Xiaomi Document Reader Privacy Policy
1. Introduction
Thank you for choosing to use the Xiaomi Document Reader software services (hereinafter referred to as "the Services") developed and operated by WPS Software Pte. Ltd. and/or its affiliates (hereinafter referred to as "we", “us” or "WPS"). For purpose of this Privacy Policy, “affiliates”means any entity who, either directly or indirectly controls WPS, or who is controlled by WPS, where the term “control”shall mean direct or indirect ownership of at least fifty percent of voting interests or having the power to direct or cause the direction of management and set the policies of an entity, whether such control is exercised by voting rights, contractual arrangement or otherwise.
Scope of application of the Service:
l Xiaomi Document Reader client (a client application running on the Android operating system);
l Xiaomi Preview SDK (referring to the Xiaomi Document Reader integrated into third-party developers in the form of an independent SDK plugin).
To protect your privacy when you use our Services, we developed this Privacy Policy, which explains how we process the personal data (also referred to as “information”) we collect about you, and for what purposes. Please note that this Privacy Policy only applies to our Services, and does not apply to any third-party websites, products, services or applications, even if part or all of our Services are accessible through them. This Privacy Policy reflects our firm commitment to your data privacy and our persevering endeavor to full compliance with international standards and applicable regulations. Our dedication ensures transparency, accountability, and high standard of data protection in all aspects of our operations in connection with the provision of the Services.
To briefly summarize, this Privacy Policy includes the following sections:
Introduction
Language and Revision to This Privacy Policy
How We Collect and Use Your Information
Cookies and Similar Technologies
With Whom We Share Your Information
Cross-border Transfer of Information
Your Rights in Relation to Our Use of Your Information
The Security and Storage of Your Information
How Long We Retain Your Information
Our Policy Towards Minors
Links to Other Sites
Additional Privacy Information for EEA Users
Additional Privacy Information for California Residents
Contact Us
As we operate on a global scale, we understand that our users may come from different regions in the world. In order to meet the legal requirements in your region, we have included region-specific sections in this Privacy Policy. Please view the corresponding section below in addition to other parts of this Privacy Policy to get information specific to your region:
(1) If you are an user in the EEA, please see the section headed “Additional Privacy Information for EEA Users”to view the EEA specific terms.
(2) If you are a California resident, please see the section headed “Additional Privacy Information for California Residents”to view the California specific terms.
If you do not find your region here, plead read this Privacy Policy carefully to learn about our general and universal policies, which we adopted and maintained as a global standard to protect your personal data.
If you do not understand which section applies to your region, please contact us through the methods listed in the “Contact Information” section of this Privacy Policy.
2. Language and Revision to This Privacy Policy
Except as otherwise provided by applicable law or expressly stated in the local language version, in case of any differences or inconsistencies between the English version and the local language version of this Privacy Policy, the English version shall prevail to the greatest extent permitted by applicable law.
Any information that is collected by us in providing the Services is covered by the version of this Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time in accordance with the law. If we make any material changes to this Privacy Policy, we will notify you in advance of such changes by publishing them on our corresponding website(s), sending emails, displaying in-app pop-ups or using other notification methods, and we will update the Last Updated Date above to indicate when such changes become effective. If the changes to be made may materially and adversely affect your rights in any way, we will re-obtain your consent in advance in accordance with the applicable laws.
3. How We Collect and Use Your Information
3.1 Providing You with Document Preview Services
When you use the document preview service through the Xiaomi Document Reader client, we will, for service purposes, collect the following necessary personal information from you:
l While you are connected to the Internet, the file format information you actively upload (including but not limited to Word, Excel, PPT, PDF, and TXT, but not involving document content information), as well as device information (including but not limited to mobile phone system version, device model, device brand, device manufacturer, device resolution, system language, Android ID, and UUID). To facilitate the document preview service, we will, upon obtaining your explicit consent, access your file read/write permission. This permission is a sensitive permission; if you refuse to grant it, your normal use of the document preview function will be affected, but it will not affect your use of other functions that do not require file read/write permission. Even if you consent, you may revoke or change the authorization at any time through the operating system settings on your device.
When you use functions related to the Xiaomi Preview SDK through a third-party developer, we will, for service purposes, collect the following necessary personal information from you or the third-party developer:
l Your device information (including but not limited to mobile phone system version, device model, device brand, device manufacturer, device resolution, system language, Android ID, and UUID).
3.2 Improving Our Products or Services
To ensure your normal use of our services, to understand your usage and compatibility of the Service, and to provide data support for the development of new products/services and the improvement of existing functions/services, we will conduct data analysis through the software information (version number) and device information (including carrier information (MCC, MNC), device identifiers (Android ID, OAID), device model, device type, system version, screen resolution, and screen size) generated during your use of the Service.
We use your information only when we have a valid legal basis. For a better understanding of the legal bases, you may refer to section 12 “Additional Privacy Information for EEA Users”below. For more information on how we share your personal data, please see Section 5 “With Whom We Share Your Information” below.
4. Cookies and Similar Technologies
Information Collected Using Cookies and Other Web Technologies. Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.
（1）“Cookies” are small text files that are placed on your hard drive by a Web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and Web traffic routing on our Services, and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your hard drive on the basis of related arrangement. Please note that this Privacy Policy covers only our use of Cookies but not use of Cookies by such third parties.
（2）“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on Web pages (or in an e-mail).
5. With Whom We Share Your Information
Our Services does not involve the sharing of personal information.
If we subsequently share your information with third parties for service purposes, we shall do so on the premise of complying with the principles of "lawfulness and legitimacy, minimum necessity, and purpose limitation" and obtaining your explicit authorization. Meanwhile, we shall adopt effective technical protection measures for the output format, transfer, and use of such information. At the contractual level, we shall strictly require our partners to fulfill their obligations and responsibilities for the protection of your information, and shall enter into data protection agreements with business partners prior to cooperation.
6. Cross-border Transfer of Information
Since we are a global company, it may be necessary for us to transfer your information to any third party affiliated to us or with whom we have a business or cooperative relationship. We have data centers in locations such as Singapore, France, the United States and India. These locations are selected to enable efficient service operation, enhance performance, and ensure redundancy to safeguard data in the event of an outage or other issues. In the course of using our Services, your information is stored in one or more of the aforementioned data centers taking into consideration factors such as proximity to your region and capacity of local infrastructure. We take appropriate measures to process the data we collect in accordance with the provisions of this privacy policy and the requirements of applicable laws.
Please note that where it is necessary to deliver the services, we will transfer personal data to countries/territories outside your countries/territories. In such cases, an adequacy decision may be absent and such countries/territories may not provide an adequate level of protection to your personal information. However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Policy and applicable laws.
In addition, to the extent that is necessary for maintaining and operating our Services, we may transfer necessary information pertaining to your use of our Services to our affiliates that we entrust with the maintenance and operation of our Services.
If you want to know more about such Cross-border Transfer of Information, please send your e-mail to privacy@wps.com. We will duly handle your response but please note that our Services may not be available to you if you refuse cross-border transfer of information.
7. Your Rights in Relation to Our Use of Your Information
We provide the following rights to protect your information for our global customer:
(1) Right of Access. You have the right to receive information about your personal data processed by us upon request.
(2) Right to Rectification. You have the right to correct or amend your information if it is incorrect, inaccurate or incomplete.
(3) Right to Withdraw Your Consent. You have the right to withdraw consent given to us at any time. As a result, we are no longer allowed to continue the processing based on this consent in the future. This does not affect the legality of the processing carried out on the basis of the consent up to the point of withdrawal.
(4) Right to Erasure. You have the right to obtain from us, under the following conditions, the deletion of your information:
A. the respective processing purpose has been achieved;
B. we have unlawfully processed your information;
C. you have withdrawn your consent without another legal basis applying to the data processing;
D. you have successfully objected to the data processing;
E. in cases where there is an obligation to delete information on the basis of EU law or the law of an EU member state to which we are subject.
If you have any questions or require any further assistance, please contact us by privacy@wps.com.
You can exercise your right to access, update and delete your information:
in the settings of your Apps or other Products, or
you could contact us at privacy@wps.com and we will assist you to exercise your right.
We may provide other rights for residents of some countries/territories subject to the locally applicable data protection law. Please refer to the region-specific sections below for more information regarding your rights in EEA and California regions.
We respect and take necessary measures to protect your information no matter where you live.
If you have any questions about these rights or you would like exercise any of them, please contact us by sending an email to privacy@wps.com. Additional details of how to get in touch are set out below. In addition, if you are not satisfied with the responses you receive, you may file a complaint with a data protection authority on our collecting and processing of your information. Please see this directory for more details with regard to the local data protection authorities.
8. The Security and Storage of Your Information
We take all reasonable administrative, physical and electronic measures to protect the information that we collect from or about you from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss. We work hard to protect you and WPS from unauthorized access, alteration, disclosure, or destruction of information we hold, including: (i) we use encryption to keep your data private while in transit; (ii) we restrict access to personal data to WPS employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. However, please note that no transmission over the Internet is completely secure or error-free, and that the information security policies, rules and technical measures utilized and maintained by us may be subject to compromise.
When you use our Services on your computing and mobile devices (“Devices”), such as by using one of our downloadable applications, some of your data will be stored locally on such Devices.
We have data centers in locations such as Singapore, France, the United States and India. These locations are selected to enable efficient service operation, enhance performance, and ensure redundancy to safeguard data in the event of an outage or other issues. In the course of using our Services, your information is stored in one or more of the aforementioned data centers taking into consideration factors such as proximity to your region and capacity of local infrastructure. We take appropriate measures to process the data we collect in accordance with the provisions of this privacy policy and the requirements of applicable laws.
9. How Long We Retain Your Information
We will retain your information for the period strictly necessary for fulfilling the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We will cease to retain your information once the corresponding retention period has elapsed, the purpose of processing is fulfilled, or after we terminate the operation of the relevant services, save as otherwise required or permitted by applicable laws and regulations.
10. Our Policy Towards Minors
To protect minors’ privacy and personal data security, we provide specific protection with regard to minors’ personal data. Our Services are not directed towards minors under the age of 16 （or other minimum age otherwise provided by the related jurisdictions） and we do not knowingly collect, store, share or use personal data from minors. If you are a minor under 16（or other minimum age otherwise provided by the related jurisdictions）, you are not permitted to use and install our products, unless your parent or legal guardian provides verifiable consent. If we learn that we have collected personal data of a minor under 16, unless we have first obtained verifiable, explicit parental permission for collecting personal data of such minor, we will take steps to delete such information as soon as we can.
11. Links to Other Sites
Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.
12. Additional Privacy Information for EEA Users
In this section, we provide additional information to European Economic Area (EEA) users, as required under EU privacy laws, including the General Data Protection Regulation (“GDPR”).
(1) Legal Basis of Processing Information
We process information if one of the following applies:
A. Necessary for entry into, or performance of, any contract(s) with you (Art 6(1)(b) of the GDPR).
B. Necessary for the legitimate interests of us, where these are not overridden by your interests or fundamental rights and freedoms (Art 6(1)(f) of the GDPR). Our legitimate interests include enabling us to more effectively manage and operate our business and provide our products and services; protecting the security of our businesses, systems, products, services; internal management; and complying with internal policies and processes.
C. Necessary for compliance with a legal obligation to which we are subject (Art 6(1)(c) of the GDPR).
D. Necessary in order to protect the vital interets of a natural person (Art 6(1)(d) of the GDPR).
E. Necessary for the performance of a task carried out in the public interest or in the exercise of official authority vetsed in us (Art 6(1)(e) of the GDPR).
F. In limited circumstances and to the extent the legal bases for processing set out above do not apply, processed with your consent (Art 6(1)(a) of the GDPR).
(2) Cross-border Transfer of Information
If you are based within EEA, please note that where necessary to deliver the services, we will transfer personal data to countries/territories outside the EEA. Countries/territories outside the EEA may not provide an adequate level of protection to your personal data. Where such is the case, we will take appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Policy. The safeguard we primarily rely upon is the European Commission-approved standard contractual data protection clauses.
(3) GDPR Rights
In general, EEA users have the following rights with respect to their personal data in addition to the rights mentioned in Section 7 “Your Rights in relation to Our Use of Your Information”:
A. Right to Object. You have the right to object to the processing of your information. If you object, we will no longer process your information unless we can prove compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims on our part.
B. Right to Restriction of Processing. You have the right to request us to process your information only to a restricted extent under the following conditions:
1) the accuracy of your information is contested;
2) you request limited processing instead of deletion under the conditions of a justified right of erasure;
3) the data is no longer required for the purposes pursued by us, but you need the information to assert, exercise or defend legal claims; or
4) the success of an objection is still disputed.
C. Right to Data Portability. You have the right to receive from us information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, as well as the right to request us to forward this information to another controller under the following conditions:
1) the processing is based on consent or the contract; or
2) the processing is carried out by automated means.
13. Additional Privacy Information for California Residents
In this section, we provide additional information to California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”). This section does not apply to publicly available information lawfully made available by state or federal government records, de-identified information, aggregate consumer information, or other personal data that is exempt under the CCPA (such as information covered by the Health Insurance Portability and Accountability Act).
While our collection, use and disclosure of personal data varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected，shared and disclosed (for business purposes) personal data about California residents in the prior 12 months (from the Last Updated date above), and the rights California residents have under the CCPA regarding this personal data.
CCPA Rights and CPRA Rights
In general, California residents have the following rights with respect to their personal data:
Do-not-sell-or-share (opt-out): to opt-out of our sale or sharing of their personal data.
Right of deletion: to request deletion of their personal data that we have collected about them and to have such personal data deleted, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies.
Right to know: with respect to the personal data we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
A. categories of personal data collected
B. categories of sources of personal data
C. categories of personal data about them we have disclosed for a business purpose or sold
D. categories of third parties to whom we have sold or disclosed for a business purpose their personal data
E. the business or commercial purposes for collecting or selling their personal data
F. a copy of the specific pieces of personal data we have collected about them
Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Right to correct: the right to correct inaccurate personal data about you collected by us.
Right to limit: the right to limit the use and disclosure of sensitive personal data about you collected by us.
Right of No Retaliation Following Opt Out or Exercise of Other Rights: we shall not discriminate a customer (e.g. denying goods/services, charging different prices. providing different level or quality of goods or services) because such a customer exercise any of the rights above.
Submitting CCPA/CPRA Requests
California residents may submit CCPA/CPRA requests to exercise your lawful rights listed above to privacy@wps.com.
When you submit a CCPA/CPRA request, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must provide your name and contact information to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us by email; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
As this section is mainly to provide your with additional information under the CCPA/CPRA, for general information on what information about you is being collected and how we use, process, share or transfer them, please refer to sections above.
Please note that we did not sell your personal information in the preceding 12 months. For more information on how we shared and/or disclosed for a business purpose your information in the preceding 12 months, please refer to Section 5 “With Whom We Share Your Information” above.
14. Contact Us
If you have any questions, concerns complaints regarding our processing of your personal data, please contact us at your convenience through the following ways:
Data Controller: WPS Software Pte. Ltd.
E-mail: privacy@wps.com
Address: 6 RAFFLES QUAY #14-06 SINGAPORE(048580)
EU Representative: Kingsoft Office Software International Limited
E-mail: privacy@wps.com
Address: Trinity House, Charleston Road, Ranelagh, Dublin
Data Protection Officer
Email: wpsdpo@linkstraits.com
Address: #10-01, 10F, Parkview Square, 600 North Bridge Rd, Singapore 737919