Bytello Account Privacy Policy

Last updated: October 18 , 2022

Thank you for registering Bytello Account! Bytello Account is a single sign-on authentication scheme for user 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 Share, 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 "Bytello", "we", "our", or "us" ), 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 your 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.

If you are under 16 or otherwise regarded as a minor in your jurisdiction, do not provide any personal data without your parent’s or guardian’s permission.

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

X. How This Policy is Updated

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. We 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 will 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 will also collect your country/region information, in order to ascertain where we would retain your personal data. 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 Share, Bytello DMS, etc., without re-registration for another account.

To be more specific, you can create account and log in Bytello Class, Bytello OS, Bytello Share via Bytello ID account system, and you can create account and log in Bytello DMS via Bytello User Center account system. When you create account and log in Bytello DMS via Bytello User Center account system, we will further collect your organization name, your organization region.

We may provide more Bytello services and products for you, and the name of the service or product as well as the way of the registering may be changed according to our business development, you could get the updated information by visiting our official website www.bytello.com.

(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 through Bytello dashboard (only apply to the use of Bytello ID account system), we will collect your Google/Microsoft account information, including your registered email address, profile photo, user name, email verification information, zoom account (if any), teams account (if any), for the sake of user identity verification. In no event shall we access or store your cloud storage resources unless at your command.

(4) When we conducting relevant promotional activities, such as providing marketing and promotional materials and updates, and conducting user research , we collect the email address that you consent to provide it to us. If you no longer wish to receive certain types of promotional materials, you may opt-out by the method provided in the message or via the account system unless otherwise specified under applicable laws. 

(5) For the sake of device management, we will 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.

(6) To ensure the normal operation of the Bytello Account and to improve and optimize your service experience, we will collect how you interact with Bytello dashboard, i.e., time and duration of your log-in, click-on, etc.

(7) We do not request or intend to collect any “special categories of information”, such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences or orientation. We also want to kindly remind you to be cautious when sharing this information about yourself (or others) in our Services.

(8)  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 will 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.

(9) 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 will 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:

•Microsoft Internet Explorer

•Microsoft Edge

•Mozilla Firefox

•Google Chrome

•Safari for macOS

•Safari for iOS

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 Cookie Notice.

III. How We Store and Retain Your Personal Data

1. How We Store Your Personal Data

The personal data we collect and generate in our operations in European Economic Area (EEA) is processed and stored in a third-party cloud storage located in Germany, except for cross-border transmissions permitted under the applicable law. 

The personal data we collect and generate in our operations in the United State is processed and stored in a third-party cloud storage located in the United State, except for cross-border transmissions permitted under the applicable law.

The personal data we collect and generate in our operations in the south-east Asian regions and countries is processed and stored in a third-party cloud storage located in Singapore, except for cross-border transmissions permitted under the applicable law.

2. How We Retain Your Personal Data

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.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.  

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 will 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 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.

If you are located in the European Economic Area (“EEA”), you may also object to the processing of your personal data for certain purposes:

8. Right to Withdraw Consent

If you agree 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

For the purposes described in the Privacy Policy, your personal data may be transferred to these data centers in accordance with applicable law. We may also transfer your personal data to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions. However, this does not change our commitment to comply with this Privacy Policy and to protect your personal data.

If we need to transfer personal data outside of your jurisdiction, whether to our affiliates or third-party service providers, we will comply with related applicable laws. We will take corresponding protective measures according to the requirements of applicable laws to ensure data security. 

If your personal data collected and generated in the European Economic Area is transferred to countries outside the European Economic Area, we will ensure that proper protective measures are taken to comply with General Data Protection Regulation (“GDPR”). 

For more information on protection measures on personal data in scenario of cross border data transfer, please contact us. 

X. How This Policy is Updated

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

Special Terms for United States

If you are using the Services in United States, the following additional terms apply. If any conflict arises between the main Privacy Policy, the following terms shall prevail: 

Minimum Age. In the United States, the minimum age for users is 13. We therefore do not knowingly collect any personal data from children under the age of 13 in the United States without parental consent, unless permitted by law. If we learn that a child under the age of 13 has provided us with personal data, we will delete it in accordance with applicable law.

California Consumer Privacy Act. For Users who are California residents, you have the following extra rights under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal data over the past 12 months.

You have the right to request that we delete your personal data that we collected from you, subject to certain exceptions.

We did not sell personal data and therefore did not process requests for opt-out of sale.

California “Shine The Light” Law. For users located in California, we do not share your personal data with third parties for those third parties’ direct marketing purposes. 

In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal data of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal data over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal data about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal data about an individual User’s online activities over time and across different online services when using the App.