Zen Booster Privacy Policy
Zen Booster Inc. (hereinafter referred to as “our company”) and its affiliates (hereinafter referred to as “we”) attach great importance to the protection of users’ personal information and privacy, so we have developed a privacy policy that covers how to collect, store, use, share and protect user information and the ways we provide for you to access, update, delete and protect these information. We hope that through this privacy protection statement (hereinafter referred to as “the privacy policy”), we can clearly introduce to you how we handle your personal information and other data.
This privacy policy is closely related to your products and/or services using Zen Booster. Before using all products and/or services of Zen Booster, please read and thoroughly understand the Privacy Policy of Zen Booster (especially the underlined content) and make sure that you understand our processing rules for your personal information (as defined below) and other information, and make appropriate choices accordingly. If you do not agree to any content of this privacy policy, it means that you have chosen to give up the use of Zen Booster products and/or services, and please immediately stop using Zen Booster products and/or services. By using any of Zen Booster products and/or services, you agree and fully understand the entire contents of this privacy policy.
Introduction
This policy contains the following contents:
I. How do we collect and use your personal information and other data
II. How do we use cookies and the like
III. Legal sharing, transfer or public disclosure of your personal information
IV. How do we safely protect and preserve the information you provide
V. How do you access and control the information you provide
VI. Protection of minors’ information
VII. Notice and revision
VIII. Governing law and dispute resolution
IX. How to contact us
Special Tips
1. Thank you for your use and trust in Zen Booster. We will continue to provide you with more secure and reliable services.
2. All products and services of Zen Booster (including all products or services of Zen Booster and products or services of Zen Booster affiliated companies without independent privacy policy) are subject to this privacy policy, but certain specific products and/or services will be subject to specific privacy policy.
3. The privacy policy of specific products and/or services mentioned above forms part of this privacy policy. In case of any inconsistency with this privacy policy, the privacy policy of specific products and/or services shall prevail.
4. Unless otherwise expressly specified in this privacy policy, this privacy policy does not apply to products and/or services provided to you independently by third parties that are accessed through our products and/or services, for example, the products or websites shown to you in search results, websites that may contain third-party services or other websites linked to our services. Please note, if you provide your personal information and other data to a third party when using its products and/or services, your information shall be subject to the privacy statement or similar policies of such third party, and we shall not be liable for any improper use or disclosure of the information provided by you by any third party.
I. How do we collect and use your personal information and other data
Personal Information. Personal information refers to all kinds of information recorded electronically or by other means that can identify a particular natural person or reflect the activities of a particular natural person independently or in combination with other information.
We will only collect and use your personal information and other data for lawful purposes as follows:
(I) You authorize us to collect and use your personal information and other data
Our products and/or services include certain business functions and. additional functions, which include the necessary functions to implement the cleaning for acceleration, security protection, software management, etc., and the necessary functions to improve our products and/or services. We may collect, save and use the following information about you to achieve these functions. If you do not provide relevant information, you may not be able to enjoy our products and/or services.
Therefore, in order to provide you with better and more personalized. products and services, you agree, we may collect the following information:
1. Information that may be collected during your use of products or services. We may collect information about your use of products and/or services, including how they are used, including:
1) Device Information. In order to provide the products and/or services, We may collect device property information (such as your hardware model, operating system version, device configuration, unique device identifier, international mobile device identity code IMEI, network device hardware address MAC, advertising identifier IDFA, etc.), device location information (such as location information obtained through GPS), device connection information (browser type, telecom operator, language), and device status information (such as device sensor data, device application installation list). We may correlate information collected from your various devices so that we can provide you with consistent services on those devices. We may associate your device information or phone number with your Zen Booster account to facilitate consistency of follow-up services.
2) Log Information. When you use Zen Booster’s products and/or services including but not limited to cleaning for acceleration, security protection, software management, discovering free WiFi, etc., our server can automatically record some information, such as your use of our products and/or services, IP address, service URL, browser type, and language. Please note, the above information does not include any of your personal information or other information, nor does it include any content that you may send or share through the use of relevant applications, services or websites.
3) Location Information. When you enable the device location function and use our location-based services, we may collect and process information about your actual location at that time, so that you can timely receive relevant products or preferential push services without manually entering your geographical coordinates. We will use a variety of technologies for location, including IP address positioning, GPS positioning and other sensors that can provide relevant information (for example, may provide nearby device information for Zen Booster). You can stop the collection of your geo-location information by turning off the location function, but you may not be able to access the relevant services or functions or achieve the intended effect of the relevant services.
All the above data is anonymous. Meanwhile, we will adopt encryption to ensure the security of information.
2. Necessary functions to improve our products and/or services You understand and agree, when you use Zen Booster services, we may collect your browsing information, your interests and hobbies for data analysis in order to form a user portrait. We may obtain additional information about you for the reasonable purpose of providing services and improving service quality, including the information you provide when you contact customer service, information you send to us when you participate in the questionnaire survey or need creative advertisement, and relevant information we obtain when you interact with our affiliates and partners. We may correlate information collected from your various devices so that we can provide you with consistent services on those devices. We may combine information from one service with information from other services, possibly through the use of cookie, pixel labels and similar technologies that create and maintain unique identifiers, so as to provide you with more accurate push services, personalized contents and suggestions.
3. Information you may need to provide to us when using specific products and services
1) Running environment of your device. In order to ensure the security of your payment, we will identify the software with payment function installed in your mobile phone and check its payment environment;
2) Cache files access. When you enable application garbage cleaning, with your permission, we will access cache files of the applications you are using, and clean them, and in order to help you clean up the cache files, we may need to use permissions to access, modify or delete contents on the SD card;
3) Software permissions and application list. In order to perform security protection, we will scan the software permissions and application list in your mobile phone, timely find the abnormal status of the software, and send software update alerts to you;
4) Camera permission. In order to provide privacy protection of camera monitoring, with your permission, we will access your camera activation and send security tips to you;
5) Network speed information. When you enable network speed PK, with your permission, we will report your network speed record and geographical location for PK with other users and generate PK results;
6) Installed Apps. By using Antivirus function, we will collect your "Insatalled Apps" data to analyze the malware and virus from your device, which service is provided by "TRUSTLOOK" company. The Privacy Policy of Trustlook: https://www.trustlook.com/privacy.html
7) Device conditions. In order to realize the functions of the service, such as optimization, acceleration, searching and killing, display, management, etc., if necessary, we may check the relevant conditions of your mobile terminal device, including but not limited to the running environment, memory, mobile phone information, etc.
Please note, there is no need to provide information if you do not choose to use a particular product or service.
(II) You may choose whether to authorize us to collect and use your personal information and other data
1. In order to make your use of Zen Booster more convenient and improve your use experience, we may collect and use your personal information and other data in the following additional functions. If you do not provide these personal information or other information, you can still use Zen Booster, but you may not be able to use these additional functions that can bring you a better experience or need to fill in some information repeatedly when using certain services. These additional functions include:
(1) Personalized recommendation function based on location information: We will collect your real-time location information (we only collect your geographical location at that time, but we will not combine your location information at different periods to determine your whereabouts) to determine your location, and automatically recommend goods or services that can be purchased in your area.
(2) Additional function based on camera: You may use this additional function to take photos and scan codes.
(3) Security Scanning: Zen Booster shall read scan the newly-installed application to recognize its security state in your device. The result of scanning shall be demonstrated with a suggestion in the suspension window on the desktop of your device. But such scanning shall not obtain any of your using information and data of the application itself.
(4) APP Manager: When you use the function of APP Manager to delete certain application and its data therein, Zen Booster shall obtain the permission to delete the information and data of the to-be-deleted application to execute the deletion.
2. The above additional functions may require you to open access to your geo-location (location information), camera, album (photo gallery) and microphone to us on your device to enable the collection and use of the information involved in these functions. You may also decide to turn these permissions on or off at any time. Please note, by opening the permissions, it represents you authorize us to collect and use personal information and other data to achieve the above functions; and by closing the permissions, it represents you cancel the authorization, and we will no longer continue to collect and use your personal information and other data, and will not be able to provide the aforesaid functions corresponding to these authorizations for you. Your decision to close the permissions will not affect the processing of personal information and other data previously based on your authorization.
(III) You are fully aware that we do not need your authorization to collect and use personal and other information in the following circumstances:
1. Relating to national security or national defense security;
2. Relating to public security, public hygiene or major public interests;
3. Relating to criminal investigation, prosecution, trial or enforcement of judgment;
4. For safeguarding the significant legitimate rights and interests such as life and property of personal information and other data subjects or other individuals, but difficult to obtain the consent of the person;
5. The personal information and other data collected is made public by the personal information and other data subjects themselves;
6. Your personal information and other data are collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;
7. Necessary for execution of contract as per your request;
8. Necessary to maintain the safe and stable operation of the products and/or services provided, such as identifying and dealing with failures of products and/or services;
9. Necessary for legal news reports (if applicable, but only for the purpose of public interests);
10. Necessary for academic research institutions to carry out statistics or academic research based on public interests (if applicable, but only for the purpose of public interests), and when the results of academic research or description are provided externally, the personal information and other data contained in the results are de-identified;
11. Other circumstances stipulated by laws and regulations.
(IV) We obtain your personal information and other data from third. parties
Third-Party Information. To provide you with products/services or to improve the quality of products/services and the degree of personalization or due to concerns about the safety of products and services or other reasonable needs, we will receive your personal information and other data from affiliates, partners and other trusted third-party suppliers, service providers and agents in accordance with laws and regulations or based on your authorization, and understand and agree, we shall not be liable for the collection and provision of such third parties.
(V) Rules for use of your personal information and other data
1. We will use the collected personal information and other data legally in accordance with the relevant laws and regulations and the provisions of this privacy policy for the purpose of realizing the functions of our products and/or services.
2. After collecting your personal information and other data, we will use technical means to de-identify the data in accordance with the relevant laws and regulations, and the de-identified information will not be able to identify the user subject. Please understand and agree, we have the right to use the de-identified information in this case; and without disclosing your personal information and other data, we have the right to analyze and commercialize the user database.
3. Authorization for Use. Please note, during your use of your products and/or services, we remain authorized to use all personal information and other data provided by you when using our products and services, unless you delete or disapprove us to collect it through system settings.
4. We will conduct statistics on the use of our products and/or services, and may share such statistical information with the public or third parties (including but not limited to communications service providers that send email or push notifications on our behalf, mapping service providers that provides us with location data, financial service providers, etc.), to show the overall use trend of our products and/or services, or to maintain and improve our services, but these statistics do not contain any identifying information about you.
5. We will only share your personal information and other data for legitimate purposes. Meanwhile, we will desensitize your information by way of content replacement or anonymous processing to protect the security of your personal information and other data.
II. How do we use cookies and the like
(I) Use of cookies
1. To meet your personalized requirements. We will send one or more small data files called cookies on your computer or mobile device. The cookies assigned to you are unique and can only be read by web servers in the domain where the cookies are published to you. We send cookies to you to simplify your repeated login steps, help you optimize your selection and interaction of advertisements, and help you determine your login status and account or data security.
2. We will not use cookies for any purpose 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 computer. Most web browsers accept cookies automatically, but you can usually modify your browser settings to reject cookies as you see fit. In addition, you can clear all cookies saved in the software. However, if you do this, you may need to personally change the user settings every time you visit our website, and the corresponding information you recorded before will be deleted, which may have some impact on the security of the services you use.
(II) Use of network beacon and similar technologies
In addition to cookies, we will also use online beacon and other similar technologies on the website. Our webpages often contain electronic images (called “single-pixel” GIF file or “web beacon”). We use the network beacon in the following ways:
1. We count the number of visitors by using the network beacon on our website, and identifying registered Zen Booster users by visiting cookies.
2. Through the cookies information obtained, we can provide personalized services for you.
III. Legal sharing, transfer or public disclosure of your personal. information
(I) Sharing
1. Certain third Party.
We will share your personal information with certain third party in the following cases:
(1) It is necessary to provide information in accordance with the applicable laws and regulations and the mandatory administrative or judicial requirements;
(2) It is necessary to provide information in order to safeguard the interests, property or security of Zen Booster, affiliates or partners of Zen Booster, you or other users of Zen Booster or the public;
(4) Only by sharing your information can we provide you with the services you need;
(5) Handle disputes between you and others at your request;
(6) Comply with the provisions of the relevant agreements signed with you (including the electronic agreements signed online and the corresponding platform rules) or other legal documents;
(7) Use based on academic research (if applicable, but only for the purpose of public interests);
(8) Use for the public interests in accordance with relevant laws and regulations.
2. Affiliates of Zen Booster
We may share your personal information with our affiliates. However, we will only share necessary personal information for the purposes stated in this privacy policy. If our affiliates want to change the purpose of processing personal information, we will seek your authorization again. Our affiliates include our affiliated companies and advertising, licensors, suppliers and other partners.
(II) Transfer
We will not transfer your personal information to any company, organization or individual, except in the following cases:
1. Obtain your prior consent or authorization;
2. It is necessary to provide information in accordance with the applicable laws and regulations and the mandatory administrative or judicial requirements;
3. Comply with the provisions of the relevant agreements signed with you (including the electronic agreements signed online and the corresponding platform rules) or other legal documents;
4. In the event of a merger, acquisition, transfer of assets or similar transactions involving the transfer of personal in formation, we will require the new company or organization holding your personal information to remain bound by this privacy policy. Otherwise, we will require the company or organization to re-seek authorization from you.
(III) Public disclosure
We will only disclose your personal information to the public under the following circumstances and on the premise of adopting security measures in line with industry standards:
1. Disclose the personal information you specify in a manner that you expressly agree to in accordance with your requirements;
2. Where it is necessary to provide information in accordance with the applicable laws and regulations and the mandatory administrative or judicial requirements, we may publicly disclose your personal information in accordance with the type and manner of disclosure required. Subject to compliance with laws and regulations, when we receive the above request for disclosure of information, we will require the issuance of corresponding legal documents, such as summons or investigation letters. We strongly believe that the information we are asked to provide should be as transparent as possible to the extent permitted by law. All requests are carefully reviewed to ensure they have a legitimate basis and are limited to data that law enforcement has a legitimate right to obtain for specific investigative purposes. As permitted by laws and regulations, the documents we disclose are protected by encryption keys.
(IV) Statement of third-party liability
Third-Party Service. Please note, your transaction counterparties, operators of third-party websites you visit and third parties who access through us (such as third parties providing services in Zen Booster APP) may have their own privacy protection policy; when you view webpages created by third parties or use applications developed by third parties, these third parties may place their own cookies or pixel labels, which are not under our control and their use is not subject to this policy. We will use commercially reasonable efforts to require these subjects to take protective measures for your personal information, but we cannot guarantee that these subjects will take protective measures in accordance with our requirements. Please contact them directly for details of their privacy policy. If you find that the webpages created by these third parties or the applications developed by third parties are at risk, you are advised to terminate the relevant operations to protect your legitimate rights and interests. Zen Booster suggests that you carefully review the privacy statements of such third-party websites or service providers to understand how they handle your personal information for prudent decision-making.
IV. How do we securely protect and preserve your personal information
(I) Our techniques and measures for protection of your personal information.
The personal information we collect will be stored in Singapore. We attach great importance to the security of personal information, and take all reasonable and feasible measures to protect your personal information:
1. Technical Measures for Data Security. We undertake that we will make information security protection to a reasonable level of security. In order to protect your information security, we are committed to using a variety of security technologies and supporting management systems to prevent your information from being disclosed, damaged or lost, including the establishment of reasonable regulations and safety techniques to prevent your personal information from unauthorized access, use or modification, and to avoid the damage or loss of data.
Zen Booster’s network services adopt encryption technologies such as transport layer security protocol, and provide security services via https and other means to ensure the security of data in the transmission process. Zen Booster adopts a variety of encryption technologies to encrypt and save users’ personal information, and provides security domain isolation for any storage medium or information system containing users’ personal information through logical or physical isolation.
During the use of personal information, such as personal information display, personal information association calculation, we will use a variety of data desensitization technologies to desensitize sensitive fields, so as to enhance the security of personal information in use.
Zen Booster will bear no liability for any password leakage or any password being obtained and used by a third party not caused due to Zen Booster.
2. Other security measures Zen Booster takes to protect personal. information. Zen Booster has established information classification systems, user information security management systems and secure development rules to regulate the security of personal information in respect of internal storage, use, sharing, etc. Zen Booster controls the overall security of data through information contact confidentiality agreements and monitoring and auditing mechanisms.
Zen Booster will monitor the behavior of staff in handling your information, and continuously provide training for staff on relevant laws and regulations and privacy policies to strengthen the security awareness, and will also organize all staff to take security exams, and conduct security and privacy protection training courses to enhance staff’s awareness of the importance of protecting personal information.
3. Please understand that problems may be caused by factors beyond our control due to technical limitations and possible malicious means. In the event of an unfortunate personal information security incident, we will promptly inform you, in accordance with the requirements of laws and regulations, of the following: basic situation and possible impact of security incidents, measures we have taken or will take, suggestions for you to prevent and reduce risks by yourself, remedies for you, etc. We will promptly inform you of the relevant information by email, mail, phone or push notification. When it is difficult to inform the subjects of personal information one by one, we will release an announcement in a reasonable and effective way. Meanwhile, we will also take the initiative to report the handling of personal information security incidents in accordance with the regulatory requirements.
4. If we cease operation, we will stop the activity of collecting your personal information in time, notify you of the operation cessation in the form of delivery one by one or announcement, and destroy or anonymize the personal information we hold.
V. How do you access and control the personal information you. provide
1. You can contact our customer service to help you correct or delete your personal information, or if you need to access, correct or delete other personal information generated by your use of our products and/or services.
2. If you find your personal information leaking, especially your account leaking, please immediately contact us in the manner as agreed in [How to contact us] at the bottom of this policy, so that we can take appropriate measures.
3. If you find that the collection and use of your personal information by us violates the provisions of laws and administrative regulations or the agreement with you, you may contact our customer service to request the deletion of your personal information collected under such violation.
4. If you find that your personal information collected and stored by us is wrong, you may contact our customer service for correction.
5. Before responding to your request stated in 3 or 4 above, in order to ensure security, we need to verify your identity and certificate data first, and complete processing within five working days after verification; under special circumstances, the reply shall be made within no more than 30 days or within the time limit prescribed by laws and regulations. If you are not satisfied with our reply, you can also complain to the consumer rights protection department or file a lawsuit to the court having jurisdiction.
6. In the following cases, we will not be able to respond to your request as required by laws and regulations:
(1) Relating to national security or national defense security;
(2) Relating to public security, public hygiene or major public interests;
(3) Relating to criminal investigation, prosecution or trial;
(4) There is sufficient evidence that you have subjective malice or abuse of rights;
(5) Responding to your request will result in serious damage to the legitimate rights and interests of you or other individuals or organizations.
7. Change the scope of your authorization
To compete each business function, some basic personal. information will be required (see “I. How do we collect and use your personal information and other data” of this privacy policy). You may at any time grant or withdraw your authorization for the collection and use of additional personal information.
You can do it yourself in the following ways:
You can find Zen Booster in the system settings – application. management of your device and manage, modify or delete related permissions.
After you withdraw your authorization, we will no longer process the. corresponding personal information. However, your decision to withdraw your authorization will not affect the personal information processing previously carried out based on your authorization.
VI. Protection of minors" personal information
1. Zen Booster attaches great importance to the protection of minors’ personal information. If you are a minor under the age of 18, please make sure that your guardian reads this privacy policy carefully before using our products and/or services, and that you use our products and/or services or provide information to us with the consent of your guardian.
2. If your guardian disagrees with your use of our services or provision of information to us in accordance with this policy, please terminate your use of our services immediately and contact us in a timely manner.
3. Upon receipt of your written notice, or upon our own knowledge, where Zen Booster has collected personal information of minors without the prior consent of their guardians, Zen Booster will stop the collection and use of the relevant information immediately.
4. Zen Booster will protect the confidentiality and security of minors’ personal information in accordance with the relevant national laws and regulations.
VII. Notice and revision
1. This privacy policy will be updated from time to time to provide you with better services and with the business development of Zen Booster. However, we will not reduce your rights under this privacy policy without your express consent. We will send an updated version on Zen Booster’s mobile terminal and notify you of relevant content updates through website announcement or other appropriate ways before it takes effect. Please also visit Zen Booster to keep up with the latest privacy policy.
2. In case of major changes, we will inform you in a more prompt manner, including but not limited to sending email, mail, phone, push notifications, etc. Major changes referred herein include but are not limited to:
(1) Major changes in our service model;
(2) Changes in main targets of public disclosure of personal information.
3. Revision of Privacy Policy. Any revision that we may make to this privacy policy forms an integral part of this privacy policy, and has retrospective effect. By continuing to use our products and/or services, you agree to be bound by the revised privacy policy.
VIII. Governing law and dispute resolution
1. Dispute Resolution. In case of any dispute between you and Zen Booster regarding the content of this privacy policy or its implementation, the parties shall resolve the dispute through friendly consultation. If no consensus can be reached through consultation, the parties agree to submit the dispute to a court having jurisdiction in the place our company is located for resolution by litigation.
IX. How to contact us
1. We have a dedicated personal information protection department (or personal information protection specialist) who can be reached at coober.pedy.1776@gmail.com.
May 25th, 2021