Privacy Policy

Effective Date: 1/8/2024

Introduction

Beautiful Interaction International Co., Limited (hereinafter referred as “Beautiful Interaction” or “the Company” or “We”) is aware of the importance of user information protection, and will do our best to protect user information security, we will take security measures in accordance with the laws to protect user information and privacy security, and will abide by the following principles: the principle of balance of rights and obligations, the principle of clarity of purpose, the principle of independent choice, the principle of reasonableness and necessary, the principle of security, the principle of participation, and the principle of openness and transparency, etc.

We collect, store, use, share, transfer, disclose and protect information about our users when they use products or services related to Beautiful Interaction in accordance with the Privacy Policy. We would like to inform users the way we handle user information through the Privacy Policy. In this respect, we would like to remind users to read carefully the Privacy Policy when browsing the information or enjoying the services related to this website, and to use the related products and services only after confirming that they fully understand and agree to it. The provisions of the Privacy Policy that are (may be) significant to your rights and interests are in bold underlining in order that you should pay particular attention. After you check the box “have read and agreed to the User Registration Agreement and Privacy Policy” and click register now, you are deemed to have fully understood and agreed to all the contents of the Privacy Policy, which will take effect at the same time when you register successfully. The Privacy Policy will be updated from time to time. Your use or continued use of the products or services that we provide shall constitute your full understanding and agreement to the entire contents of the Privacy Policy (including updated versions).

Definition

1.1 Beautiful Interaction products or services refer to the Mixdesk software products and ancillary services subscribed by users from Beautiful Interaction and its related parties, and the products, promotions and marketing services provided only once or multiple times through other feasible methods such as webpage, email, public account, SMS, telephone call and etc..

1.2 Affiliated party means a company, organization or individual that has any connection to Beautiful Interaction through a relationship of partnership, investment or control (or joint control).

1.3 Third party means any other company, organization or individual who are not Affiliated party in the Privacy Policy.

Table of Contents

The Privacy Policy will help users understand the following:

Main Body

I. Scope of Application of the Privacy Policy

1.1 The Privacy Policy applies to the collection, storage, analysis, transmission, use, processing, transfer, backup, deletion, and protection of user information in the course of the sale of products and the provision of services by Beautiful Interaction and its affiliated parties. If the information is unable to identify the real identity of the user alone or in combination with other information or reflect the activities of a specific user, it is not personal information in the legal meaning.

II. Scope and Manner of Collection of User Information

2.1 When the user registers on the Beautiful Interaction website (www.mixdesk.com) and enjoys the relevant services, the user understands and agrees that we may collect, store and use the data relating to the user information (the “User Information”) as set out in the following clause 2 and clause 3, and if the user does not provide or agree to our collection of the relevant User Information, they may not be able to become our user or subscribe to our products and enjoy certain services provided by us or achieve the intended results of the relevant services:

2.1.1 Personal data information filled in and/or provided by the user, including: name/title, mobile number, email address, address (not accurate address), and information from questionnaires related to the provision of services to the user, etc., that can identify the user’s identity, either alone or in combination with other information.

2.1.2 Information obtained under different terminals: When the user grants specific privileges in software installation and use, Beautiful Interaction will receive and record information relating to the device or application used by the user (e.g., hardware and software characteristics such as device name, operating system, browser and version, device type, unique device identifier, etc.), information related to the location of the device (e.g., sensor information such as IP address, GPS location, etc.), information obtained under different terminals (e.g., Openid, user’s nickname, user’s avatar, etc.). Beautiful Interaction may correlate the above information in order to provide consistent services to users on different devices.

2.1.3 Log information: When the user uses the relevant services, Beautiful Interaction will automatically collect information relating to the use of Beautiful Interaction’s services by users and save them as relevant web logs. For example: user’s IP address, browsed information, records of website accessed, clicking information, language used, date and time of accessing the service, cookies, Web Beacon and so on.

2.1.4 Mobile analytics data stored in certain mobile applications, Beautiful Interaction uses mobile analytics software, which may record information such as how often a user uses the application, events that occur within the application, cumulative usage, performance data, and where application crashes occur. Because Beautiful Interaction and third-party service providers use technologies such as cookies, tags, and scripts, these technologies are used to analyze trends, administer the site, track users’ site activity, and gather statistical information about the entire group of users. Beautiful Interaction receives individual or aggregated analytics collected through the above technologies.

2.1.5 Supportive information of users’ accounts: Based on the consultation records, trouble report records, and troubleshooting process for the user’s faults (e.g., communication or call records) generated as a result of the use of the Beautiful Interaction’s services by users, Beautiful Interaction will record and analyze those information in order to respond to the user’s request for assistance in a more timely manner and to improve the services.

2.1.6 Information of users obtained from third parties: Beautiful Interaction may obtain relevant information on users from third parties through proper channels, and use the information of users obtained from third parties in compliance with relevant laws and regulations.

2.1.7 Transaction and Payment Information: In order to help you successfully complete the transaction and protect your transaction security, when you place an order for a transaction or for the purpose of completing a transaction, Beautiful Interaction may collect information such as your traded goods/services information, order number, time of placing the order, amount of the transaction, method of payment, and third-party payment account number (Alipay, UnionPay account number, Stripe, and other relevant account), and other information.

2.1.8 Information exempted from obtaining consent to collect and use in accordance with the laws: including those directly related to national security, national defense security, public safety, public health, public interest; disclosure or provision of the information where necessary according to the mandatory requirements of the relevant laws and regulations, or directly related to the investigation of a crime, prosecution, trial and execution of the judgment, etc.; in order to safeguard the life, properties or other legitimate rights and interests of Beautiful Interaction’s other customers, companies and its affiliated parties, or where necessary to safeguard the safety of the products or services; disclosed to the public by the users themselves, or User Information collected by Beautiful Interaction from lawful public disclosure of information, such as lawful news reports, governmental disclosure of information and other channels; where necessary for the signing or fulfillment of a contract based on the user’s request; where necessary for academic research institutions to carry out statistical or scholarly research based on the public interest, and when the results of academic research or description are provided to the public, User Information contained in the results will be de-identified; and in other cases stipulated by laws and regulations.

2.2 The above scope of User Information is not necessarily the content of User Information that will be collected by Beautiful Interaction, the Company will collect the necessary information within the scope of the above User Information that is relevant to the provision of services to the users according to the content of the services selected by the users.

III. Use of Cookies and Similar Technologies

3.1 The user understands and agrees that when the user registers on the official website of Beautiful Interaction and enjoys the relevant services provided by Beautiful Interaction, in order to enable Beautiful Interaction to better provide services to the user, we may use relevant technologies to collect and store User Information (including User Information collected from time to time through the following cookies), and in the process one or more cookies or anonymous identifiers may be sent to the user’s computer or mobile device and User Information may be collected from time to time through relevant cookie; cookies or anonymous identifiers usually contain identifiers, the name of the site and some numbers and characters. Cookie technology enables websites to store data such as user browsing history (including User Information or personal information).

3.2 Many web browsers have a Do Not Track function which allows Do Not Track requests to be issued to websites. If a user’s browser has Do Not Track enabled or chooses not to use cookie, then we will respect the user’s choice, but you may not be able to log in or use services or functions that rely on cookies.

3.4 We will not use cookie and similar technologies for any purpose other than those set out in the Privacy Policy, or share, transfer or disclose User Information obtained through cookie and similar technologies to parties other than those set out in the Privacy Policy, and users can retain or delete cookie according to their preferences, and they can also erase all cookies saved in their web pages.

IV. Storage of User Information

4.1 In the absence of a request for modification or deletion by the user, we will take reasonable and practicable security measures that comply with industrial standards to effectively store the User Information.

4.2 Storage Period: We will retain User Information for the period as necessary to fulfill the purposes set forth in this Policy, except as otherwise provided by laws or regulations. We judge the storage period of User Information based on the following criteria:

4.2.1 Fulfillment of the purpose of transactions related to the user, maintenance of corresponding transactions and business records in order to respond to possible inquiries or complaints from the user;

4.2.2 Ensure the safety and quality of the services we provide to our users;

4.2.3 Whether the user agrees to a longer retention period;

4.2.4 The existence of other special agreements or provisions of laws and regulations concerning the retention period.

4.3 After the retention period has elapsed, we may delete or anonymize your personal User Information as required by applicable laws.

V. Purpose of Using User Information

5.1 For the purpose of providing services related to Beautiful Interaction, we will use the collected User Information in accordance with the Privacy Policy and the License Agreement. For any other purposes other than the abovementioned ones, we will obtain the consent of the users in advance. Specifically, we will use the collected User Information for the following purposes:

5.1.1 In order to provide the services to you (including, but not limited to direct promotions promoted by us or our affiliated parties to users), Beautiful Interaction and its affiliated parties may send you information, notices, or engage in business communications with you, including, but not limited to verification codes that are necessary to ensure completion of the services, push notifications that are necessary to use the services.

5.1.2 We may design, develop and promote new products and services (including, but not limited to, product advertisements, user profiles and statistics) based on statistical data of User Information.

5.1.3 In order to improve the security of your use of the services provided by Beautiful Interaction and its affiliated parties, to ensure the safety of the operating environment and to identify abnormal account status, to protect you or other users or the public from infringement of personal and property safety, to better prevent phishing websites, fraud, network vulnerabilities, computer viruses, cyber-attacks, cyber-intrusion, and other security risks, and to more accurately identify the violation of law, regulations or Beautiful Interaction’s related agreements and rules, we may use your User Information or membership information, and integrate device information, relevant network logs, and information legally shared by our affiliated parties to determine the risk of your account and transactions, to perform the authentication, detection and prevention of security events, and to take the necessary measures of recording, auditing, analyzing, and disposing of them in accordance with the laws.

5.2 After we have de-identified the User Information by technical means (in order to reduce the risk of other organizations or individuals being able to identify the user by means of de-identified personal information, we will take appropriate management measures to store the de-identified data separately from the information that can be used to recover the identification of the user). The user agrees and is aware that in this case we have the right to use the de-identified information and that we have the right to analyze and commercially use the de-identified information of the user without disclosing the User Information.

5.3 The user knows and agrees that, unless the user sends a notice of modification or deletion to Beautiful Interaction and the processing is completed by Beautiful Interaction, using the relevant services of Beautiful Interaction by users will constitute continuing authorization on us to use all the User Information during the user’s use of the relevant services of Beautiful Interaction to the extent that it is consistent with the Privacy Policy.

5.4 The user understands and agrees that we may carry out a statistical survey on the use of our services by users and may share such statistics with third parties to show the overall trend of the use of our relevant services. However, these statistics will not contain any User Information.

VI. Sharing, Transfer and Disclosure of User Information

6.1 In order to fulfill the relevant purposes stated in the Privacy Policy, some of our services will be provided to users by third parties. In order to facilitate the users’ enjoyment of such services, we may provide, transfer or use User Information (or part of User Information) to third parties in accordance with the principles of lawfulness, legitimacy, necessity, specificity and clear-out goals in order to assist third parties located in Hong Kong or in a country or region outside Hong Kong to provide services to the users, and the third parties will only have access to the User Information necessary for the fulfillment of their duties.

6.2 We will carry out reasonable investigations into the data security capabilities of third parties and require third parties to take such confidentiality and security measures as are necessary to store, use and process the User Information that we provide or transfer to them, to ensure that the relevant User Information is not disclosed and that the relevant User Information is not kept longer than is reasonably necessary for the processing of the data.

6.3 As we continue to develop our business, we may enter into mergers, acquisitions, equity transfers, asset transfers, business transfers or similar transactions, and we may experience a change of control or shareholding, and User Information may be transferred to our affiliated parties located in Hong Kong or in a country or region outside of Hong Kong as part of such a transaction, without the need for further consent or written consent from the user. In the event of such a change, we will require the new controller of User Information to continue to protect User Information in accordance with laws and regulations and with security standards no less stringent than those required by the Privacy Policy.

6.4 We may provide, share or transfer User Information to affiliated parties located in Hong Kong or in countries or regions outside of Hong Kong in the ordinary course of our business, but we will not provide, share or transfer User Information to any third party other than affiliated parties of Beautiful Interaction, except under the following circumstances:

6.4.1 Prior express authorization or consent of the user;

6.4.2 Shared by users themselves to third parties;

6.4.3 Relating directly to national security, national defense security, public safety, public health, and public interest;

6.4.4 Disclosure or provision is necessary in accordance with the mandatory requirements of relevant laws and regulations, or is directly related to the investigation of a crime, prosecution, trial, and execution of a judgment. Subject to laws and regulations, when we receive a request for disclosure of the aforementioned information, we will require that the other party must produce legal documents corresponding to the request, such as a subpoena or letter of inquiry, and we will carefully review all requests to ensure that they have a legal basis;

6.4.5 Within the scope permitted by laws and regulations, where necessary to safeguard the life, property and other legitimate rights and interests of other users of Beautiful Interaction, the Company and its affiliated Parties, or to maintain the safety of the products or services, such as finding, preventing, and dealing with illegal activities such as fraud and reducing credit risk;

6.4.6 User Information collected from lawful public disclosures, such as lawful news reports, government disclosures, and other sources;

6.4.7 Necessary for the conclusion and performance of a contract to which the user is a party, or for the implementation of human resources management in accordance with labor regulations established by laws and collective contracts concluded in accordance with the laws;

6.4.8 When an academic research institution carries out statistical or academic research necessary in the public interest and when provides the results of academic research or description to the public, it de-identifies the information contained in the results;

6.4.9 During the due diligence review of a proposed commercial transaction under the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong);

6.4.10 Other cases stipulated by laws and regulations.

6.5 The user agrees that we may use the User Information to carry out direct promotions of Beautiful Interaction and/or our affiliates’ to the user from time to time, and if the user does not agree to the aforesaid arrangements, the user may email Beautiful Interaction (E-mail: support@mixdesk.com) and clearly inform the their dissenting decision, and we will cancel and record the user’s option of disagreement, and subsequently terminate the use of the User Information for direct promotional activities of Beautiful Interaction and/or our affiliated parties to the user.

VII. User Information Security Protection

7.1 We attach great importance to the security of User Information and will endeavor to take a variety of reasonable security measures (in terms of both technology and management) in accordance with industrial standards to protect User Information, to prevent improper use or unauthorized access, public disclosure, use, modification, damage, loss or leakage of User Information provided by users.

7.2 We use encryption technology, anonymization, and other reasonably practicable means to protect User Information and use trusted protection mechanisms to prevent malicious attacks on User Information.

7.3 We will establish a specialized information security working group, a security management system, and data security processes to safeguard User Information. We adopt a strict data use and access system to ensure that only authorized personnel have access to User Information, and conduct security audits of data and technology at appropriate times.

7.4 Although we have taken reasonable and effective measures as described above and have complied with the standards required by the relevant legal provisions, users are requested to understand that, due to technological limitations and the possible existence of a variety of malicious means, in the internet industry, even if every effort is made to strengthen the security measures, it is not always possible to completely guarantee the absolute security of the User Information, but we will do our best to ensure that the information that the user provides with us is safe.The user is aware of and understands that the systems and communication networks used by the user to access our services may experience problems which is beyond our control, and the user shall understand and accept that we shall not be liable to pay any compensation and/or indemnification of any kind for any loss and/or damage incurred or caused to the customer as a result of the aforementioned risks, which are beyond our control. Therefore, we strongly recommend that the user take active measures to protect the security of information.

7.5 We will formulate an emergency response plan and immediately activate the emergency response plan in the event of a User Information security incident in an effort to prevent the impact and consequences of any security incident from expanding. Once a User information security incident (leakage, loss, etc.) has occurred, we will, in accordance with laws and regulations, promptly inform the user of: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions that the user can take on his own to prevent and minimize the risk, and the remedial measures for the user. We will promptly inform users of the incident-related situation in the form of pushing notifications, emails, letters, SMS, etc. When it is difficult to inform them one by one, we will take reasonable and effective ways to publish announcements. At the same time, we will also report the disposition of User Information security incidents in accordance with the requirements of the relevant regulatory authorities.

7.6 We would like to remind users in particular that the information protection measures provided in the Privacy Policy are only applicable to the products or services provided by Beautiful Interaction and its affiliated parties. We do not have the ability and obligation to protect any information submitted by users in applications or websites other than those related to the services provided by Beautiful Interaction, regardless of whether the users’ login or browsing of the abovementioned software, websites or platforms is based on the links or guidance provided by Beautiful Interaction or not, and we shall not be held legally liable for the same.

VIII. Management of User Information

8.1 We attach great importance to the management of User Information and make every effort to protect the user’s right to access, modify (update or correct), supplement, delete, change the scope of authorization and revoke the authorization of User Information.

8.2 If the user needs to access, modify (update or correct), supplement, delete, change the scope of authorization and withdraw the authorization of the User Information, users can use the service mailbox (support@mixdesk.com) provided by us or office address to get in touch with our personal data officers, submit the relevant application to us, and we will provide users with access, modification, deletion and termination of authorization and other services according to the user’s needs after verification of the user’s identity.

8.3 If the user applies for deletion of information and terminates the authorization for us to provide relevant services to the user, we will delete the relevant information in our system and no longer provide relevant services to the user. At the same time, the user’s decision to terminate the authorization does not affect our previous information processing based on the user’s authorization. After the user or we assist the user in deleting the relevant information, we may not be able to immediately delete the corresponding information from the backup system because of limitations of applicable laws and security technologies, and we will securely store the user’s personal information and restrict any further processing thereof until the backup can be erased or anonymized.

8.4 We may not be able to respond to a user’s request in accordance with laws and regulations if the User Information falls under one of the following circumstances:

8.4.1 Relating to national security and national defense security;

8.4.2 Relating to public safety, public health, significant public interest, etc;

8.4.3 in connection with the investigation for crimes, prosecution, trial and enforcement of sentences;

8.4.4 If there is sufficient evidence of subjective malice or abuse of rights on the part of the user;

8.4.5 Responding to the user’s request will result in serious damage to the legitimate rights and interests of the user or other individuals or organizations;

8.4.6 Where trade secrets are involved;

8.4.7 Other cases stipulated by laws and regulations.

IX. Terms of Use for Minors

9.1 If the user is a minor under the age of 18, before using the products or services related to Beautiful Interaction, he/she should read the Privacy Policy together and under the supervision and guidance of his/her legal guardian and use the products or services related to Beautiful Interaction with his/her guardian’s consent. We protect the personal information of minors in accordance with relevant or applicable state laws and regulations, and will only collect, use, store, share, transfer or disclose the personal information of minors as permitted by law, with the express consent of the parents or other guardians, or as necessary for the protection of children.

9.2 The user and the user’s guardian shall be responsible for the truthfulness of the information provided by the user, and if we are unable to determine that the user is a minor from the information provided by the user, then we shall not be responsible for the protection of the privacy of minors.

X. Effectiveness and Changes to the Privacy Policy

10.1 In order to provide users with better services, services related to Beautiful Interaction will be updated and changed from time to time, we may revise the Privacy Policy from time to time, and such revisions form part of the Privacy Policy and have the same effect as the Privacy Policy. However, in principle, we will not reduce the rights of users under the Privacy Policy currently in effect.

10.2 When the Privacy Policy is updated, we will explain the specific changes to the Privacy Policy by means of a public announcement or other appropriate means, so that users can keep up to date with of the latest version of the Privacy Policy, and users understand and agree that we do not need to give users any individual notification, and that updates to the relevant Privacy Policy will take effect immediately without obtaining the users’ written consent or further consent. If you do not agree with the modified part, you should contact us immediately and stop using the service. If you continue to use the services provided by the Company, you are deemed to have agreed to and accepted the modified part.

XI. Application of law and Settlement of Disputes

11.1 The formation, effectiveness, performance and interpretation of this Agreement shall be governed by the laws of Hong Kong and, in the absence of express provisions in the laws, by prevailing industry practices.

11.2 In the course of the performance of this Agreement, if any dispute arises between the parties, the parties shall resolve it by negotiation, including lodging a complaint with the data protection authority. In the event that negotiation fails, both parties may sue in the Hong Kong courts, which shall have non-exclusive jurisdiction.

XII. Others

12.1 The headings in the Privacy Policy are for convenience only and do not affect the meaning or interpretation of any provision of the Privacy Policy.

12.2 If users have any comments or suggestions on the Privacy Policy or its functions relating to the collection, preservation, use, sharing, disclosure and protection of User Information, users may provide feedback or complaints through the Beautiful Interaction feedback channel. We will provide feedback to users as soon as possible after receiving their comments and suggestions.

12.3 We have set up a special feedback channel for information protection, and users can contact us in the following ways: Service Email: support@mixdesk.com; Office Address: UNIT B,13/F,SHING LEE COMMERCIAL BUILDING,NO.8 WING KUT STREET CENTRAL HONG KONG.

12.4 The copyright of the Privacy Policy is owned by Beautiful Interaction and the Company reserves the right of final interpretation and modification to the extent permitted by law.