PRIVACY POLICY – Points.red

PRed (hereinafter referred to as we) attaches great importance to the privacy and personal data protection of users. We may collect and use your information when you use our products and/or services. We hope that we can illustrate to you how we collect, use, processing, storage, transfer and sharing the information when your use our products and/or service, and the ways we will provide you with access, update, delete, and protect the data by PRed Privacy Policy (hereinafter referred to as the privacy policy)

This policy indicates that you understand the following contents:

Ⅰ. How do we collect and use your personal data?

Ⅱ. How do we use cookies and similar technologies?

Ⅲ. How do we share, transfer and publicly disclose your personal data?

Ⅳ. How do we protect and preserve your personal data?

Ⅴ. How do you manage your personal data?

Ⅵ. Protection of minors’ data

Ⅶ. Notice and amendment

Ⅷ. How to contact us

This privacy policy is relevant to PRed service which you use and the various business functions included in the service (hereinafter generally referred to as our products and/or services), We hope you read it carefully to make sure you have fully understand the content of this policy set forth and you can make the choice that you think appropriate under the guidance of the privacy policy before using our products and/or service. We try to keep the terms of this Privacy Policy as concise as possible and provide further explanations for your better understanding. You use/ continue to use our products and/or services after we update this privacy policy (we will remind you of updated news in time), which means you agree to this privacy policy content (updated version), and agree that we collect, use, process, save and share your relevant information in accordance with this privacy policy.

If you have any questions about this privacy policy or related matters, you can contact us at any time by visiting https://www.points.red, or sending an email to cs@pineapplec.com.

Ⅰ. How do we collect and use your personal data?

Personal data refer to all kinds of data recorded by electronic or other means that can identify a particular natural person or reflect the activities of a particular natural person individually or in combination with other data. The personal data involved in this Privacy Policy includes: basic data ( user name, personal phone number, email address); Network identity data (including system account number and IP address); Personal property data (transaction and consumption records, as well as virtual property data such as balance, PRed and coupons); Personal Internet surfing record (including website browsing record, software using record and click record); Personal equipment data (including hardware number, MAC address, operating system type, unique device identification code in software list (Information which describes basic information of personal common equipment, such as IMEI/ Android ID/IDFA/OPENUDID/GUID, SIM card IMSI data); Personal location data;

We will only collect and use your personal data for the following purposes:

(Ⅰ) You must authorize us to collect and use your personal data

Our products and/or services include the core functions which are necessary to earn or redeem PReds, to improve our products and/or services, and to secure transactions. We may collect, process, store, and use the following information related to you to achieve these functions. If you do not provide relevant information, you will not be able to enjoy our products and/or services. These features include:

1.Functions necessary to earn or redeem PReds during consumption and payment

(1) Member Registration

Firstly, you need to register a member account to become a PRed user. When you register, at least you need to provide us with your member account ID, password, your mobile phone number and email address (for email verification). We will send SMS verification code or email to verify your identity. Your account ID is your default ID, you can modify your ID, gender, birthday, hobbies and other account information. Your account information will help us to provide you with personalized product recommendations and a better consumption experience, but if you do not provide such information, it will not affect your basic functions of earning or redeeming PReds when you consume and pay.

(2) Display and Search of Commodity Information

In order to provide you a better using experience, we may collect your equipment information and type of browser when you use our products and/or service (including equipment name, model, equipment identification number, operating system and application software version, language settings, resolution, the service provider network ID (PLMN)), to provide you the optimal way of commodity display. We will also use your above personal information to continuously improve and optimize the above functions.

You can also search to find exactly what goods or services you need. We will retain your search content to facilitate you to re-enter or show you the products associated with your search. Please note that your search keyword data cannot be independently identified, your search keyword data does not belong to your personal data. We have the right to use it for any purpose. Only when your search keyword data is used in combination with your other data, which can identify you, during that time, we will treat your search keyword data as your personal data and protect it in accordance with this Privacy Policy together with your search history.

(3) Consumption

When you consume in a merchant, we need to manage the merchant in accordance with laws, regulations and regulatory provisions to prevent the risk of cash out or fraud. Therefore, we will directly collect your transaction information or collect from the merchant, including transaction amount, transaction object, transaction commodities, transaction time and distribution information (if any). If you do not agree that we record the foregoing information, you may not be able to complete the transaction. But it will not impact your use of other services provided by us.

(4) Payment function

When you get PReds from PRed, we need to share your order number, transaction amount and other information of PRed with the third-party payment agency to confirm your payment instruction and complete the corresponding PReds.

4.1) PReds

When you use PReds to redeem the payment amount, we need to record your PRed account balance and transaction information. If you do not agree with us to record the above information, you may not be able to use PReds to redeem the payment amount.

4.2) Quick Payment

When you use the express payment service, you can directly show your bank card to the merchant to complete the payment. We do not collect your personal banking information above.

4.3) Credit Card Payment

When you use the credit card payment service, you can directly show your credit card to the merchant for payment. We do not collect your personal credit card information above.

2. Functions necessary to improve our products and/or services

We may collect your order information, browse information, and your interests (which you can select from the account settings) for data analysis to form user portraits to display you the goods or services that you are interested in, or show you the items you might want to find when you search. We may also obtain your other information that we need to provide services and improve the quality of our services reasonably, such as the information that you send to us when you participate in the questionnaire survey and the information that we obtain when you interact with our affiliates and our partners. For data collected from your various devices, we may associate them so that we can provide consistent services to you on those devices. We may combine information from one service with information from other services to provide you with services, personalized content and recommendations.

3. Functions necessary to ensure the security of transactions

To improve security of using our products and/or service of the system, preventing fishing website fraud and protecting the security of the account more accurately, we may judge the risk of your account through analyzing your browsing information, order information, commonly used software materials, equipment materials and other means, and we may record some links we think there’s a risk ( URL ); We will also collect your equipment data to analyze the system problems of PRed, count the traffic and screen possible risks, and check when you send abnormal data to us.

(Ⅱ) You can decide if authorize us to collect, process and use your personal data

1. The following additional functions may collect, process and use your personal information in order to making your consumption more convenient and fun, and enhancing your experience of earning or redeeming PRed during payment on PRed. If you do not provide such personal information, you can still earn or redeem PReds when conducting payment, but you may not be able to use additional features that can bring you pleasure when consuming or You need to fill in some information repeatedly when consuming. These additional features include:

(1) Personalized recommendation feature based on the location information: we will collect your location information (we will only collect your geographical position at that time, but will not associate your location data in each period to determine your whereabouts trajectory) to determine the location where you are, then automatically recommend for you PRed you can use, purchase for goods or services. For example, to recommend you the nearest partner merchant of PRed.

(2) Additional functions based on address book information: We will collect your address book information so that you do not have to manually enter the contact information of your address book; In order to increase the social interest of your consumption, we can also determine whether your friends are also members of PRed and establish a connection for your communication on PRed with your consent. If you do not provide this information, it will not affect you to use PRed App.

(3) Additional functions based on keystroke recognition: For providing your more secure and convenient payment service, if your device supports fingerprint function, you can choose to use fingerprint payment service. You need to enter your fingerprint information on your device, and then complete the information verification on your device when you make the fingerprint payment. We only receive verification results and do not collect your fingerprint information. If you do not want to use fingerprint verification, you can still pay by other means.

(4) In order to provide you one-click sharing service, our product integrates Youmeng+ U-SharesdK, which will collect your device identification information (such as IMEl/ Android ID/DFA) and the social account information you need to share, to complete the one-click sharing service. For your information security, we have made data security confidentiality agreement with the third party SDK service providers, and these companies will strictly comply with our data privacy and security requirements. We will not share your personally identifiable information with them unless you agree to do so.For a better understanding of Youmeng+’s data types,usages, and how to protect your personal information, you can visit https://www.umeng.com/policy to know more about the privacy policy of Youmeng+.

2. To use above additional functions, you are required to give us access to your geo-location (location data), camera, album (photo gallery), microphone and address book in your device to collect, process and use the data for these functions. You can view the enabled status of above permissions in the Account Settings – Settings – Privacy of your personal mobile devices and decide to turn them on or off at any time. Please note when you open the permissions, it represents that you authorize us to collect process, and achieve above functions. When you close the permissions, it represents that you cancel the authorization, then we will no longer continue to collect, process, and use your personal data, and we are unable to provide you above authorized functions. Your decision of turning off your permission does not affect the processing of your personal data that was previously done based on your permission.

(III) You fully understand that we do not need your authorization to collect and use personal data under any of the following circumstances:

1. Those related to national security and national defense security;

2. Those related to public safety, public health and major public interests;

3. Those related to criminal investigation, prosecution, trial and execution of judgment;

4. Perform legal obligations according to law;

5. For the purpose of safeguarding the personal material lawful rights and other individuals’ significant legitimate rights and interests, such as life and property, but the person himself is physically or legally incapable of giving consent;

6. The personal data collected are disclosed to the public by the subject of personal data;

7. Your personal data collected from legally disclosed information, such as legitimate news reports and government information disclosure;

8. Necessary to sign the contract according to your requirements;

9. Necessary to maintain the safe and stable operation of the products and/or services provided, such as the detection and disposal for faults of the products and/or services;

10. Necessary for lawful news reporting;

11. When it is necessary for an academic research institution to carry out statistics or academic research based on the public interest and to provide the results of academic research or description to the outside world, the personal data contained in the results are de-labeled;

12. Other circumstances prescribed by laws and regulations.

(IV) Circumstances in which we obtain your personal information from third parties

We may obtain your authorized shared account information (icon, ID) from third parties (such as WeChat, QQ, etc.) and bind your third party account to your member account after you agree to this privacy policy, so that you can directly log in and use our products and/or services through your third party account. We will use and process your personal data in accordance with relevant laws and regulations after confirming the legality of the source of personal data as agreed with third parties.

(Ⅴ) Rules for the use of your personal data

1. We will use and process the personal data collected in accordance with the provisions of this Privacy Policy and for the purpose of implementing the functions of our products and/or services.

2. After collecting your personal data, we will de-identify the data through technical means. The de-identified data will not be able to identify the subject. Please understand and agree that we have the right to use the de-identified materials in this circumstance; We have the right to analyze and commercialize the database of users without disclosing your personal data.

3. Please note that all personal data provided by you for using our products and/or services will continue to be authorized when you use them unless you deleting or rejecting our collection through system Settings. However, when you freeze/deactivate/cancel your account, we will stop using and then delete your personal information.

4. We will make statistics on the usage of our products and/or services and may share such statistics with the public or third parties to demonstrate the overall usage trend of our products and/or services, but such statistics do not include any identifying information about you.

5. When we display your personal data, we will desensitize your data by means of content replacement and anonymous processing to protect the security of your data.

6. When we wish to use your personal data for other purposes not specified in this policy, or when the data is collected for a specific purpose, we will seek your prior consent in the check form.

Ⅱ. How do we use cookies and similar technologies?

(I) The use of Cookies

1. In order to realize the personalized requirements of your networking experience for more relaxed access experience. We may send one or more small data files named Cookies to your computer or mobile device. Cookies specified to you are unique and can only be loaded by the web servers in your domain which published the Cookies to you. We send Cookies to you in order to simplify the steps of your repeated login, to store your consumption preferences or goods in your shopping cart and other information to provide you with preferences for consumption, to help you optimize the selection and interaction of advertisements, to explain your login status and account or data security.

2. We will not use Cookies for any purpose other than those stated in this Privacy Policy. You can manage or delete Cookies according to your preferences. You can clear all Cookies saved on your computer. Most browsers automatically accept Cookies, but you can usually change the browser settings to reject Cookies according to your own needs. In addition, you can also remove all Cookies saved in the software. However, if you do this, you may need to personally change user settings every time you visit PRed website, and any information you previously recorded will be deleted, which may affect the security of the services you use.

In addition, we will use the following techniques

JavaScript

To record your actions on the site so that we can tailor our services to meet the needs of our users. During the process, we will find out your browser type, location, time, use time, web address, web page name and the web site to which you are switched to our web site. You can disable JavaScript in your browser to stop us recording the data directly. However, be aware that disabling JaveScript may limit the functionality of your site.

Marketing Cloud

We use this tool to record your activities on our website to improve our products. It helps us check how many people visit our site, what our pages are viewed and how often. The evaluation is done anonymously and used automatically by predictive intelligence to improve the way we present our products. For registered members, the system records users’activities on the site to improve the user experience and display relevant content.

Please note that standard Internet browsers accept Cookies according to default Settings. You may also set your browser to reject all or some Cookies or to require your consent before receiving new Cookies. Most browsers provide instructions under the help option of the menu. Under the help option, you can also learn how to delete Cookies received.

Please note that if you do not accept any or some Cookies, you may not be able to use all functions of our site.

By using our website, you agree to use the Cookies and tools described above.

(II) Use of LBS and other similar technologies

In addition to cookies, we will also use LBS and other similar technologies on the website to calculate the number of visits by users, identify registered users of PRed by visiting cookies, and provide personalized services for you.

Ⅲ. How do we share, transfer and publicly disclose your personal data?

(1) Sharing

1. We will not share your personal data with any company, organization or individual other than PRed, except where:

(1) Obtain your express consent or authorization in advance;

(2) To provide in accordance with applicable laws and regulations, the requirements of legal procedures, mandatory administrative or judicial requirements;

(3) To the extent permitted by laws and regulations, it is necessary to provide to protect PRed, its affiliates or partners merchants, you or other members of PRed or the public interests, property or security from damage;

(4) Only by sharing your data can we realize the core functions of our products and/or services or provide the services you need;

(5) Handle your disputes with others as required by you;

(6) In accordance with the relevant agreement signed with you (including the e-agreement signed online and the corresponding platform rules) or other legal provisions;

(7) To use based on academic research;

(8) To use based on the public interest in accordance with laws and regulations.

2. We may share your personal information with our affiliates. However, we will only share necessary personal data for the purposes stated in this Privacy Policy. If our affiliates wish to change the purpose of processing your personal data, they will ask for your permission.

3. We may share your order information, account information, device information and location information with third parties such as partners to ensure the smooth completion of the services provided to you. However, we will only share your personal data for lawful, legitimate, necessary, specific and clear purposes and will only share the personal data necessary to provide the services. Our partners have no right to use the shared personal data for any other purposes. Our partners include the following types:

(1) Suppliers of goods or technical services. We may share your personal data with third parties that support our functions. These supports include supplying or providing infrastructure technical services, payment services, data processing, etc. We share this information for the purpose of realizing the core consumption reward function of our products and/or services, or we need to share your order number and order amount with a third-party payment agency to confirm your payment instruction and complete payment, etc.

(2) Third-party merchants. We must share your order information and the necessary information related to the transaction with the third-party merchants to realize your need to purchase goods or services from them, and enable them to earn or redeem PReds and subsequent after-sales services.

(3) Partners entrusted by us for promotion. Sometimes we provide promotional services on behalf of other businesses to the members who use our products and/or services. We may use your personal information and indirect users portraits formed by your non-personal information collection which entrusts us to partner ( the client ) share, but we will only offer these covered and effective data to the client, and do not provide your personal identity information, or we will summarize these data, so that it will not identify you personally. For example, we can tell the client how many people have seen their promotional materials or bought their products after seeing them, or provide them with unidentifiable statistics to help them understand their audience or customers.

4. We will sign strict privacy policy with companies, organizations and individuals with whom we share personal data, requiring them to handle personal data in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures. In order to ensure the security and control of data in a third party, we provide SSL technology for secure and reliable data encryption to ensure the security and anonymity of user data. In the use of sensitive personal data, we require third parties to adopt data desensitization and encryption techniques to better protect user data.

5. Exchange information with other companies and organizations in order to comply with laws, enforce or apply our Terms of Use and other agreements, or to protect the rights and property or security of PRed, you or other members of PRed, such as to prevent illegal activities such as fraud and reduce credit risks. However, this does not include personal data that are sold, rented, shared or otherwise disclosed for profit in violation of the commitments made in this Privacy Policy.

(2) Assignment

We will not transfer your personal data to any company, organization or individual other than by giving notice or obtaining permission from the public authorities in accordance with the law:

1. Obtain your express consent or authorization in advance;

2. Provide information in accordance with applicable laws and regulations, requirements of legal procedures, mandatory administrative or judicial requirements;

3. Comply with the relevant agreements signed with you (including the e-agreement signed online and the corresponding platform rules) or other legal documents;

4. In the event of a merger, acquisition, transfer of assets or similar transaction involving the transfer of personal data, we will require the new company or organization holding your personal data to remain subject to this Privacy Policy, otherwise we will require the company or organization to seek authorization from you again.

(Ⅲ) Public disclosure

Under the premise of adopting safety protection measures in line with industry standards, we will only publicly disclose your personal data if:

1. According to your requirements, disclose your designated personal information with your express consent;

2. In cases where your personal information is required by laws, regulations, compulsory administrative enforcement or judicial requirements, we may publicly disclose your personal information in accordance with the required type and manner of disclosure of your personal information. Subject to compliance with laws and regulations, when we receive a request for such disclosure, we will require the issuance of a corresponding legal document, such as a subpoena or letter of investigation. We firmly believe that the information requested of us should be as transparent as possible to the extent permitted by law. All requests are carefully reviewed to ensure that they have a legitimate basis and are limited to information that law enforcement has a legitimate right to access for specific investigative purposes. To the extent permitted by laws and regulations, the documents we disclose are protected by the encryption key.

Ⅳ. How can we protect and preserve your personal data?

(I) The technologies and measures we used to protect your personal data

We take personal data security very seriously and take all reasonably practicable measures to protect your personal data:

1. Technical measures for data security

We will adopt security measures in line with industry standards, including the establishment of reasonable system specifications, security technology to prevent your personal data from unauthorized access to use, modify, avoid damage or loss data.

(1) The network service of PRed adopts SSL encryption technology to provide browsing service for users through HTTPS transport protocol with high security and reliability, ensuring the security of user data during transmission.

(2) PRed uses encryption technology to encrypt and save users’ personal data, and uses virtualized directory technology to isolate and protect user information security measures. In the use of personal data, such as personal data display and personal data association calculation, we will use a variety of data desensitization technologies, including SHA256, HSTS, CC attack protection, to enhance the security of personal data in use.

(3) PRed adopts strict data access permission control and multiple identity authentication technology to protect personal data and avoid illegal use of data.

(4) PRed adopts automatic code security check and data access log analysis technology to conduct personal data security audit.

2. Other security measures taken by PRed to protect personal data

(1) PRed manages and standardizes the storage and use of personal data by establishing data classification system, data security management standard and data security development standard.

(2) PRed carries out comprehensive security control of data through privacy policy of data contacts, monitoring and auditing mechanism.

(3) PRed shall establish a data security committee and set up a dedicated data protection department and a data security emergency response organization to promote and protect personal data security.

(5) Strengthen safety awareness. We will also conduct security and privacy training courses to enhance staff’s awareness of the importance of protecting personal data.

3. We only allow PRed, relative employees and partners who need to know such data to access personal data, and set up strict access permission control and monitoring mechanism for this purpose. We also require all personnel who may have access to your personal data to perform the corresponding confidentiality obligations. Failure to meet these obligations may result in legal liability or termination of the partnership with PRed.

4. We will take all reasonably practicable steps to ensure that irrelevant personal data are not collected. We will retain your personal data only for as long as necessary for the purposes stated in our policy, unless the retention period is extended or permitted by law.

5. The Internet is not a completely secure environment, and it is impossible to determine whether email, instant messaging, social network and other ways of communicating with other users are completely encrypted. We recommend that you use complex passwords when using such functions, and take care to protect your personal data security.

6, the Internet environment is not 100% secure, we will do our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access to information, public disclosure, tampering, or destruction of your legitimate rights and interests, we will bear the corresponding legal liability.

7. Handling of security incidents

(1) When trading goods or services online with a third party through the website of PRed, you will inevitably have to disclose your personal information, such as contact information or postal address, to the trading party or potential trading party. Please properly protect your personal data and only provide it to others if necessary.

(2) In order to deal with the possible risks of personal data disclosure, damage and loss, PRed has formulated a number of systems to clarify the classification standards of security incidents, security vulnerabilities and corresponding processing procedures. PRed has also set up a special emergency response team for security incidents. According to the requirements of safety incident handling regulations, it launches security plans for different security incidents to prevent losses, analyze, locate, formulate remedial measures, and work with relevant departments to trace and deal.

(3) In the event of an unfortunate personal data security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, the suggestions that you can prevent and reduce the risk independently, and the remedial measures for you. At the same time, we will timely inform you of the event by email, letter, phone call, push notification and other means. If it is difficult to inform the subject of personal data one by one, we will take a reasonable and effective way to publish the announcement. At the same time, we will also, in accordance with the requirements of regulatory authorities, report the disposal of personal data security incidents.

8. If you have any questions about our personal data protection, you can contact us through the contact information agreed at the bottom of this policy. If you find that your personal information is leaked, especially your account and password, you can contact us at any time by visiting https://www.points.red or sending email to cs@pineapplec.com.

(Ⅱ) Preservation of your personal data

Your personal data will be stored in AWS/ Macao Special Administrative Region. If you use the cross-border transaction service and need to transfer your personal data to foreign countries to complete the transaction, we will individually obtain your authorization and consent and ask the recipient to handle such personal data in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

Please note that after you successfully applying to freeze/deactivate/cancel your account, we will complete the audit of your account freeze/deactivate/cancel within 48 hours of your application. After the audit is approved, we will delete or anonymize your personal data.
If we terminate the services or operations, we will notify you at least 15 days in advance and delete or anonymize your personal data after termination of the services or operations.

Ⅴ. How do you manage your personal data?

PRed attaches great importance to your personal data and does its best to protect your rights to access, correct, delete and withdraw your consent to your personal data so that you have the full ability to protect your privacy and security. Your rights include:

1. Access and correct your personal data

You have the right to access, inspect and correct your personal data at any time.

2. Delete your personal data

You can directly clear or delete information from our products and/or services page, including order information, browse information, shipping address information;

You may request us to delete your personal data:

(1) If our handling of personal data violates laws and regulations;

(2) If we collect and use your personal data without your consent;

(3) If our handling of personal data violates our policy with you;

(4) If we terminate the services and operations.

If we decide to respond to your request for deletion, we will also notify the entities that have obtained your personal data from us to delete them in a timely manner, unless otherwise required by laws and regulations, or if such entities are independently authorized by you. When you delete data from our services, we may not immediately delete the corresponding data from the backup system, but we will delete the data when the backup is updated.

3. Change the scope of your authorization or withdraw your authorization

You may change the scope of your authorization to continue to collect personal data or revoke your authorization by deleting data, turning off device functions, or making privacy settings on PRed website or software. You may also revoke all authorization which continue to collect your personal information by logging out of your account.

4. Freeze/ deactivate /cancel your account

You can log out directly from our products. After you freeze/deactivate/cancel your account, we will cease to provide you with products and/or services and, upon your request, we will delete your personal information unless otherwise required by laws and regulations. For details, please refer to the attachment Notes on Freezing/Deactivating/Canceling Member Accounts.

5. If you do not want to accept the promotional information we send to you, you can cancel at any time by:

(1) You can contact us at any time by email to cs@Pineapplec.com.

(2) We will cooperate with third-party platforms or media to recommend personalized products to you based on your personal information. This personal information includes such information as your consumption on this platform and the interests you have entered in your account settings. The platform only provides us with the display of products. The link of the display content is the personalized product display information within PRed, which is managed by PRed. Therefore, we will not provide any of your personal information to advertisers.

(3) In order to protect your privacy, we will not, in any way or by any means, push to you any promotional or product information involving religious belief, sex, disease or other sensitive content.

6. Respond to your request

If you cannot access through the way to consult, correct or delete your personal information, or you need to visit and consult, correct or delete other personal information generated by using our products and/or services, or you think there is any violation of laws, regulations, or provisions of the personal information collection or usage of PRed, you can send email to cs@pineapplec.com to contact us. For security purposes, we may require you to provide a written request or otherwise which can prove your identity, and we will respond your request within 30 days after receiving your feedback and verifying your identity. In principle, we do not charge you for reasonable requests, but for repeated requests beyond reasonable limits, we will charge a certain cost according to the situation. We may reject requests that are gratuitously repetitive or require too many technical means (for example, the need of developing new systems or change existing practices radically), pose a risk to the legitimate interests of others, or are highly impractical (for example, involving backing up data on tape).

We will not be able to respond to your request as required by laws and regulations in the following circumstances:

(1) Those related to national security and national defense security;

(2) Those related to public safety, public health or major public interests;

(3) Those related to criminal investigation, prosecution and trial;

(4) There is sufficient evidence to show that you have subjective malice or abuse of rights;

(5) Responding to your request will cause serious damage to your or other individuals’ and organizations’ legitimate rights and interests.

Ⅵ. Protection of Personal Data of Minors

1. PRed attaches great importance to the protection of minors’ personal data. If you are a child under the age of 18, prior written consent of your parent or legal guardian should be obtained before using our products and/or services. PRed protects the personal data of minors in accordance with relevant laws and regulations of China and Macao.

2. In the case of collecting personal data of a minor with the consent of his/her parents or legal guardian, we will only use, process or publicly disclose such data if permitted by law, with the explicit consent of his/her parents or guardian, or the situation which is necessary to protect the minor.

3. If we find that we have collected the personal data of a minor without the prior verifiable consent of our parents or legal guardian, we will seek to delete the data as soon as possible.

Vii. Notice and Amendment

1. With the development of PRed and in order to provide you with better services, this privacy policy will be updated accordingly. However, we will not delete your rights of this Privacy Policy without your express consent. We will issue an update version on PRed official website as well as PRed APP and notify you about the update of relevant content through a website announcement or in other appropriate ways before it taking effect. You are also requested to visit PRed to keep abreast of the latest privacy policy.

2. We will also provide more prominent notification of major changes (including but not limited to email, text message or special notice on the browse page to explain specific changes to our Privacy Policy).

Material changes in this policy include, but not limited to:

(1) Great changes have taken place in our service mode, such as the purpose of processing personal data, the type of personal data to be processed, and the manner of using personal data;

(2) We undergo significant changes in ownership structure, organizational structure etc, such as business adjustment, the change of ownership caused by bankruptcy mergers and acquisitions.

(3) The main objects of personal data sharing, transfer or public disclosure change;

(4) There is a major change of your rights to participate in the processing of personal data and the way of your operation;

(5) When our responsible departments, contact information and complaint channels for handling personal data safety change;

(6) When the personal data security impact assessment report indicates high risk.

3. We will also archive older versions of this policy for your reference.

Ⅷ. How to contact us

1. If you have any questions, comments or suggestions concerning this privacy policy or your personal information, you can contact us at any time by visiting https://www.points.red, or sending email to cs@Pineapplec.com.

2. As a rule, we will reply you within 30 days. If you are not satisfied with our reply, especially if our handling of personal data damages your legitimate rights and interests, you can also make a complaint or report to the relevant regulatory authorities.

This Policy was written in Chinese and English respectively. If there is any inconsistency or ambiguity of these two versions, the Chinese version should be prevailed.