privacy

This Privacy Policy is an integral part of the Developer Agreement and applies to all of the services offered by NEXGO GOBAL LIMITED and its global affiliates (collectively, "NEXGO", "we", "us", and "our" ), including the NEXGO Developer Platform ( https://developer.nexgoglobal.com/ , hereinafter referred as “Website” or “Platform”). Please carefully read and fully understand the content of each term herein. AS LONG AS YOU AGREE WITH the DEVELOPER AGREEMENT OR BY ACCESSING TO OR USING OF THIS NEXGO DEVELOPER PLATFORM, WEBSITE OR ANY SERVICE OFFERED BY NEXGO, YOU ARE FULLY AGREEING TO BE BOUND BY THIS PRIVACY POLICY AND IRREVOCABLY AUTHORIZE US TO COLLECT, USE, SHARE, PROTECT, MANAGE AND OTHERWISE INTERNATIONALLY TRANSFER YOUR PERSONAL DATA UNDER THE TERMS AND CONDITIONS AS STIPULATED HEREIN. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, YOU MUST DISCONTINUE THE ACCESS TO OR USE OF OUR WEBSITE, CONTENT OR SERVICE FORTHWITH.


Privacy Policy

The Privacy Policy was updated on [27th, July], 2021.


NEXGO respects your privacy. Therefore, we have developed a Privacy Policy that covers how we collect, use, share, protect, manage and otherwise internationally transfer your personal data. Based on the principle of lawfulness, fairness and necessity, NEXGO will only collect the information necessary for the purpose of performing our services to you in accordance with this Privacy Policy. Please take a moment to read and understand our Privacy Policy and let us know if you have any questions.


Personal data means any electronic or other information which alone or jointly with other information can be used to identify a natural person or make him/her identifiable. This Privacy Policy explains how NEXGO processes your personal data. It should be noted that this Privacy Policy is of a general nature and is not comprehensive, which does not cover all processing scenarios as information about product or service specific data collection and processing will be provided to you in supplementary notices. Therefore, before using a specific product or service, it is recommended that you read the privacy notice or supplementary statement released by NEXGO or applicable agreement entered into force between you and NEXGO for the product or service to understand how it processes your personal data.


This Privacy Policy describes:

1. How NEXGO Collects Your Personal Data

2. How NEXGO Uses Your Personal Data

3. How NEXGO Uses Cookies

4. How NEXGO Shares Your Personal Data

5. How NEXGO Protects Your Personal Data

6. How You Can Manage Your Personal Data

7. International Transfers of Your Personal Data

8. Updates to This Privacy Policy

9. How to Contact Us


1. How NEXGO Collects Your Personal Data

1.1 Personal Data that You Provide to NEXGO

When you use NEXGO Developer Platform, log in your account, retrieve information, upload download documents, connect to our services, contact us to seek after online solution through this Platform or Website, we may collect a variety of information, including your account or your sub-accounts users’ name, phone number, email address, contact address, IP address, your website, qualification or certification documents or other information necessary for our service. NEXGO will take appropriate and necessary measures to ensure the security of the information that you provide. You must ensure that your sub-accounts users, whose information you provide, have consented to you providing their information to NEXGO.

To meet some jurisdictions' requirements on real-name authentication of accounts, NEXGO might ask you to provide a proof of identity issued by the government or relevant information that can identify you.


1.2 Information that NEXGO Collects in Your Use of Services

NEXGO will collect data about your device and how you and your device exchange information with NEXGO products and services. This type of information includes:

a. Log information. When you use NEXGO services or view NEXGO-provided content, NEXGO will automatically collect and log some information, such as the time of access, access count, IP address, and information about incidents (such as errors, crashes, restarts, and upgrades).

b. Location information. NEXGO will collect, use, and process the approximate or location of your device when you access our Developer Platform. Location information can be obtained via IP address, GPS, WLAN (Wi-Fi) or service provider network ID.

c. Information you store on NEXGO servers. For example, the Android Package, logos, screenshots and marketing brochures you upload to the NEXGO Developer Platform will be stored on NEXGO servers for rapid access,distribution and sharing between devices.


1.3 Collection and Use of Non-Identifiable Data

Non-identifiable data refers to data that cannot be used to identify an individual. Examples of non-identifiable data include statistics on website visits and application uploads and downloads NEXGO will collect statistics information to understand how users use our services, contents or Website. By doing so, we can improve our services to better meet your requirements.

We keep your personal data and non-identifiable data separate, and use each independently. Circumstances may arise where NEXGO collects, uses, discloses, and transfers non-identifiable data for other purposes at our own discretion.


2. How NEXGO Uses Your Personal Data

2.1 Register, activate or use a NEXGO Account so that you can enjoy a wider range of features in NEXGO Developer Platform.


2.2 Provide personalized user experience and content.


2.3 Subject to your consent, we may send you information about contents and services you might be interested in, invite you to NEXGO promotional activities and market surveys, or send marketing information to you. If you change your mind, you may withdraw your consent at any time.


2.4 Carry out internal auditing, data analysis, and research; analyze business operation efficiency and measure market shares; and improve NEXGO's products and services.


2.5 Synchronize, share, and store the data you have uploaded, downloaded, as well as the data needed for the download operations.


2.6 Improve our loss prevention and anti-fraud programs.


2.7 Process pursuant to laws and regulations, e.g. tax authority requests.


2.8 Other purposes within specific services or with your consent.


3. How NEXGO Uses Cookies

3.1 To ensure our Website works correctly and provide a safer experience, we may at times place a small piece of data known as a cookie on your computer or mobile device. A cookie is a small piece of text file stored by a web server on a computer, mobile and other devices. The content of a cookie can be retrieved or read only by the server that creates the cookie. The text in a cookie often consists of identifiers, site names, and some numbers and characters. Cookies are unique to the browsers or mobile applications you use, and enable websites to store data such as your preferences.


3.2 Like many other websites or Internet service providers, we use cookies to improve user experience. While the cookies that we use may change from time to time as we improve and update the products, we use them for the following purposes:

a. Authentication. When you visit the Website, we may create a unique ID to identify you. If cookies with this function are not used, the Website will treat you as a new visitor every time you load a web page. For example, if you are redirected to another web page from the Website you are already logged in to and then return to the Website, it will not recognize you and you must log in again.

b. Security. We use cookie to secure the operation of the Website.


3.3 Cookies allow websites to remember your settings such as language, font size on your device, or other browser preferences. This means that a user does not need to reset preferences for every visit.


3.4 Third parties may set their cookies on our Website, like Google. They use these cookies to receive IP, your configuration information about your browser and your access on our Website, but do not collect your personal identity information. You can learn more about how these third parties use cookies by visiting their sites.


3.5 To help you manage cookies based on your own preferences easily, most web browsers provide the option of blocking cookies. You can clear all the cookies stored on your computer whenever you want. For details, please visit the websites of Internet Explorer, Google Chrome, Mozilla Firefox, or Safari.


4. How NEXGO Shares Your Personal Data

4.1 We do not share personal data with other companies, organizations and individuals unless one of the following circumstances applies:

a. Sharing with consent: After obtaining your consent, NEXGO will share the information that you have authorized with specified third parties or categories of third parties.

b. Sharing in compliance with legal obligation and in compliance with laws and regulations: NEXGO may share your information as required by third party for claimed infringement actions or any applicable laws and regulations, for resolving legal disputes, or as required by administrative or judiciary authorities pursuant to law, or reasonable and necessary purposes to implement relevant agreements or this Privacy Policy, or to protect public interest, personal safety and property,intellectual property rights and other legitimate rights of our clients, ourselves, our affiliates, our users or employees.

c. Sharing with NEXGO affiliates: Your information may be shared within NEXGO's affiliates only for explicit, and legitimate purposes, and the sharing is limited only to information required by services.


5. How NEXGO Protects Your Personal Data

5.1 NEXGO attaches great importance to the security of your personal data and has adopted standard industry practices to protect your personal data and prevent it from unauthorized access, disclosure, use, modification, damage, or loss. To this end, NEXGO takes the following measures:

a. We take reasonable and feasible measures to ensure that the personal data collected is minimal and relevant to what is necessary in relation to the purposes for which they are processed. We retain your personal data for no longer than is necessary and relevant for the purposes as stated herein. Where a legal requirement obliges the retention of personal data for a specific minimum period, we will retain data for at least that period.

b. We use a range of technologies such as cryptographic technologies to ensure the confidentiality of data in transmission. We implement trusted protection mechanisms to protect data and data storage servers from attacks.

c. We hold security and privacy protection training courses, tests, and publicity activities to raise employees' personal data protection awareness.


5.2 NEXGO is committed to protecting your personal data. Nevertheless, you recognize that no security measure is perfect and no product, service, website, data transfer, computing system, or network connection is absolutely secure.


5.3 If any personal data security incident occurs, NEXGO will notify you, pursuant to relevant legal and regulatory requirements, of the basic information about the security incident and its possible impact, measures that NEXGO has taken or will take, suggestions about active defense and risk mitigation, and remedial measures. The notification may take the form of an email, text message, push notification, etc. If it is difficult to notify data subjects one by one, we will take appropriate and effective measures to release a Security Notice. In addition, we will also report the handling status of personal data security incidents as required by supervisory authorities.


6. How You Can Manage Your Personal Data

6.1 Access, rectification, deletion, data portability, restriction of processing, objection to processing. Legislation in some countries and regions to which NEXGO provides products and services or from where NEXGO processes personal data, provides that data subjects have the right to request (hereinafter referred to as "requests") access to, rectification of, or erasure of your personal data retained by NEXGO. In addition data subjects have the right to data portability and to restrict and or object to the processing of your personal data by NEXGO including to withdraw consent where such processing is based on consent.

a. Requesting modes and channels
Data subjects' requests must be submitted in accordance with NEXGO designated customer service email channels referring to Article 9 “How to Contact us” at the end of this Privacy Policy or your designed customer managers to facilitate feedback of progress and result. The requests are valid even when the requester does not specify the laws on which the requests are based.

b. Validity of requests
Most laws require data subjects to comply with specific requirements when you initiate requests. This Privacy Policy requires data subjects to: (i).Submit requests through dedicated channels provided by NEXGO; (ii). Provide sufficient information for NEXGO to verify your identities (to ensure those who initiate the requests are the data subjects yourselves or those authorized by you); (iii). Ensure that you requests are specific and feasible.

There are some circumstances, provided by laws and regulations, in which NEXGO may not have to comply with the request in full or at all.


6.2 Consent withdrawal
You can change the authorized personal data collection scope or withdraw your consent without affecting the lawfulness of the processing activities based on the consent and prior to such withdraw. NEXGO will release the methods for withdrawing consent for specific products and services.


7. International Transfers of Your Personal Data

7.1 Our services may be delivered through resources and servers located in Singapore. To offer our services, we may need to transfer your personal data among several countries. Authorized NEXGO personnel and third parties acting on our behalf may access, use and process personal data collected from you in a country/region that is different from the country/region where you entered the personal data, which may have less stringent data protection laws. When we transfer your personal data to other countries/regions, we will protect the personal data as described in this Privacy Policy or as otherwise disclosed to you at the time the data is collected (e.g. via privacy notice or supplementary statement of specific service).


7.2 If you are from the EU, it is important for you to know that the transfer of your data to the recipients in these countries is secured either by the participation on the basis of standard contractual clauses adopted by the European Commission and compliant with the EU data protection laws. By using our Services, you agree to such transfer and processing within the purposes set herein.


8. Updates to This Privacy Policy

8.1 This Privacy Policy may be subject to major changes where change of circumstances occurs. NEXGO reserves the right to update, at our discretion, this Privacy Policy at any time. Should this Privacy Policy be revised from time to time, NEXGO will release the change notice via various channels, for example, posting the latest version on NEXGO Developer Platform. All major changes are hereby incorporated into this Privacy Policy by this reference and your continued use of the NEXGO Developer Platform following the release of such major changes shall indicate your acceptance of the major changes. "Major changes" in this Privacy Policy include but are not limited to:

a. Major changes in our service modes, for example, purposes of personal data processing, types of processed personal data, and ways of using personal data;

b. Major changes in our ownership structure, organizational structure, etc., for example, ownership changes caused by business adjustment, bankruptcy, or acquisition;

c. Changes in the main objects of personal data sharing, transfer, or disclosure;

d. Major changes in your rights regarding personal data processing and the ways in which you can enjoy those rights;

e. Changes of NEXGO departments, contacts, and complaint channels responsible for the security of personal data processing;

f. High risks identified in personal data security impact assessment reports.


9. How to Contact Us

If you have any questions, comments, suggestions, or want to exercise your privacy rights, or have any privacy issues for which you need to lodge a privacy complaint, or want to consult general data protection, please contact us via Email: sales@xgd.com or liaise with your own NEXGO Customer Manager.