Effective date as of July 19, 2024
Welcome to our products and services! We understand the importance of your personal information to you. As the provider of FileShow products and services (referred to as "we" or "Stellar"), we strictly adhere to legal and regulatory requirements by implementing corresponding security measures to protect your personal information, ensuring its security and controllability.
We respect and protect the personal privacy rights of all users who use our services. To provide you with more accurate and personalized services, Stellar will use and disclose your personal information in accordance with this Privacy Policy.
Stellar will handle this information with a high degree of diligence and caution, protect your privacy, and ensure the security of your personal data, in compliance with the Personal Data (Privacy) Ordinance (Chapter 486) of Hong Kong, especially where applicable. Except as otherwise provided in this Privacy Policy, Stellar will not disclose or provide this information to third parties without your prior permission.
Stellar may update this Privacy Policy from time to time. By agreeing to the Stellar Service Agreement, you are deemed to have agreed to the entire content of this Privacy Policy. This Privacy Policy is an inseparable part of the Stellar Service Agreement.
This policy will help you understand the following:：
1. Scope of This Policy
2. How We Collect and Use Your User Information
3. How We Share, Transfer, and Publicly Disclose Your User Information
4. How You Can Exercise Your Rights to Manage Personal Information
5. How We Use Cookies and Similar Technologies
6. How We Protect and Store Your User Information
7. How We Handle Children's Personal Information
8. How this Policy is Updated
9. How to contact Stellar
1. Scope of This Policy
This Policy applies to FileShow’s web, mobile platforms (including but not limited to Apps and mini-programs), software development kits (SDKs), and application programming interfaces (APIs) used by third-party websites and applications to access and use our products and services. If we or our affiliates provide products or services to you with separate privacy policies or statements, those respective products or services are subject to their corresponding privacy policies or statements.
Except for the information collection and use activities described in this Policy, this Policy does not apply to other services provided to you by third parties. Those other services are subject to their separate personal information collection and usage rules provided to you.
2. How We Collect and Use Your User Information
2.1 What Personal Information We Collect about You
When you use our products and/or services, we need or may need to collect and use the following types of your personal information :
a) To provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally;
b) To provide you with additional functions of our products and/or services, you can choose to separately agree or disagree with our collection and use of the information. If you refuse to provide this information, you will not be able to use the relevant additional functions normally or achieve the intended functional effects. However, this will not affect your use of our basic functions.
2.2 How We Use Your User Information
a) Account Registration: Your email address, password, account name to be used, and company name. We collect this information to help you complete the registration of your FileShow account and to protect your account security. If you refuse to provide this information, you may not be able to successfully register a FileShow account, but this will not affect your ability to use basic services such as browsing and searching that do not require an account.
b) During your use of the FileShow system, we may receive and record specific device information and network identity information based on the specific permissions you grant during software installation and use. This may include device identifiers, basic system information (IP address) and application usage information.
c) Personal information provided when you contact us, use services, or request assistance. For example, contact information (account name and account ID, email address, phone number) and business information (company name).
d) In order to provide you with more convenient, high-quality and personalized products and/or services, and to enhance your experience, we may collect and use your personal information through enabling system permissions when providing you with the following additional services. If you do not agree to enable the relevant permissions, it will not affect your use of FileShow's basic services, but you may not be able to enjoy the user experience provided by these additional services:
| Device Permissions | Corresponding Business Functions | Functionality Scenario Explanation | Whether it can be Turned off |
|---|---|---|---|
| Notifications | System Notifications | App-Related Push Notifications | Yes, after it is turned off, it will only affect the corresponding function and will not affect other functions of FileShow. |
| Storage (Album) | Upload and Download | Upload all types of files from the device’s storage (album), including images, videos, audio files, etc., to FileShow for management. | Yes, after it is turned off, it will only affect the corresponding function and will not affect other functions of FileShow. |
| Microphone (Recording) | Upload | Record videos or audio, and upload them to FileShow for management. | Yes, after it is turned off, it will only affect the corresponding function and will not affect other functions of FileShow. |
| Camera (Webcam) | Upload and scan | Capture videos/photos, scan documents, and upload them to FileShow for management. | Yes, after it is turned off, it will only affect the corresponding function and will not affect other functions of FileShow. |
You can turn these permissions on or off at any time at your discretion.
Please note, enabling any permission means you authorize us to collect and use the relevant personal information to provide the corresponding service. Once you disable any permission, it means you have withdrawn your authorization, and we will no longer collect and use the related personal information based on that permission, nor will we be able to continue providing the service associated with that permission. Your decision to disable a permission will not affect the information collection and use conducted based on your prior authorization.
2.3 Exceptions to Obtaining Authorization for Collecting and Using Your Personal Information
You fully understand that, according to relevant laws and regulations, in the following situations, we can collect and use personal information without obtaining your authorization and consent:
a) Directly related to national security and national defense security;
b) Directly related to public safety, public health, or significant public interest;
c) Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;
d) For the purpose of protecting your or other individuals’ significant legitimate interests such as life and property, but where it is difficult to obtain consent;
e) The personal information collected is disclosed to the public by yourself;
f) Collecting your personal information from legally and publicly disclosed information, such as from lawful news reports, government information disclosures, and other channels;
g) Necessary for the conclusion and performance of a contract at your request;
h) Necessary for maintaining the safe and stable operation of the product and related services, such as discovering and handling malfunctions of the product or service;
i) Other circumstances stipulated by laws and regulations.
2.4 Rules for the Use of Personal Information
a) We will use the collected personal information in accordance with the provisions of this Policy.
b) The personal information provided by you according to this policy or collected with your consent will continue to authorize us to use during your use of this product. When you deactivate your account, we will cease to use and delete your personal information or anonymize it.
c) In order to improve our products and provide you with services that better meet your personalized needs, we will extract your preferences, behavioral habits, and other characteristics from your personal information collected with your authorization. Based on these characteristic tags, we will create indirect user profiles to offer more accurate and personalized services and content, including displaying, pushing messages, and potential commercial advertisements. If you do not wish to receive commercial advertisements from us, you can unsubscribe by replying to the unsubscribe prompt via SMS or using other methods we provide.
d) When we use your personal information for other purposes not specified in this Policy, or use the information collected for specific purposes for other purposes, we will seek your consent in advance.
3. How We Share, Transfer, and Publicly Disclose Your User Information
3.1 Sharing
Unless we obtain your explicit prior consent or comply with other laws and regulations, or meet mandatory requirements from government authorities, we will not share your personal information with companies, organizations, or individuals outside of Stellar.
3.2 Transfer
We will not transfer your personal information to any company, organization or individual, except in the following circumstances:
a) Transfer with Explicit Consent: With your explicit consent, we will transfer your personal information to other parties.
b) In the event of a merger, acquisition, or bankruptcy liquidation, if personal information transfer is involved, we will require the new entity holding your personal information to continue to be bound by this Privacy Policy. Otherwise we will require that entity to obtain your authorization consent again.
3.3 Public Disclosure
We will only publicly disclose your personal information in the following circumstances:
a) With your explicit consent;
b) Legal Disclosure: In compliance with laws, regulations, legal procedures, litigation, or mandatory requirements from government authorities, we may disclose your personal information.
3.4 Exceptions to Obtaining Prior Authorization Consent for Sharing, Transfer, and Public Disclosure of Personal Information
According to relevant laws and regulations, we may share, transfer, or publicly disclose your personal information in the following circumstances without obtaining your authorization consent:
a) Directly related to national security and national defense security;
b) Directly related to public safety, public health, or significant public interest;
c) Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;
d) For the purpose of protecting your or other individuals’ significant legitimate interests such as life and property, but where it is difficult to obtain consent;
e) The personal information collected is disclosed to the public by yourself;
f) Collecting your personal information from legally and publicly disclosed information, such as from lawful news reports, government information disclosures, and other channels;
g) According to legal requirements, if we use technical measures and other necessary measures to de-identify personal information and ensure that the data recipient cannot recover and re-identify the data subject, the sharing, transfer, or public disclosure of such data will not require separate notification to you or your consent.
h) Other circumstances stipulated by laws and regulations.
4. How You Can Exercise Your Rights to Manage Personal Information
You can access and manage your information through the following ways. We will respond to your requests in accordance with relevant laws and regulations:
4.1 Accessing and Correcting Your Personal Information
You have the right to access your personal information, except where exceptions are provided by laws and regulations. If you find that there are errors in the personal information we process about you, you have the right to request correction. You can access and modify your personal information through the following methods:
Your account information: Log in to FileShow, click on your avatar to enter the user settings, where you can modify your display name and account password.
Your company information: Log in to the FileShow management console, navigate to settings, where you can modify company name, company logo, and other information.
4.2 Delete your Personal Information
In the following situations, you can also request us to delete your personal information:
a) If our processing of personal information violates laws and regulations;
b) If we collect and use your personal information without your consent;
c) If our processing of personal information violates agreements with you;
d) If you no longer use our products or services, or if you have deactivated your account;
e) If we no longer provide products or services to you.
After you delete information from our service, we may not immediately delete the corresponding information from the backup systems, but will delete this information when the backups are updated. Please be aware and understand that if the retention period specified by laws, regulations, or this privacy policy has not expired, or if deletion of personal information is technically difficult to achieve, we will stop processing beyond storage and take necessary security measures.
4.3 Account Deactivation by Personal Information Subject
You can request to deactivate your account with us. After verifying your identity and clearing any assets in your account (if applicable), we will proceed with the account deactivation service for you. Upon successful deactivation, we will cease providing products or services to you and, in accordance with applicable laws and regulations, delete your personal information or anonymize it.
4.4 Responding to Your Requests
For security purposes, you need to submit a written request or provide other forms of identity verification. We may first require you to verify your identity before processing your request. We will respond to your request within 15 days.
For your reasonable requests, we generally do not charge a fee. However, for repeated requests beyond a reasonable limit, we may charge a certain cost. Requests that are unreasonably repetitive, require excessive technical means (such as developing new systems or fundamentally changing current practices), pose risks to the legitimate rights of others, or are impractical may be refused.
In the following situations, we will be unable to respond to your request:
a) Where it is related to Personal Data Controllers' performance of obligations provided for by laws and regulations;
b) Directly related to national security and national defense security;
c) Directly related to public safety, public health, or significant public interest;
d) Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;
e) Where the Personal Information Controller has sufficient evidence showing that the Personal Information Subject is acting in bad faith or abusing their rights;
f) For the purpose of protecting your or other individuals’ significant legitimate interests such as life and property, but where it is difficult to obtain consent;
g) Responding to Personal Information Subject's request would seriously harm to the legitimate rights and interests of the Personal Information Subject or other individuals or organizations;
h) Involving trade secrets;
i) Other circumstances stipulated by laws and regulations.
5. How We Use Cookies and Similar Technologies
To ensure the normal operation of the website and provide you with a more convenient browsing experience, we store small data files called Cookies on your computer or mobile device. Cookies typically contain identifiers, site names, and some numbers and characters. Stellar can only read Cookies provided by Stellar. With Cookies, we can store your preferences. The next time you visit, we will display the information you need. You can manage Cookies according to your preferences and also delete all Cookies stored on your computer. Most web browsers have features to block Cookies. However, if you do this, you may need to change user settings each time you visit our website. For detailed instructions on how to change browser settings, please visit the relevant settings page of your browser.
6. How We Protect and Store Your User Information6.1 Retention Period
6.1 Retention Period
We will retain your personal information for the period necessary to provide services. However, in cases where laws and regulations specify a longer retention period, you consent to a longer retention period, it is necessary to ensure the security and quality of services, achieve dispute resolution purposes, or when technically difficult to implement, we may extend the retention period within a reasonable scope after the expiration of the aforementioned retention period. After the retention period expires, we will delete your personal information or anonymize it in accordance with legal requirements.
6.2 Security Measures
a) We have implemented industry-standard security measures to protect the personal information you provide, to prevent unauthorized access, disclosure, use, modification, damage, or loss of data. We will take all reasonable and feasible measures to protect your personal information.
b) We have established dedicated management systems, processes, and organizations to safeguard the security of personal information. In the event of a security incident such as personal information leakage, damage, or loss, we will activate emergency response plans and take proactive measures to prevent the incident from escalating in accordance with legal requirements. We will promptly inform you of the basic details of the security incident, the actions we have taken or will take to address and remedy the situation, and provide advice on how you can respond, through notifications, emails, or other forms of communication. If individual notifications are impractical, we will issue warnings through announcements or other means.
7. How We Handle Children's Personal Information
Our products, websites, and services are primarily aimed at adults. Without the consent of parents or guardians, children should not create their own personal information subject accounts.
For cases where children’s personal information is collected with parental consent, we will only use or disclose this information when permitted by law, with explicit consent from parents or guardians, or when necessary to protect children. Under this policy, anyone under the age of 14 will be considered a child.
If we discover that we have collected personal information of children without prior verifiable parental consent, we will endeavor to promptly delete such data.
8. How this Policy is Updated
Our Privacy Policy may be updated from time to time.
Without your explicit consent, we will not reduce the rights you are entitled to under this policy. Any changes to this policy will be posted on this page. For significant changes, we will notify you through prominent pages of our products or services, or by sending you an email or other appropriate means of communication. If you do not agree with these changes, please stop using our products and services immediately.
The significant changes referred to in this policy include but are not limited to:
a) There have been significant changes in our service model, such as the purposes of processing personal information, types of personal information processed, and ways of using personal information;
b) There have been significant changes in our ownership structure, organizational structure, etc., such as changes in ownership resulting from business adjustments, bankruptcy, mergers, and acquisitions;
c) There have been changes in the main recipients of personal information sharing, transfer, or public disclosure;
d) There have been significant changes in your rights regarding the processing of personal information and how they are exercised;
e) There have been changes in the department responsible for handling personal information security, contact methods, and complaint channels;
f) When the personal information security impact assessment report indicates a high risk.
9. How to contact Stellar
If you have any questions, comments, or suggestions regarding this Privacy Policy, you can contact us via the following email: support@fileshow.com. We will respond within 15 days.
If you are not satisfied with our response, especially if our processing of personal information has harmed your legitimate rights and interests, you can also seek a solution by filing a lawsuit with a court with jurisdiction over the defendant's place of residence.
HK Stellar Cloud Services Limited