Privacy Policy

Xpark Privacy Policy

INFINIX MOBILITY LIMITED (hereinafter referred to as "Xpark", "we", or "our") is the provider and operator of the Xpark platform and services (hereinafter referred to as "this platform"). We fully respect your privacy rights and will do our utmost to safeguard the security of your personal information. In the process of providing products or services (referred to collectively as "this service"), we may collect and use your personal information based on your consent or in accordance with applicable laws and regulations. This Privacy Policy (hereinafter referred to as "this Policy") aims to help you understand how we collect, use, disclose, process, and protect the personal information you provide when using Xpark products or services. It also outlines your rights over this personal information and how we uphold these rights. This Policy applies to all products and services provided by Xpark, including applications, mini-programs, webpages for both computers and mobile smart terminals, software development toolkit (SDKs), application programming interfaces (APIs), or any other forms that may emerge in the future, intended for use on third-party websites and applications.

It is important to note that this Policy does not apply to services provided by third parties. You may receive content or web links from third-party providers. Please carefully consider whether to access links, content, products, and services provided by third parties. Before submitting personal information to third parties, please carefully read their privacy policies. To ensure that you fully understand this Policy and can make informed choices, we strive to present it in a clear and understandable manner, and we emphasize key points by clearly identifying or highlighting them (particularly through bold, capitalization, underlining, etc.). We also provide a pop-up prompt and guide you to understand the core content of this Policy when you first use our services.

Before using our products or services, submitting personal information to us, or agreeing to our collection of your personal information, please read this Policy carefully to understand how we handle your personal information, and please visit our Policy regularly for updates. If this Privacy Policy is updated, we will post notifications on relevant products or websites to inform you of the updates. If you access or use our services after receiving such notifications, it indicates that you agree to the updated Privacy Policy. You can check the "Last Updated" date at the top of the Privacy Policy to confirm the latest update time.

If you have any questions, please feel free to contact us through the following methods:
Privacy@infinix.com
You can also access this Privacy Policy through the following methods:
Xpark Official Website - Bottom - Privacy Policy
Xpark APP > My > Settings > About > Privacy Policy

This Privacy Policy will help you understand the following:

1. How We Collect and Use Your Personal Information

2. How We Use Cookies and Similar Technologies

3. How We Store and Protect Your Personal Information

4. How We Share, Transfer, and Disclose Your Personal Information

5. How Your Personal Information Is Transferred Across Borders

6. Your Rights Regarding Your Personal Information

7. How We Handle Children's Personal Information

8. Third-Party Service Providers and Their Services

9. Supplementary and Updated Provisions of This Policy

10. Joint Controllers

11. How to Contact Us

1.    How We Collect and Use Your Personal Information

I.    General Overview

Xpark firmly believes that basic privacy rights should not vary depending on where you reside. Therefore, we regard any information related to an identified or identifiable natural person as "personal information," especially information related to the natural person's name, identification information, location data, online identifiers, or specific data related to the natural person's body, physiology, genetics, psychology, or associated data, regardless of where the natural person resides.

We only collect information required for specific, explicit, legitimate purposes and ensure that your information is not processed further in ways inconsistent with these purposes. If we intend to use your personal information for purposes not explicitly defined in this Privacy Policy, we will seek your consent again.

When collecting your personal information, we collect it through the following three methods: 1) information you directly provide to us (such as the nickname, avatar, name, and phone number you provide when logging into your account or participating in our marketing activities); 2) information generated during your use of the Platform through automated means (such as device information and service log information); 3) information we obtain from other sources.

You have the right to choose whether to provide personal information when using Xpark products or services or when requested by us. You are not obliged to provide personal information to Xpark. However, in some cases, if you choose not to provide it, Xpark will be unable to provide you with the relevant products or services or respond to or resolve the issues you encounter. We only collect and use your personal information for the purposes described in this Policy. The following examples illustrate the personal information we collect from you:

II.    Main Business Functions of Xpark and Collection and Use Scenarios

The main business function of this Platform is to provide comprehensive services such as online shopping on the network.

1)    Providing Login Services

To facilitate your use of the Platform's features and services, you can log in to the Platform using the Infinix ID service. When you choose to log in using your Infinix account, we will obtain your Open ID, email, and phone number from the Infinix ID service and associate the above information with the Xpark platform, generating a User ID and default nickname. If you refuse to provide this information, you will be unable to register an Xpark account and use related functions. However, this will not affect your normal use of other functions on Xpark in guest mode (browsing and using basic business functions without becoming a registered user).

During the registration and use of the Platform, you can voluntarily provide, fill in, or modify your nickname, name, avatar, gender, marital status, occupation, hobbies, and income range in the personal center to help us understand you better and provide improved services. However, refusing to provide supplementary information will not affect your experience with registration and login functions. When you modify your avatar on a mobile device, we will need to access your gallery and camera permissions. You can disable these permissions at any time through system settings. If you deny these permissions, we won't be able to help you upload or change avatars.

While using the Platform, you can add your favorite stores to the Wishlist, and you can view your collected product information at any time through the personal center. If you enable the email subscription feature, we will send relevant Xpark information to the email address linked to your account. You can manage your subscriptions through the personal center interface. If you receive platform coupons, they will be associated with your account, and you can view them at any time.

If you are a merchant user, after logging into the Platform, you can create your store on the Xpark platform and list corresponding products. In this case, you need to provide the store's name, contact information, and address. Please note that the store information you provide will be publicly displayed on the Xpark platform for other users to browse.

You can send invitation codes to other users through the Xpark platform. During this process, we will record the inviting user's User ID and the invited user's ID.

2)    Providing Address Management Services

To provide a convenient shopping experience, we offer address management services. In this function, we will collect and save the information you submit, including your name, postal code, contact information, and specific address details (country, city, street). You can add, modify, or delete your saved information at any time using the address management function.

3)    Providing Online Shopping Services

You can place orders in the online store through the Platform. When you place an order, we collect your order information (product details, quantity, time, price, discount information) and the delivery address information you select (name, contact information, shipping address).

When you need to make a call to the displayed phone number on the service page, we will request access to your phone permission for making the call. You can revoke this permission at any time through system settings. If you deny this permission, we won't be able to provide you with the corresponding functionality, but you can still use other services normally.

Please be aware that when you shop in a store operated by a merchant user, we will share your order and delivery information with the merchant user to facilitate the transaction. If you purchase our products through distribution channels, we will obtain your user ID and purchase information (product details, quantity, purchase time, coupons, price), and your order information will be shared with the distributor for reference.

You can review the products you purchased through the Xpark platform and leave comments. When you upload or download comment images using your mobile phone, we will need to access your gallery and camera permissions. You can disable these permissions at any time through system settings. If you deny these permissions, we won't be able to help you upload related image information, but you can still use other functions normally.

4)    Providing Online Customer Service

If you encounter any problems while using the Platform, you can contact us through our online customer service to seek help. We may collect the consultation content, chat record content, contact information (email, phone number, call records and content, or other contact information you provide), in order to contact you or help you resolve issues, or record the solutions and results of relevant issues. If you refuse to cooperate in providing such information, we may be unable to provide this service to you, but it will not affect your use of other functions on the Platform.

5)    Providing Participation in Promotional Activities

We may periodically initiate or provide promotional activities for you. When you participate in corresponding promotional activities, we will collect the information you voluntarily provide to us through the promotional activity interface, such as your name and contact information, to contact you and issue prizes. If you refuse to provide the information required for participation in promotional activities, we may be unable to provide you with this service or prizes and rewards, but it will not affect your use of other functions on the Platform.

6)    Providing Advertising and Marketing Services

During your use of Xpark products and services, we and our advertising partners (such as Google Ads) may collect your device information, advertising interaction information (user clicks, click behavior, sources), order information, login status, order information, visit duration, click behavior, and page view information to display relevant promotional content to you (which may include more relevant personalized advertising content). Throughout this process, we will strictly protect your privacy. We may analyze the above information and create user profiles (placing your personal information into one or more fields) to establish a personal profile. Targeted advertising will only be provided within the extent required by applicable laws and with your prior consent. Targeted advertising will only be provided within the extent required by applicable laws and with your prior consent. We may combine the above information with other information (including information from different services or devices such as computers, mobile phones, and other connected devices) to provide and improve our products, services, content, and advertising. You can retain the right to opt out of receiving personalized advertisements and opposing user profile analysis at any time, including identity analysis for direct marketing and automated decision-making purposes. To exercise these rights, you can contact us at Privacy@infinix.com. The pathway to opt out may vary depending on different versions. Please understand and agree that the information you submit on advertising pages is collected and used by third-party advertisers or advertising companies, and they are responsible for protecting the personal information you submit. When using third-party services, you need to accept the constraints of their privacy policies. Please read their privacy policy carefully.

7)    Improving Our Products or Services

We may also obtain other information from you for reasonable purposes of improving our products or services, including:

i.    Device-related information: If you use a mobile device to access our services, we will obtain your device name, device model, Google Advertising ID (GAID), International Mobile Subscriber Identity (IMSI), Internet Protocol (IP) address, Media Access Control (MAC) address, Serial Number (SN), operating system (OS) version and type, Read-Only Memory (ROM) version, Android version, Space Identifier (Space ID), system language, phone settings for country or region, device manufacturer information and model name, device hardware basic configuration information and status, network operator and connection type, device or user identity card information (SIM card).

ii.    Behavioral records: When you use the Platform's services, we will collect detailed usage information of our services for record-keeping, such as user clicks, click behavior, user sources, order information, login status, order information, device information, visit duration, click functions, page view behavior, access time, access open times, usage duration, temporary historical messages, standard system logs, event information (errors, crashes, reboots, upgrades), data usage, and other log information generated by the device's use.

The above information will help us analyze the quality of Xpark services and optimize service functions and page layouts.

III.    Other Instances of Collecting Your Information

In situations permitted by applicable laws, we may obtain your personal information from other individuals, business entities, public channels, or third parties you indicate, as well as cooperative partners and other lawful channels to provide our products or services and assist in ensuring information security and preventing fraud. We will explain this at the time of collection and obtain your consent. We may also collect information about you, your device, or your use of services through other means, which will be explained and consented to at the time of collection. In order to better improve our product layout and provide you with better services, we may analyze, statistically analyze, and predict the collected information in an anonymous manner (including using anonymous data for machine learning or model algorithm training). We will take technical and other necessary measures to process the collected personal information, making it impossible to re-identify specific individuals and irrecoverable. According to applicable laws and regulations, the use of such processed data does not require separate notification and consent.

2.    How We Use Cookies and Similar Technologies

I.    What Are Cookies and Similar Technologies

With the iterative updates of our product features, to ensure the normal operation of the Platform and provide you with a more convenient access experience, as well as to recommend content or advertisements that may interest you, we may store small data files called cookies on your mobile device in existing or future products and services. Cookies usually contain identifiers, site names, and some numbers and characters. Our websites, online services, interactive applications, and email information services may use cookies and other similar technologies, such as pixel tags and web beacons. Because the information collected through cookies and similar technologies does not contain any personally identifiable information, we generally consider it as non-personal information. However, if Internet Protocol (IP) addresses or similar identification markers are considered personal information under the laws of relevant countries, we will also comply with the legal provisions of those countries.

II.    Why We Use Cookies and Similar Technologies

We and our partners use cookies or similar tracking technologies to better understand the usage of the mobile software on your device, including understanding the frequency of your application usage, events occurring within the application, cumulative usage, performance data, and where the application is downloaded from. Specifically:

We will not use Cookies for any purposes other than those described in this privacy policy. You can manage or delete Cookies according to your preferences. You can clear all Cookies saved on your mobile device through browser settings, and you can also choose not to be tracked, opt-out of interest-based advertising, and reset (clear) mobile device settings (content and data) to prevent tracking

3.    How We Store and Protect Your Personal Information

 I.    How We Store Your Personal Information

We store the personal information collected based on your consent in accordance with the provisions of relevant national privacy data protection laws and regulations. Unless prohibited by local laws and regulations, we may store the collected personal information in countries or regions other than the country where our business is located.

Currently, Xpark may store your personal information in: Ireland. Specifically:
The personal information collected and generated in our business will be stored on servers located in Ireland. In the future, based on business needs, we may introduce servers in other regions or countries, and we will update this policy accordingly.

Whether personal information is stored in the country of our business or in other countries or regions in compliance with laws, we will store it in accordance with the regulations regarding data storage as stipulated by relevant laws and regulations. We will also consider the nature, scope, purpose of personal information processing, potential risks, and the serious consequences that may arise in case of any harm, and implement necessary security measures. For example, we will use encryption and de-identification methods to store collected personal information. Additionally, we will store information for the minimum period required based on the business requirements. We will retain data beyond the storage period or delete data that you request us to delete, taking suitable measures without violating relevant laws and regulations.

II.    How We Protect Your Personal Information

We will take other necessary measures to ensure the security of your personal information, prevent data abuse, unauthorized access, unauthorized modification, disclosure, or destruction.

We implement security protection measures to safeguard your personal information and regularly monitor our systems for potential vulnerabilities and attacks. We employ management, technical, and physical protection measures to ensure the security of your personal information by considering its nature, processing methods, and security. We continuously strive to improve these protective measures to ensure the security of your personal data.

Of course, it is important to note that no website, internet transmission, computer system, or wireless connection is completely secure. Apart from our necessary security measures, users also need to enhance their awareness of privacy security risks. For example, when using our services to access third-party websites, links, products, or services, for the security of any data collected by these websites, links, products, or services, please exercise caution and read their terms and conditions carefully. We do not assume any legal responsibility for data security issues caused by such third parties. If you find that certain content, advertisements, or functions on our website, product, or service are provided by third parties and may endanger your personal privacy and security, please contact us promptly. We will prioritize the handling of such issues in accordance with laws and regulations.

Due to the inherent risks of websites, internet transmission, computer systems, or wireless connections not being entirely secure, it's important for users to be vigilant about privacy security risks, in addition to the security measures we implement. For instance, when using our services to access third-party websites, links, products, or services, it's crucial to exercise caution and carefully read the terms and conditions of those websites, links, products, or services regarding the security of any collected data. We do not hold legal responsibility for any data security issues caused by such third parties. If you come across content, advertisements, or functions on our website, products, or services that might be provided by third parties and could jeopardize your personal privacy and security, please contact us promptly. We will handle such matters as per legal requirements and regulations.

4.   How We Share, Transfer, and Disclose Your Personal Information

When it comes to sharing, transferring, and disclosing your personal information, we uphold the principles and requirements of minimization, necessity, and legal obligation. Generally, we do not share, transfer, or disclose your personal information to external parties. However, in cases where relevant laws and regulations apply or permit, we may share, transfer, or disclose your personal information in the following circumstances:

I.    How We Share Your Personal Information

We will not sell any personal information to third parties. To provide you with timely services, your personal information may be shared with Xpark's affiliates. We will only share information within Xpark's affiliates for legitimate and explicit purposes, and we will share only the necessary information required to provide services, subject to the constraints of the stated purposes in this privacy policy. If the relevant purpose is not included in this policy, we will explain it in the privacy policy or notice specific to the corresponding product or service.

We may share the necessary personal information with authorized third-party partners (including technical service providers, data storage providers, after-sales service providers, marketing promotion providers, third-party SDK service providers, etc.) to perform certain functions or provide you with better services and user experiences. Specifically, (1) to ensure smooth order processing, we provide your delivery address to logistics service providers to complete logistics delivery; (2) our technical service providers provide technical support for our customer service platform to ensure the smooth functioning of our customer service function; (3) if you purchase from a merchant user's shop, your order information and delivery address will be shared with the seller to complete the order. We conduct such sharing activities based on the principles of minimization, necessity, and legal permission. Before sharing information, we will sign strict confidentiality agreements with authorized partners and require them to process personal information in accordance with this policy and the relevant confidentiality and security measures required by applicable laws in your jurisdiction. Additionally, we will require them to provide data security features and information security qualifications (such as level protection assessment, information security management system, etc.). When embedding SDKs or similar applications of authorized partners on our platform, we fulfill the obligation of careful notification and require that the SDK obtaining information protects your data security.

For evaluation, analysis, or other business services, we may also share your non-personal information with third parties. For instance, we may use aggregated information to help partners (such as advertising providers) understand the effectiveness of their services, feedback, and usage trends.

In cases involving mergers, acquisitions, bankruptcy liquidation, asset transfers, and other related transactions, if personal information transfer is involved, we will require new entities holding your personal information to continue to be bound by this privacy policy through agreements or other appropriate measures. We will also require such entities to implement confidentiality and security measures for personal information processing that are no less than the requirements of this policy.

II.    How We Transfer Your Personal Information

Xpark will not transfer your information to any other party unless the following circumstances arise:

III.    How We Disclose Your Personal Information

Xpark may need to disclose your personal information in accordance with legal requirements, statutory procedures, litigation, and/or requests from government authorities and agencies. We may also disclose information about you if such disclosure is necessary or appropriate for matters of national security, law enforcement, or other issues of public importance.

Furthermore, we may share your personal information with the following parties:

5.   Cross-Border Data Transfer of Your Personal Information

For the purposes described in this Privacy Policy, and with compliance to applicable laws and regulations in your region and your authorized consent, we may transfer your personal information to the resources or servers mentioned in Section Three of this policy for storage or processing. We may also transfer your personal information to third-party service providers and business partners, which could lead to the transfer of your data to other countries or regions. Privacy protection laws in these countries or regions may differ and the legal jurisdiction of these servers may or may not protect personal information to the same standards as your jurisdiction. However, we will still make efforts to comply with our privacy policy to protect your personal information. We will conduct cross-border transfers and other processing of personal information in accordance with the legal requirements of the country or region where the personal information is located.

If we transfer personal information to regions outside of your country's jurisdiction, whether to our affiliated companies or third-party service providers, we will adhere to relevant applicable laws. We will take appropriate security and protection measures to ensure that all such transfers comply with the requirements of local data protection laws.

6.   Your Rights Regarding Your Personal Information

As a data subject, you have a range of rights regarding your personal information, including the right to confirm, access, correct, delete, withdraw consent, and file complaints (collectively referred to as "requests"). We fully understand and respect these rights, and in accordance with applicable laws, these rights are also subject to specific exclusions and exceptions. We will take proactive measures to ensure that your rights are effectively protected. However, please understand that for security reasons, we may need to verify your identity before processing your requests. For legitimate and reasonable requests, we generally do not charge fees. However, for repeated or excessive requests beyond reasonable limits, we may, depending on actual management costs within the limits allowed by applicable laws, charge reasonable fees. We may also refuse requests that are groundless, require excessive technical efforts (such as developing new systems or fundamentally changing current practices), pose risks to the legitimate rights of others, or are impractical, or violate legally mandatory requirements.

7.   How We Process Children's Personal Information

Xpark's products and services are not intended for children under 14 years old or the equivalent age defined by the laws in your jurisdiction (the criteria for determining the age of children vary in different countries or regions, and we will primarily define children based on the laws and regulations of the specific country or region of the business). We do not actively collect personal data of children, and we do not use children's personal information for marketing purposes. If you find that related children's information has been transmitted to us, please send an email to Privacy@infinix.com to contact us, and we will delete the relevant information as soon as possible. If we discover that we have collected personal information of children, we will make efforts to delete the content promptly.

8.   Third-Party Service Providers and Their Services

When using Xpark products or services (such as life services, online customer service, etc.), you may receive links to websites or content and services provided by third parties other than us. Some third-party products or services may be provided through SDKs and other methods. You can decide whether to access or accept websites, products, and services provided by third parties based on your own judgment. Our privacy policy does not apply to any products and services provided by third parties. As we cannot substantially control third parties, we cannot be responsible for the collection and processing of your personal information by such third parties. When submitting any information to such third parties, please carefully understand their privacy policy and pay attention to protecting your personal information.

9.   Supplementary and Updated Policies

Based on changes in our business, technology, applicable laws, and operations, we reserve the right to update or modify this policy from time to time. If this policy is modified, we will publish the latest policy here (on this page), or through our official website www.xpark.com, or by individually notifying you. Please regularly check this page or notifications sent by us to stay informed of updates to this privacy policy. While this privacy policy may be adjusted, we will not diminish your rights according to this privacy policy without your explicit consent.

When we collect other personal information from you or when we use or disclose your personal information for new purposes, we will obtain your explicit consent again in accordance with applicable laws. If you continue to use products and services on the website, mobile devices, and/or any other devices, you will be bound by the updated privacy policy. The content of Xpark products or services described in this agreement may change based on the type of products you use, system versions, or local legal requirements.

10.   Joint Controllers

Shanghai Chuanying Information Technology Co., Ltd. as a joint controller, together with us, is responsible for processing your personal information. Shenzhen Zhiyuanyunshang Technology Co., Ltd and Shanghai Chuanying Information Technology Co., Ltd. have clearly defined their respective responsibilities regarding joint processing, including the GDPR and other applicable legal regulations. You can contact us to obtain more information about joint controllership. Please refer to Section Eleven "How to Contact Us" for contact information.

11.   How to Contact Us

If you have any suggestions, questions, or concerns about our privacy policy or practices related to personal information protection, please contact us through the following means:

Email: Privacy@infinix.com (Note: This email is solely for receiving emails related to our privacy policy or our practices in personal information protection)

We will review your privacy or personal information requests as soon as possible and respond within 15-30 days after verifying your user identity. If your request involves complex or significant issues, we may ask you for more information.

If you are not satisfied with our response, especially when your legitimate rights have been violated by us, you can seek solutions from relevant data protection regulatory authorities in your jurisdiction. If you present such consultations to us, we will provide information about relevant complaint channels that may apply based on your situation.