1905 GO Privacy Policy

Last Updated:

This Privacy Policy provided by 1905 (Beijing) Network Technology Co., Ltd. (the “Company”), located at 3F, Building F, Huayuan Enterprise, No.5 Beizhan North Street, Xicheng District, Beijing, China, 100044.

We are committed to preserving your privacy and safeguarding your sensitive information. We conduct our business in compliance with the People's Republic of China Network Security Law and have implemented additional measures to protect your personal information.

This Privacy Policy aims to help you understand how we collect, use, disclose and process your personal information, and the following statements describe our general information-gathering and usage practices.

This Privacy Policy should be read together with the Terms of Use. Unless otherwise defined, terms used herein shall have the same meaning as defined in the Terms of Use, as posted on the Company’s website, via the 1905 G

1. Consent to collection, usage, disclosure and/or processing

By continuing to use our services, and/or purchasing, receiving or retaining 1905 GO membership or any part thereof, after the effective date of this Privacy Policy (as set out above), you are deemed to have agreed and consented to allow the Company and its affiliates and related corporations (collectively, the "Group") to:

1.1. collect, use, disclose and/or process Customer Information about you that you had previously provided to the Group, that you now provide to the Group and/or that you may in future provide to the Group for the purposes set out below; and

1.2. disclose information about you to third party service providers that are engaged by the Group to perform certain functions in connection with the purposes set out below, so long as disclosure is necessary to enable such third party service providers to perform such functions. The third party service providers as referred to in paragraph 1.2 above may be located within or outside China. In this regard, by continuing to use our services and/or purchasing, receiving or retaining 1905 GO membership after the effective date of this Privacy Policy (as set out above), you are deemed to have agreed and consented that such third party service providers may, to the extent necessary to perform the said functions, collect, use, disclose and/or process information about you. The terms "we", "our" and "us" refer to the Group.

2. The ways through which we collect your personal information

We may collect your personal information when you:

2.1. subscribe to our services;

2.2. open a 1905 GO Account;

2.3. use the 1905 GO App and other related products or services;

2.4. purchase, receive or retain 1905 GO membership;

2.5. sign up for alerts or newsletters;

2.6. contact us with a question or request for assistance;

2.7. visit our website, including but not limited to information collected in relation to cookies, pixel tags, Flash cookies or other local storage stored on your computer or other devices (if applicable).

3. The information that we collect

The information that we collect depends on the products and services that you use and/or subscribe to. Here are some key examples:

3.1. your Customer Information: this includes your name, email address, and telephone number, as well as service-related information such as bank and credit card details, your 1905 GO-approved devices identification and IP address;

3.2. your interaction with us: emails or letters you send to us or other records of any contact you have with us;

3.3. your 1905 GO Account information: your Credentials, and the subscription services you use or other details related to your 1905 GO Account;

3.4. information on your use of our services: feedback on the 1905 GO App and the degree of seamlessness that you enjoy when you use the 1905 GO App;

3.5. your preferences: this is based on what you share with us on how you would like to be contacted, and your preferred products and services; and

3.6. information from other organizations: these organizations include fraud-prevention agencies, business directories, credit reference agencies or individuals we believe you have authorized to provide your personal details on your behalf.

4. How we use, disclose and/or process your information

We may use, disclose and/or process your information for:

4.1. the provisioning and administration of services, so as to enable us to:

4.1.1. open a 1905 GO Account for you;

4.1.2. process your orders and activate or deactivate our services;

4.1.3. offer rewards and promotions, and share promotional benefits and loyalty programs which you may qualify for;

4.1.4. provide updates, offers, invitations to events and deliver relevant targeted advertising, including through email, voice and SMS (or other text messaging platforms) with your prior consent or if otherwise permitted under local laws and regulations.

4.1.5. enable us to process bills and payments;

4.1.6. respond to enquiries and requests from you or people you have authorized;

4.1.7. inform you about service upgrades and updates; and

4.1.8. provide directory assistance in relation to the 1905 GO App;

4.2. market research, network and service enhancement, so as to enable us to:

4.2.1. conduct market research and customer satisfaction surveys to improve our customer service; develop new products, as well as personalize the services we offer you; and

4.2.2. perform market analysis;

4.3. audit, accounting or legal compliance, credit checks and solvency purposes;

4.4. any takeover, amalgamation, merger, or acquisition of the Company, whether potential or not;

4.5. circumstances where the personal information is anonymised and aggregated before being shared, such that the information is devoid of any personally identifiable features;

4.6. the mitigation of certain security risks, and in that regard:

4.6.1. inform you of service and security issues;

4.6.2. prevent and detect fraud or other crimes and recover debts;

4.6.3. conduct internal audits;

4.6.4. ensure the safety and security of our properties and systems; and

4.6.5. conduct checks for AML, CFT and related risks; and

4.7. meeting legal, regulatory and other requirements, complying with the Applicable Laws of the People's Republic of China and any other relevant jurisdiction including but not limited to those related to AML and CFT, and providing assistance to law enforcement, judicial and other government agencies.

5. Sharing your information with third party service providers

We may share your information with third party service providers to perform certain functions in connection with the purposes set out in this Privacy Policy, including but not limited to:

5.1. business partners and vendors we work with to deliver services you have subscribed to;

5.2. compliance service providers for verification purposes;

5.3. financial institutions for purposes such as facilitating payments (if applicable);

5.4. service providers providing administrative and/or infrastructural support for our services; and

5.5. marketing companies for market analysis purposes (if applicable).

Your information is disclosed to the above only for relevant purposes set out above or in the interest of our customers

The third party service providers may or may not be based in jurisdictions outside of the People's Republic of China. We will use our best endeavours to ensure that third party service providers we work with observe strict confidentiality and data protection obligations consistent with this Privacy Policy and will be protected at a standard that is at least comparable to that under the Personal Data Protection of the People's Republic of China.

6. Retention of your personal information

6.1. We will retain your personal information for as long as necessary to fulfil the purposes set out in this Privacy Policy. However, we will retain your information for a longer period where required by law and for the duration of any statutory limitation period for claims.

7. General Information and questions

7.1. Should you have any questions, please feel free to contact us at go@1905.com.

7.2. We may amend or modify this Policy from time to time. The revised Privacy Policy will be posted on our website, via the 1905 GO App or any other form or manner deemed to be appropriate by the Company.