Bytello Account Privacy
Policy
Last updated:
June 14, 2022
Thank you for
registering Bytello Account! Bytello Account is a single sign-on
authentication scheme for customer identity and access management, whereby you may log in to all products
and services that support Bytello Account (hereinafter referred to as “Bytello-related products or
services”), including but not limited to Bytello Class, Bytello OS, Bytello DMS. We may collect and use your personal data when you register or log in to the
Bytello Account. The personal data you assented to provide is used by the data controller, Guangzhou Shirui
Electronic Technology Co., Ltd. (hereinafter referred to as “Shirui” or “We”), domiciled in Building 5, No.
192 Kezhu Road, Economic and Technological Development Zone, Guangzhou, China, for the sake of providing
quality single sign-on authentication services. Personal data refers to any information
relating to an identified or identifiable natural person.
In this Privacy
Policy, we will explain to you about the purposes, method and scope of the collection and use of your
personal data by us,
your rights to your personal data, and the security measures we take to protect your
information.
Before using our
Bytello Account, please read this Privacy Policy carefully to learn our practices to
protect customer’s personal data. If you do not agree with the terms of this Privacy Policy, you can
cease to register Bytello Account by clicking “Disagree” and we will not be able to provide you with
Bytello-related products or services. If you click “Agree” to continue the registration thereof, it
means that you fully and clearly understand the following terms regarding information collection and
usage, your rights to your personal data, etc. Please note that each Bytello-related product or service
has a standalone privacy policy, which describes the purpose, method and scope of the collection and use
of your personal data thereby, and shall be consented separately prior to your use of such product or
service. If there is a conflict between this Privacy
Policy and such standalone privacy policy, the
latter will take precedence with respect to your use of or access to the specific Bytello-related
product or service.
This Privacy Policy will help you understand the following:
I. How We Collect and Use Your Personal
Data
II. How We Use Cookies and Similar
Technologies
III. How We Retain Your Personal
Data
IV. How We Share, Transfer or Publicly Disclose
Your Personal Data
V. How We Protect Your Personal
Data
VI. Your Rights to Your Personal
Data
VII. How We Process Children's Personal
Data
VIII. Third-party Service Providers and Their
Services
IX. How Your Personal Data is Transferred
Globally
I. How We Collect and Use Your Personal
Data
We collect personal data for more efficient operation and to provide you with
best usage experience. Our channels to collect personal data include: (1) information directly provided by
you to us; (2) information we obtain when you log in to the Bytello Account; and/or (3) information we
obtain from third parties.
The information we collect depends on the feature
you actually use, the environment in which you interact with us, the choices you
make.
（1） To provide you with single sign-on account registration
and login functions, we may collect your email address, password, in order to register your account and
assist you in logging in and using the Bytello-related products or services. We may also collect your
country/region information, in order to ascertain where we would retain your personal data. We may collect
your date of birth for the sake of age screen to offer more protection for children. If you do not provide
the above-mentioned information, we will not be able to provide you with the account registration and login
services. When you have registered for your account, you can choose whether or not to provide us with
information such as your user name, profile photo, etc. to further complete your
account profile.
With your Bytello Account, you may log in to
Bytello-related products or services, our affiliates or third parties that support Bytello Account,
including but not limited to Bytello Class, Bytello OS, Bytello DMS, etc., without re-registration for
another account.
（2） If the relevant laws and regulations in the country
where you register the Bytello account have real-name authentication requirement, we will also collect your
real-name authentication information, such as your name, ID number, etc. If you refuse to provide such
information, we may not be able to provide you with the corresponding account registration
services.
（3） When you use the third-party cloud storage service
though Bytello dashboard, we may collect your Google/Microsoft account information, including your
registered email address, profile photo, user name, email verification information, for the sake of
user identity verification. In no event shall we access or store
your cloud storage resources unless at your command.
（4） For the sake of device management, we may collect
information about your device including device name, device model, IMEI number, mobile phone model, Mac
address, serial number, IP address, operating system version, and other device information.
（5） To ensure the normal operation of the Bytello Account
and to improve and optimize your service experience, we may collect how you interact with Bytello dashboard,
i.e., time and duration of your log-in, click-on, etc.
（6） When you use certain features in Bytello-related
products or services, i.e., editing and synchronizing coursework and courseware work products cross
multiple devices, in order to provide you with quality services, we may collect your personal data
concerned with the aforementioned features in addition to the registration information. In no event
shall we collect additional personal data unless you choose to use certain features in Bytello-related
products or services.
（7） We will use your personal data in strict accordance
with the purposes described in this Privacy Policy, and your personal data will only be used
for the purposes identified, described, and authorized by you at the time of collection. We will acquire
your separate consent in advance if the information is to be used for any purpose that is not specified
in this Privacy Policy. We will acquire your separate consent in advance when the information collected
for a specific purpose is to be used for other purposes. Without consent of users, we will not provide
third parties with users’ personal data.
Lawfulness of Data Processing
（1） Based on the relevant purposes of data usage, the
lawfulness basis for our processing of your personal data includes:
（2） You have given consent to the processing of your
personal data for one or more specific purposes;
（3） Processing is necessary for the purposes of the
legitimate interests pursued by us or by a third party, except where such interests are overridden by the
interests or fundamental rights and freedom of you;
（4） Processing is necessary for the performance of a
contract or at your request prior to entering into a contract;
（5） Processing is necessary for compliance with a legal
obligation;
（6） Processing is necessary to protect the vital interests
of you or of another natural person.
（7） Processing is necessary for the performance of a task
carried out in the public interest or in the exercise of official authority vested in us.
II. How We Use Cookies and Similar
Technologies
1. What is Cookie?
Cookie is a small piece of file that our websites, Apps,
or services transfer to and store on your device. Our websites, online services, interactive Apps, emails
and advertisements may use Cookies and other similar technologies, such as pixel tags and web beacons. These
Cookies may be stored on your computer for a short period of time (e.g., only when your browser is open) or
for a longer period of time, even years. We cannot access Cookies that were not set by us.
2. How We Use Cookie and Similar
Technologies
（1） We and our partners use Cookie or similar tracking
technologies to better understand the use of mobile software on your device, how often you use , what events
occur within the App, cumulative usage, performance data, and from where the App was downloaded. We will not
link the information stored in the analysis software to any personal data you submit in the mobile
App.
（2） We and our partners use Cookie or similar tracking
technologies to analyze trends, manage websites, track user behaviors on the websites, and collect aggregate
demographic information of our user base.
（3） Many web browsers have the “Do Not Track” feature. This
feature may send a “Do Not Track” request to websites. If your browser has turned on “Do Not Track”, all of
our sites will respect this preference.
（4） Like most websites, we may automatically collect certain
information to analyze cumulative trends and manage our sites. This information may include the IP address,
browser type, Internet service provider (ISP), reference/exit page, files you view on our sites (such as
HTML pages and graphics), operating system, date/time stamps, and/or click stream data.
（5） We work with third parties to display advertisements on
our websites or to manage our advertisements on other websites. Our authorized partners may use cookies or
similar tracking technologies to provide you with advertising based on your browsing activities and
interests. If you want to opt out of interest-based ads. Please note that you will continue to receive
general ads that are not personally targeted.
3. Clear/Disable Cookies
Managing Cookies and Cookie preferences must be done
within your browser's options/preferences. Below are guides for managing Cookies in some popular
browsers:
4. More Information about Cookie
For more information about cookie and instructions on
how to configure your browser to accept, delete or disable cookie, please see www.allaboutcookies.org.
III. How We Retain Your Personal Data
The personal data will be retained by default in the
sever deployed nearest to the country/region which you have provided with us when registering the Bytello
Account. The retention period of the personal data we collect is the minimum amount of time required to
achieve the purposes of collection stated in this Privacy Policy, unless otherwise required by laws or
regulations.
If we stop operating Bytello Account for special
reasons, we will promptly inform you and stop the collection and processing of relevant personal data, and
we will delete or anonymity the personal data we hold that is related to the
Bytello Account, unless otherwise required by laws and regulations.
IV. How We Share, Transfer and Disclose Your Personal
Data
1. How We Share and Transfer Your Personal
Data
We may, from time to time, share and transfer some
personal data with Bytello-related products or services, our associated companies and the strategic partners
that work with us to provide products and services, in order to provide the products or services you
request.
（1） Bytello-related products or services: When you use Bytello Account to log in to the
Bytello-related products or services, we may collect and synchronize data about your account-related
behavior and device information to such products or services, for the sake of identity authentication and
optimizing your usage experience.
（2） Affiliates: Currently we do not share any of your data to our
affiliates. If we intend to share your data to our affiliates, we will ask for your authorization
again.
（3） Sharing with Authorized Partners: Some of our services will be provided by our
authorized partners solely for the purposes stated in this Privacy Policy. We may share some of your
personal data with our partners to provide services and to improve user experience. To be specific：
a) We may need to share your device information and
behavioral data with our advertising, analytic service partners (including but not limited to
advertising service providers, third-party ad monitoring service providers, and information flow service
providers) in order to complete the advertising and monitoring the effectiveness of advertising, etc. We
will only share your personal data with these authorized partners to the extent necessary.
b) We may need to share your personal data with our
providers (including but not limited to data storage service provider, technical service providers, etc.) in
order to perform the necessary product or service functions.
c) In some cases, we will entrust a third party to process
your personal data on our behalf. For example, companies that send emails and provide technical support on
behalf of us. These companies can use your personal data solely to provide services to you on our
behalf.
We will only share or transfer your personal data for
lawful, legitimate, necessary, specific, and express purposes, and will only share personal data that is
necessary for the service. Meanwhile, we will require the above-mentioned third parties to take appropriate
confidentiality and security measures to process personal data through agreements or other appropriate
means.
2. How We Publicly Disclose Your Personal
Data
We will only publicly disclose your personal data if it
is mandatory required by laws, in compliance with subpoena,
legal proceedings, legal actions or compulsory request by supervisory department of government agencies. If
we sincerely believe that disclosure is necessary to protect our rights, ensure your or others’ safety,
investigate fraud or respond to government, we may publicly disclose your personal data.
V. How We Protect Your Personal Data
1. How We Protect Your Personal Data
We use appropriate technical and organizational measures
to protect the personal data that we collect and process about you. The measures we use are designed to
provide a level of security appropriate to the risk of processing your personal data. Specific measures we
use include regular malware scanning, encryption, access control, etc. Your personal data is contained
behind secure networks and is only accessible by a limited number of people who have special access rights
to such systems, and are required to keep the information confidential.
2. Notification and Response of Personal Data Security
Incident
However, please note that while we have taken reasonable
steps to protect your personal data, no website, Internet transmission, computer system, or wireless
connection is absolutely secure. In the event of a personal data security incident, we will, in accordance
with the requirements of relevant laws and regulations, promptly inform you of the following: the basic
situation and possible impact of the security incident, disposal measures we have taken or will take,
suggestions for your self-protection and risk mitigation, remedies for you, etc. We will timely inform you
of the relevant situation of the event by email, letter, telephone, or push notification. When it is
difficult to inform the personal data subjects individually, we will issue an announcement in a reasonable
and effective manner. Meanwhile, we will also actively report the handling of the personal data security
incident in accordance with the requirements of the regulatory authorities.
VI. Your Rights to Your Personal Data
We respect your rights to your personal data. Below is a
list of your legal rights as well as the measures that we take to protect these rights.
1. Right to Be Informed
We will inform you of how we process your personal data
by publishing this Privacy Policy. We are committed to being open and transparent about how we use your
personal data.
2. Right to Access
You can directly query or access your personal data on
Bytello dashboard, such as you can log in to your Bytello Account at any time to access your account-related
personal data on the Bytello dashboard. To be specific: you can access your profile photo, email address,
user name, country, payment information via Bytello Account – dashboard –
profile; you can access your password via Bytello Account –
dashboard – security; If you are unable to query or access your personal data
on your own, or if you encounter any problems while exercising your right to access, you may contact us and
request access to your personal data in the manner disclosed in this Privacy Policy.
3. Right to Rectification
When you find that the personal data we processed about
you is inaccurate or incomplete, you have the right to have it rectified or completed by us. For parts of
your personal data, you can directly correct and modify it on the Bytello dashboard. To be specific: you can
correct your profile photo, email address, user name via Bytello Account – dashboard – profile; you can
correct your password via Bytello Account – dashboard – security; For personal data that has not been made available for
your own modification, you may contact us and request corrections or additions to your personal data in the
manner disclosed in this Privacy Policy.
4. Right to Delete
You may choose to delete some of the personal data you
have submitted to us. For some of your personal data, you can delete them directly on the Bytello dashboard.
To be specific：
you can delete your profile photo, user
name via Bytello Account – dashboard – profile; you can
delete your password via Bytello Account – dashboard – security;
You may request that we delete your personal data by
contacting us in the manner disclosed in this Privacy Policy if we have not yet provided you with a channel
for the deletion of your personal data, or if we do not have legal bases to continue the retention of your
personal data.
You may also contact us directly and request
cancellation of your account by contacting support@bytello.com. We will record your request to cancel your account,
conduct a manual review of your request to confirm that you are eligible to cancel your account, and we will
assist you in completing the cancellation of your account. Please note that after you cancel the Bytello
account, you will no longer be able to log-on to use Bytello-related products or
services.
5. Right to Restrict Processing
You are entitled to request us to restrict processing of
your personal data. This means we can store your personal data but cannot process it. We only retain data
needed for future response. You can contact us in the manner disclosed in this Privacy Policy to achieve
your right to restrict processing.
6. Right to Data Portability
Within scope permitted laws and regulations, you are
entitled to obtain your personal data in a structured, commonly used, and machine-readable format. For instance, if you decide to change
the service provider, this right enables you to reliably and safely move, copy or easily transfer your
personal data between IT systems without affecting its use. After your formal authorization, you can
exercise your right of data portability by contacting us in the manner disclosed in this Privacy
Policy.
7. Right to Object
Even if the processing of your data is based on our
legitimate interest, exercise of public right, direct marketing (including data aggregation) and statistics,
you have right to refuse our process to your personal data by contacting us in the manner disclosed in this
Privacy Policy.
8. Right to Withdraw Consent
If you agrees to our processing of your personal data but later changes your mind, you can withdraw your consent at any time and we
must stop processing. You may change the scope of your authorization to us to continue collecting personal
data, or withdraw your authorization by deleting information, disabling device permission settings,
canceling your account, etc.
If you withdraw your consent, we will no longer be able
to provide you with the corresponding service for which you have withdrawn your consent. Once you have
withdrawn your consent, we will no longer process the corresponding personal data. But your decision to
withdraw your consent will not affect the processing of personal data based on your previous consent prior
to the withdrawal.
9. Right to Complain
You have the right to contact us and file service
complaints in the manner disclosed in this Privacy Policy. If you are dissatisfied with our response,
especially if our handling of personal data damages your legal rights, you can also file a complaint or
report to the regulatory authorities or file a lawsuit in a court with jurisdiction.
Please note that, due to security reasons, we may verify
your identity before processing your request. In principle, we do not charge any fees if your request is
reasonable. However, based on the actual situation, we may impose a certain fee to cover our costs for
repeated requests or requests that extend reasonable limits. We may reject requests that are unreasonably
repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally
changing an existing practice), may be detrimental to the legal rights and interests of others, or are very
impractical. In addition, we may not be able to respond to your request if your request is directly related
to matters involving national security, national defense, public health, criminal investigation and other
public interests, or if the request may severely impair the legitimate rights and interests of yours or
those of other individuals and organizations.
We will respond and reply to you as soon as possible.
Generally, we will reply to you within one month upon receipt of your request (if necessary, we may extend
it by an additional two months as permitted by law. We will inform you the reason for the extension within
the aforementioned 30-day period, such as the request is too complicated or too much in volume). If you are
not satisfied with the response you received, you can refer the complaint to the relevant regulatory
authority in your jurisdiction.
VII. How We Process Children’s Personal
Data
Pursuant to the relevant laws and regulations, if you
are a child under the age of 16, before using the relevant products or services, you shall obtain consent
from your parents or legal guardians. If you are the child’s guardian, you should read this Policy carefully
before you assist the child with Bytello Account registration.
Most of our services do not target children under the
age of 16. For these services, we do not actively collect, store, use, transfer, or disclose the personal
data of children under the age of 16 through the Internet or other manners. If you are a child under the age
of 16, a parent or legal guardian of a child, or if you otherwise find out that we collect, store or use
information that may include personal data of children under the age of 16, you may contact us promptly in
the manner disclosed in this Policy and we will take steps to delete the relevant data as soon as
possible.
VIII. Third-party Service Providers and Their
Services
Our websites, mobile applications may contain links to
third-party websites, products, and services. You can choose whether to visit or accept websites, products,
and services offered by third parties. For example, you may access third-party cloud storage services in
Bytello dashboard.
We have no control over third-party privacy and data
protection policies as such third parties are not bound by this Privacy Policy. Before you submit personal
data to third parties, please refer to their privacy policies.
IX. How Your Personal Data Is Transferred
Globally
As a globally operating company, we provide our services
through resources and servers around the world. In order to ensure the service effect (e.g. to ensure
the processing speed) and provide you login services globally, under the premise of not violating local data
protection laws, we will by default store your personal data in the server nearest to the country/region
which you have provided with us when registering the Bytello Account. We have servers in China, Europe,
United States, Singapore, and Australia, which means, your personal data may be transferred to, or
accessed from, the jurisdictions outside the country/region in which you use the Bytello Account or
Bytello-related products or services.
You understand that different data protection laws
involve different risks. In such cases, we will take measures to ensure that the data we collect is
processed in accordance with this Policy and applicable laws, and that your personal data is equally
protected as in the country/region where you use the product or service. For example, we will ask your
permission to transfer your personal data overseas, and we will implement security measures such as
encryption, de-identity, and signing necessary data transfer/sharing agreements
with data recipients prior to cross-border data transfer.
This Policy is subject to updates or revisions from time to time. We will send
you change notice through different channels. If you provide us with an email address, we will notify you by
email before the change becomes effective, otherwise we will post notices on our website.
This Policy allows adjustments. However, without your express consent, we will
not diminish your rights under this Policy.
If you do not agree to the above Policy, we will not be able to collect and use
the information necessary to provide the service, and will not be able to provide you with services
normally.
This Policy shall come into force as of the date of update.
If you have any questions or concerns about our Privacy Policy or related
practice, please contact us in the following manners:
Telephone: +86 020-82075661
Email: support@bytello.com
Address: 192 Kezhu Road, Science City, Economic and
Technological Development District, Guangzhou
Service & support: 020-82260169