via system setting, we will continued to be authorized to use such information when you are using our products and/or services.
4. We will conduct statistics on the use of our products and/or services, and might share these statistical information with the public or any third party (including without limitation, communication service provider sending e-mails or push notices on behalf of us, map service provider providing location data for us, financial service provider, etc.) to present the overall use trend of our products and/or services, or maintain and improve our services, but these statistical information excludes any identity information about you.
5. We will share your personal information and other information only for legitimate purposes, and meanwhile, we will conduct desensitization on your information by way of content replacement, anonymous processing, etc., so as to protect the security of personal information and other information about you.
1. To satisfy your personalized demand for online experience and provide you with more relaxed access experience, we will send one or more small data files named Cookies to your computer or mobile device, and such Cookies assigned to you are unique, which can be read only by the Web server that has sent Cookies to your domain. We send Cookies to you for purpose of simplifying the step of repeated login, storing your shopping preferences, or items in your shopping cart, so as to provide shopping preferences for you, assisting you to optimize advertising choice and interaction, and assisting you to determine your login status and account or data security.
2. We will not use Cookies for any purpose other than those specified in this privacy policy. You may manage or delete Cookies based on your own preferences. You may clear all the Cookies saved in the computer, and although most of Web browsers will automatically accept Cookies, generally you may modify browser settings according to your own needs so as to reject Cookies; besides, you may also clear all the Cookies saved in the software. However, if you do so, you might be required to alter user settings in person upon each visit to our website, and all the corresponding information recorded previously will be deleted, which might produce certain impact on the security of services you are using.
In addition to Cookies, we will also use other similar technology on the website, such as Web Beacon, etc. Our webpage often contains some electronic images (called “single pixel” GIF file or “Web Beacon”). We use Web Beacon in the following ways:
1. We will not share your personal information with any company, organization or individual other than WiFi Master Key and its affiliates, unless in any of the following circumstances:
2. We might share your personal information with our affiliates. However, we will only share necessary personal information, and will be limited to the purpose stated in this privacy policy. If any of our affiliates needs to change the purpose of dealing with personal information, we will solicit your authorization or consent again.
We will not transfer your personal information to any company, organization or individual, unless in any of the following circumstances:
We will publicly disclose your personal information only in any of the following circumstances and on the premise of taking security protection measures in line with industry standards:
[Third-Party Service] Please note, your counterparty, the operator of any third-party website you visit, or any third party accessed via us (such as those third parties providing services in WiFi Master Key APP) might have their own privacy protection policy. When you view any webpage created by a third party, or use any application developed by a third party, such third party might place its own Cookies or pixel tags; these Cookies or tags are out of our control and their use is not bound by this policy. We will use commercially reasonable efforts to require these subjects to take protective measures for your personal information; however, we cannot assure these subjects will definitely take protective measures as per our request, so you should directly contact them to acquire details about their privacy policy. If you find any risk exists in the webpage created by such third party or in the application developed by such third party, you are recommended to terminate relevant operations to protect your legitimate rights and interests. WiFi Master Key suggests you should carefully read the privacy statement of such third-party website or service provider for an understanding of their approach to deal with your personal information, so as to bring convenience for prudent decision making.
(I) Storage of information
The personal information we collect and generate within the territory of the People's Republic of China is stored in our server in the People's Republic of China.
At present, we do not provide personal information outside the territory of the People's Republic of China. In the future, we will inform you of the purpose, recipient, security measures and security risks of information leaving the country if WiFi Master Key involves trans-border transmission or storage of personal information, and we will not do so without your consent.
We attach great importance to security of personal information, and take all reasonable and feasible measures to protect your personal information:
1. [Date security techniques and measures] We make a commitment that we will have the information security protection reach a reasonable security level. To protect your information security, we are devoted to using various security techniques and supporting management systems to prevent your information from divulgence, destroy or loss, including establishment of reasonable systems, specifications and security techniques to prevent your personal information from unauthorized access, use, modification or data damage or loss.
Network services of WiFi Master Key take such encryption techniques as transport layer security protocol, and provide security services by way of https, etc., so as to ensure the security of data in transit.
WiFi Master Key takes a variety of encryption techniques for encrypted storage of personal information of users, and assigns a separate secure domain for any storage media or information system that contains personal information of users in a logical or physical isolation manner.
When personal information is being used, such as personal information presentation, personal information correlation calculation, we will use various data desensitization techniques for desensitization on sensitive fields, so as to enhance the security of personal information in use.
WiFi Master Key gives special importance to the security protection of WiFi hotspots and passwords. All the WiFi hotspots and passwords shared by users will use 128-bit keys, under encrypted storage and transmission through 32 rounds of changes, with the encryption algorithm protected by multiple mixed reinforcements, ensuring no one can view the password on the server side or during the transmission process.
The WiFi Master Key client, after encrypted acquisition, will make encrypted storage to the server database, and when any other user connects to the network based on the hotspot shared by you, the system will search the encrypted password from the database, and after secondary encryption, transmit it to the client, and the back office will provide hotspot connection services for that user. During the whole process, your password will be encrypted and hidden to ensure security.
2. [Other security measures taken by WiFi Master Key for the protection of personal information] WiFi Master Key, by establishing information classification and grading systems, user information security management systems, security development specifications, etc., standardizes security behaviors in respect of internal storage, use and sharing of personal information.
WiFi Master Key, by establishing information classification and grading systems, user information security management systems, security development specifications, etc., standardizes security behaviors in respect of internal storage, use and sharing of personal information.
WiFi Master Key realizes comprehensive security control over data through information access confidentiality agreements, monitoring and auditing mechanisms, etc. WiFi Master Key will monitor the act of its staff dealing with your information, continuously provide training for its staff on relevant laws, regulations and privacy security guidelines, reinforce and promote the security awareness, organize all staff to take part in security exams, and hold security and privacy training courses, with an aim to strengthen its staff’s knowledge on the importance of protecting personal information.
3. Please understand, due to technical limits and any possible malicious means, problems might arise for any reason out of our control. Upon occurrence of a personal information security incident, we will, according to laws and regulations, promptly advise you of: basic information and potential impact of that security incident, measures taken or to be taken by us to handle that incident, suggestions for your independent prevention and reduction of risks, remedial measures for you, etc. We will inform you of information about that incident on a timely basis via mail, letter, phone or push notice; if it’s hard to inform personal information subjects one by one, we will make an announcement in a reasonable and effective manner. Meanwhile, we will also, as required by regulators, proactively report the situation of handling that personal information security incident.
4. If we cease operation, we will promptly stop collecting your personal information, send a notice of ceasing operation to you in a one-by-one manner or by form of announcement, and destroy or conduct anonymous processing on personal information held.
(1). You may, via WiFi Master Key login account, “My –profile photo -personal information, and via “My –Feedback”, check your personal information such as identity information or account information, etc, or modify or delete the foregoing personal information, or make relevant privacy and security settings.
(II) Correct your personal information(1) You can change your phone number by clicking on “My - profile photo - Settings - Account & Security-Change your phone number”. You can also change your Name、Profile photo and Gender by clicking on “My –profile photo -personal information”.
(2) If you find that we have handled errors regarding your personal information, you have the right to require us to make corrections. You can file a correction request in the ways listed in "(I) Access to your personal information."
(3) If you find that your personal information collected and stored by us is wrong, you may contact our customer service for correction.
In the following situations, you can require us to delete your personal information:
(1) If you find that our collection or use of your personal information has violated laws, administrative regulations or agreements with you, you may contact our customer service and require to delete your personal information collected under that violation.
(2) If you no longer use our products or services, or cancelled your account;
(3) If we no longer provide you with products or services.
Please note: When you delete information from our service, we may not immediately delete the corresponding information from the backup system, but will delete the information when the backup is updated (but when the hotspot owner cancels the hotspot sharing, it will be canceled in time).(IV) Cancel your account
You have the right to cancel your registered account. You can apply for account cancellation by clicking on "My - profile photo - Settings - Account & Security – Account Cancellation". After your account is cancelled, we will stop providing you with products or services, and will delete your personal information according to your requirements, except for otherwise required by laws and regulations.
Each function requires some basic personal information to be completed (see this Privacy Policy “I. How do we collect and use your personal information and other information”). You may give or withdraw your consent at any time for the collection and use of additional personal information collected by us.
You can do it in the following ways:
You can find WiFi Master Key in your device's System Settings - Application Management and manage, change or delete related permissions.
1.If you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the personal information processing that was previously processed based on your consent.
2. If you cannot access, modify or delete your personal information via the aforesaid ways, or you need to access, modify or delete other personal information generated when you are using our products and/or services, you may contact our customer service for assistance.
3. If you find that your personal information is divulged, especially if your account information is divulged, please immediately contact us as agreed in [How to contact us] at the bottom of this policy, so that we can take appropriate measures.
4. Before response to some requirements stated in (II) and (III) of clause 1, to ensure safety, we need to validate your identity and credentials first, and if passing the validation, processing will be completed within five working days; under any special circumstance, response shall be given within thirty days or the time limit prescribed by law. If dissatisfied with our response, you may also make a complaint with the consumer protection department or file a lawsuit with a court having jurisdiction.
5. In any of the following circumstances, according to laws and regulations, we will not be able to respond to your request:
1. WiFi Master Key attaches great importance to protecting personal information of minors. If you are a minor under the age of 18, before use of our products and/or services, please make sure that your guardian will carefully read this privacy policy, and please use our products and/or services and provide information to us with prior consent of your guardian.
2. If your guardian disagrees to your use of our services or provision of information to us as per this policy, you or your guardian should immediately stop using our services and contact us in a timely manner.
3. If becoming aware upon notice of your written notice or by ourselves that WiFi Master Key has collected personal information of any minor without prior consent of his guardian, WiFi Master Key will immediately stop collecting and using relevant information.
4. WiFi Master Key will protect the confidentiality and security of minor information in accordance with relevant state laws and regulations.
1. To provide better services for you and with the business development of WiFi Master Key, this privacy policy will also be updated from time to time. However, without our explicit consent, we will not cut rights you shall enjoy under this privacy policy. We will prompt you of relevant updates by issuing an updated version at the mobile terminal of WiFi Master Key and prior to the effective date, by website announcement or other appropriate ways, and also you should access WiFi Master Key for a timely understanding of the latest privacy policy.
2. Upon occurrence of any major change, we will inform you in a way that can better prompt you of such change, including without limitation, sending mail, letter, phone, push notice, etc. Major changes referred to herein include without limitation:
3. [Amendment to Privacy Policy] Our possible amendment to this privacy policy forms a part of this privacy policy, and has retrospective effect. By continuing to use our products and/or services, you agree to be bound by this privacy policy so amended.
1. [Governing Law] The execution, interpretation and dispute resolution of this privacy policy shall be governed by the laws of the People’s Republic of China, irrespective of any conflict of laws.
2. [Dispute Resolution] Any dispute between you and WiFi Master Key on the content of this privacy policy or its execution shall be resolved by the parties through friendly consultation; if no consensus can be reached, the parties agree to submit the dispute to a court having jurisdiction in the place where Lianshang is situated for resolution by litigation.
1. If you have any questions, comments or suggestions on this privacy policy or your personal information, please contact us by calling our customer service hotline 021-68639705 or online feedback.
2. We have set up a dedicated department for protection of personal information (or a specialist for protection of personal information), and you can contact them by sending an email to: lianwifi@wifi.com.
Note: This WiFi Master Key Privacy Policy is amended and took effect as of July 26, 2019.