超润贸易（上海）有限公司（以下简称为“我们”）作为Lubpur超润（网址：https://www.lubpur.com，以下简称为“平台”）的开发商和运营商，在此特别提醒您认真阅读、充分理解本《法律声明及隐私政策》（以下简称为“声明和政策”），请您审慎阅读。声明和政策系我们通过平台向您提供软件服务、信息披露服务、技术支持服务等（以下简称“服务”）的前提条件，声明和政策条款明确规定了您在使用服务或者进入平台并使用搜索查找、浏览、下载、收藏、邮件订阅、在线咨询等应用该平台上所公示的信息时应承担的义务或在某些特殊情形下所应负担的责任，除非您接受声明和政策所有条款，否则您无权注册、登陆或使用声明和政策所涉的任何服务。
本声明和政策努力描述了我们与您之间关于服务相关方面的权利义务。目前，我们的平台尚处于逐步完善各网站模块、改进网站各项功能、健全互联网行业领域特定信息的阶段，您登陆我们的平台并使用服务期间，我们将遵循本声明和政策所阐述的内容和方式，为您提供服务。您可以注册、登录、使用使用搜索查找、浏览、下载、收藏、邮件订阅、在线咨询等相关服务。我们将在本声明和政策中先行就拟开放的功能铺陈相应声明及政策，我们保证，该等行为将不影响您体验我们现有的各项服务，且不会侵犯您的任何合法权益。
我们会根据法律法规及其他情况变化在必要时修改服务条款或规则，服务条款一旦发生变动，将在平台上同步更新，请您及时关注和了解该变动。若您在修改条款发布之后继续使用服务的，即表示您同意且接受该等修改。在适用法律允许的最大范围内，我们保留对本声明和政策、操作规则或条款的最终解释权。
平台展示的所有内容，包括文字、图片、照片、音频、视频、软件、程序、以及页面版式设计等版权、著作权在内的所有权利归超润所有，任何媒体、公众号、个人及其他组织未经Lubpur超润授权不得转载、链接、转贴或以其他方式复制发布/发表。如任何媒体、公众号、个人及其他组织未经书面许可擅自使用平台所有内容的，平台及平台所有权人有权追究其侵权法律责任。
作为Lubpur超润的开发者（以下简称“我们”）深知个人信息对您的重要性，并会尽力保护您的个人信息安全可靠，我们致力于维持您对我们的信任，恪守以下原则，保护您的个人信息：权责一致原则，目的明确原则，选择同意原则，最少够用原则，确保安全原则，主体参与原则，公开透明原则等等。同时我们承诺，我们将按业界成熟的安全解决方案，采取相应的安全保护措施来保护您的个人信息。鉴此，我们制定本《隐私政策》（下称“本政策 /本隐私权政策”）并提醒您：
向您发送与我们与您的关系或产品/服务相关的重要信息、条款、条件、政策和/或其他行政信息的变更。为更好地回应您的个性化需求，我们将通过数据分析向您传递我们认为您可能感兴趣的产品或服务。
为确保网站正常运转、为您获得更轻松的访问体验、向您推荐您可能感兴趣的内容，我们会在您的计算机或移动设备上存储名为 Cookie 的小数据文件。Cookie 通常包含标识符、站点名称以及一些号码和字符。借助于 Cookie，网站能够存储您的偏好等数据。
除 Cookie 外，我们还会在网站上使用网站信标和像素标签等其他同类技术。例如，我们向您发送的电子邮件可能含有链接至我们网站内容的地址链接，如果您点击该链接，我们则会跟踪此次点击，帮助我们了解您的产品或服务偏好以便于我们主动改善客户服务体验。网站信标通常是一种嵌入到网站或电子邮件中的透明图像。借助于电子邮件中的像素标签，我们能够获知电子邮件是否被打开。如果您不希望自己的活动以这种方式被追踪，则可以随时向我们要求退订。
2、在涉及合并、收购或破产清算情形，或其他涉及合并、收购或破产清算情形时，如涉及到个人信息转让，我们会要求新的持有您个人信息的公司、组织继续受本政策的约束，否则我们将要求该公司、组织和个人重新向您征求授权同意。
根据法律规定，共享、转让经去标识化处理的个人信息，且确保数据接收方无法复原并重新识别个人信息主体的，不属于个人信息的对外共享、转让及公开披露行为，对此类数据的保存及处理将无需另行向您通知并征得您的同意。
（三）互联网并非绝对安全的环境，而且电子邮件、即时通讯、社交软件等与其他用户的交流方式无法确定是否完全加密，我们建议您使用此类工具时采用复杂密码，协助我们保证您的账号安全。我们将尽力保障您发送给我们的任何信息的安全性。
在不幸发生个人信息安全事件后，我们将按照法律法规的要求，及时向您告知：安全事件的基本情况和可能的影响、我们已采取或将要采取的处置措施、您可自主防范和降低风险的建议、对您的补救措施等。我们将及时将事件相关情况以应用程序推送、电子邮件、短信、电话等方式告知您，难以逐一告知个人信息主体时，我们会采取合理、有效的方式发布公告。同时，我们还将按照监管部门要求，上报个人信息安全事件的处置情况。
账户信息——您可以通过登录您在我们平台（“Lubpur超润”）注册的账户，访问您的Lubpur超润帐户中的个人资料信息，包括绑定手机号码、头像、我的客服、微信号、QQ号、地址、公司名称、公司地址、所属职位。具体操作路径为：首页—已登录。
在某些业务功能中，我们可能仅依据信息系统、算法等在内的非人工自动决策机制做出决定。如果这些决定显著影响您的合法权益，您有权要求我们做出解释，我们也将在不侵害我们及我们关联公司商业秘密或其他用户权益、社会公共利益的前提下提供申诉方法。
对于经父母或监护人同意使用我们的产品或服务而收集未成年人个人信息的情况，我们只会在法律法规允许、父母或监护人明确同意或者保护未成年人所必要的情况下使用、共享、转让或披露此信息。
随着法律法规的更新，以及平台的业务发展，我们可能适时更新本政策。但未经您明确同意，我们不会削减您依据本政策所享有的权利。我们会在网站、移动端等发布修订后的版本，并以适当的方式提醒您相关内容的变更。如该等更新造成您在本政策下权利的实质减少或重大变化，我们将通过设置弹窗提醒等方式再次取得您的同意。
LEGAL STATEMENT AND PRIVACY POLICY
Updated on: May 16, 2023
Special tips:
Lubpur Trading (Shanghai) Co., Ltd. (hereinafter referred to as "we") as lubpur (website: https://www.lubpur.com , hereinafter referred to as the "platform"), we would like to remind you to carefully read and fully understand this legal statement and privacy policy (hereinafter referred to as the "statement and policy"), please read it carefully.The statement and policy are the preconditions for us to provide you with software services, information disclosure services, technical support services, etc. (hereinafter referred to as "services") through the platform. The statement and policy terms clearly stipulate that you are using the service or entering the platform and using search, browse, download, collection, email subscription Online consultation and other obligations when applying the information publicized on the platform or responsibilities under certain special circumstances. Unless you accept all the terms of the statement and policy, you have no right to register, log in or use any services covered by the statement and policy.
This statement and policy strive to describe our rights and obligations with you in relation to the services. At present, our platform is still in the stage of gradually improving various website modules, improving various functions of the website and improving specific information in the field of Internet industry. During your landing on our platform and using the service, we will provide services for you in accordance with the contents and methods described in this statement and policy. You can register, log in, search, browse, download, collect, email subscribe, online consultation and other related services. In this statement and policy, we will first lay out the corresponding statements and policies on the functions to be opened. We guarantee that such acts will not affect your experience of our existing services and will not infringe on any of your legitimate rights and interests.
We will modify the terms of service or rules when necessary according to laws, regulations and other changes. Once the terms of service are changed, they will be updated synchronously on the platform. Please pay attention to and understand the change in time. If you continue to use the service after the publication of the modified terms, you agree to and accept the modification. To the maximum extent permitted by applicable laws, we reserve the right of final interpretation of this statement and policies, operating rules or terms.
Basic rules for using services
1.During the use of the service, you shall abide by national laws, regulations and other normative documents and our rules and requirements, shall not endanger network security, do not violate social public interests or public morality, do not make reactionary remarks, and shall not use our service to engage in activities that infringe upon others' reputation, privacy, intellectual property rights and other legitimate rights and interests. If there are any legal consequences, you will bear the corresponding legal liabilities.
2. You promise that in order to maintain the objectivity and authenticity of the service, you shall not use the service to commit any act against integrity, including but not limited to illegal business; Participate in or organize the writing and release of false information in order to obtain benefits or benefits; Conduct other violations that affect the authenticity, objectivity and normal order of the service.
3. You should use the content in the service at your own discretion and bear all risks arising from the use of the content, including those arising from reliance on the correctness, integrity or practicability of the content. We shall not be liable for any loss or damage caused by your use of the services mentioned above.
4. You must be responsible for the authenticity, legality and validity of the information transmitted. Any legal liability related to the information transmitted by you shall be borne by yourself, which has nothing to do with us.
5. If we open the user account registration and background system management functions, you should abide by laws and regulations, and register and use the account according to our instructions. You should carefully and reasonably use and properly keep your account and password, and be responsible for the actions and events under your account and password. When you find that the service account is used by an unauthorized third party or there are other account security problems, you should immediately notify us and request us to suspend the service of the service account and properly solve it through legal procedures.
We have the right to take action on your request within a reasonable time, but we are not responsible for the losses you have suffered before taking action. Without our consent, you shall not dispose of the service account to others by gift, loan, lease, transfer or other means, otherwise you shall continue to be fully responsible for the behavior of the actual user of the account.
6. We will unilaterally terminate the provision of all or part of the services under this statement and policy at any time according to our own business development needs without prior notice to you.
If you subscribe to us by email, you agree that we will push product information, special offers, suggestions and guides for you from time to time.
Copyright notice
All rights and copyright rights including all the contents of the platform, including text, pictures, photos, audio, video, software, programs, and page layout, are owned by Lubpur. Any media, official account, individual and other organizations can not be reproduced, linked, posted or copied in other ways without Lubpur authorization. If any media, official account, individual or other organization has used all contents of the platform without written permission, the owner of the platform and platform shall have the right to investigate its tort liability.
Privacy policy tips
As the developer of lubpur (hereinafter referred to as "we"), we know the importance of personal information to you and will try our best to protect your personal information. We are committed to maintaining your trust in US and abide by the following principles to protect your personal information: the principle of consistent rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of minimum sufficiency and the principle of ensuring security, The principle of subject participation, the principle of openness and transparency and so on. At the same time, we promise that we will take corresponding security protection measures to protect your personal information according to the mature security solutions in the industry. In view of this, we formulate this Privacy Policy (hereinafter referred to as "this policy / this Privacy Policy") and remind you:
This policy applies to the products or services we provide. If the products or services provided by us are used in the products or services of our affiliated companies (e.g. login directly with an account), but there is no independent privacy policy, this policy is also applicable to this part of products or services.
It should be noted that this policy is not applicable to the services provided to you by other third parties, nor to the products or services for which we have separately set the privacy policy.
Before using the products or services we provide, you must carefully read and thoroughly understand this policy, and use the relevant products or services after confirming your full understanding and consent. Once you start using our products or services, you fully understand and agree to this policy. If you have any questions, comments or suggestions on the contents of this policy, you can contact us through various contact methods provided by us, such as email（ advise@lubpur.com ）Wait.
This privacy policy will help you understand the following:
1. How we collect and use your personal information.
2. How do we use cookies and similar technologies.
3. How do we share, transfer and publicly disclose your personal information.
4. How we protect your personal information.
5. How do you manage your personal information.
6. How do we deal with minors' personal information.
7. How your personal information is transferred around the world.
8. How this privacy policy is updated.
9. How to contact us.
1、 How do we collect and use your personal information
Personal information refers to all kinds of information recorded electronically or in other ways that can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or in combination with other information.
1） How do we collect your personal information
Personal information involved in this policy includes: personal basic information (including name, company name, company address, personal avatar, wechat, QQ number, contact telephone, contact address and e-mail); Network identity information (including platform account, IP address and password and password related to the above); Online records (including download records, browsing / caching records, collection records, software use records, access records and frequency); Personal property information (including transaction information, flow records and points information); Other personal information (including personal location information, voice information, pictures, customer service consultation records).
1. The information you provided us
Relevant personal information provided to us when you register your account or use our services, such as telephone number, e-mail, company name, etc;
The shared information you provide to others through our services and the information stored when you use our services. Before providing us with the above-mentioned personal information of the other party, you need to ensure that you have obtained its authorization and consent, otherwise you will bear all adverse consequences, including tort liability.
2. Information we collect when you use a product or service
When you use our products or services, the system may automatically collect relevant information through cookies, such as your web browser information, cache records, etc.
（2） How do we use your personal information
1. Help you become our user
2. Provide you with personalized goods or services
Send you changes to important information, terms, conditions, policies and / or other administrative information related to our relationship with you or products / services. In order to better respond to your personalized needs, we will pass you products or services we think you may be interested in through data analysis.
3. Data analysis
For data analysis to enhance, improve or improve our platform or products and services and help us develop new products and services.
Please understand and agree that we will analyze the user database and make commercial use of the user database without disclosing your personal information. Unless you delete or refuse us to collect through system settings, all personal information you provide will continue to authorize us to use it during your use of our products or services.
When we use the 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.
Exceptions with authorized consent
According to relevant laws and regulations, your authorization and consent are not required for the collection, use and disclosure of your personal information under the following circumstances:
1. Related to national security and national defense security;
2. Related to public safety, public health and major public interests;
3. Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and judgment execution;
4. For the purpose of safeguarding the life, property and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain your own consent;
5. The personal information collected is disclosed to the public by yourself;
6. Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
7. Necessary to sign the contract according to your requirements;
8. It is necessary to maintain the safe and stable operation of the provided products or services, such as finding and handling the faults of products or services;
9. Necessary for legitimate news reporting;
10. When an academic research institution is necessary to carry out statistics or academic research based on the public interest and provides the results of academic research or description to the outside world, it de identifies the personal information contained in the results;
11. Other circumstances stipulated by laws and regulations.
If we stop operating websites, products or services, we will stop collecting your personal information in time, notify you of the notice of stopping operation in the form of delivery or announcement one by one, and delete or anonymize the personal information held.
2、 How do we use cookies and similar technologies
（1） Cookies
In order to ensure the normal operation of the website, provide you with an easier access experience and recommend content you may be interested in, we will store a small data file named cookie on your computer or mobile device. Cookies usually contain identifiers, site names, and numbers and characters. With cookies, websites can store data such as your preferences.
（2） Website beacons and pixel Tags
In addition to cookies, we will also use other similar technologies such as website beacons and pixel labels on the website. For example, the email we send you may contain an address link linked to the content of our website. If you click the link, we will track this click to help us understand your product or service preferences so that we can actively improve the customer service experience. A website beacon is usually a transparent image embedded in a website or e-mail. With the help of pixel labels in e-mail, we can know whether the e-mail is opened or not. If you don't want your activities to be tracked in this way, you can ask us to unsubscribe at any time.
3、 How do we share, transfer and publicly disclose your personal information
(1) Share
We will not share your personal information with companies, organizations and individuals other than service providers, except in the following cases:
1. Sharing with explicit consent: after obtaining your explicit consent, we will share your personal information with other parties;
2. Sharing under legal circumstances: we may share your personal information according to laws and regulations, litigation and dispute resolution needs, or according to the requirements of administrative and judicial organs according to law;
3. Sharing with affiliated companies:in order to facilitate us to jointly provide services to you based on the affiliated account, recommend information you may be interested in, or protect the personal and property safety of our affiliated companies or other users or the public from infringement, your personal information may be shared with our affiliated companies. We will only share the necessary personal information (for example, we will share your necessary account information with the affiliated company in order to facilitate your login account to use the products or services of our affiliated company). If we share your personal sensitive information or the affiliated company changes the purpose of using and processing your personal information, we will ask your authorization and consent again;
4. Share with authorized partners:some of our services will be provided by us and authorized partners only for the purposes stated in this privacy policy. We may share some of your personal information with our partners to provide better customer service and user experience. For example, arrange for partners to provide services. We will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and will only share the personal information necessary to provide services. Our partners have no right to use the shared personal information for other purposes unrelated to products or services.
Currently, our authorized partners include the following types:
(1) Authorized partners in advertising and analysis services.
(2) Suppliers, service providers and other partners.
For companies, organizations and individuals with whom we share personal information, we will sign strict data protection agreements and require them to handle personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.
（2） Transfer
We will not transfer your personal information to any company, organization or individual, except for the following circumstances:
1. Transfer with explicit consent: after obtaining your explicit consent, we will transfer your personal information to other parties;
2. In case of merger, acquisition or bankruptcy liquidation, or other situations involving merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require the new company and organization holding your personal information to continue to be bound by this policy, otherwise we will require the company, organization and individual to ask you for authorization and consent again.
（3） Public disclosure
We will only publicly disclose your personal information under the following circumstances:
1. We may publicly disclose your personal information with your express consent or based on your active choice;
2. If we determine that you have violated laws and regulations or seriously violated our relevant policies and rules, or in order to protect the personal and property safety of users or the public of our website and its affiliates, we may disclose your personal information in accordance with laws and regulations or our relevant policies and rules, Including relevant violations and measures taken against you by our website.
According to the law, sharing and transferring personal information that has been de identified, and ensuring that the data receiver cannot recover and re identify the subject of personal information, does not belong to the external sharing, transfer and public disclosure of personal information, and the storage and processing of such data will not need to be notified to you and obtain your consent.
4、 How do we protect your personal information
（1） We have taken reasonable and feasible security measures in line with the general solutions in the industry to protect the security of the personal information you provide and prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information.
（2） We will take reasonable and feasible measures to try our best to avoid collecting irrelevant personal information. We will only retain your personal information for the period required to achieve the purpose stated in the cost policy, unless the retention period needs to be extended or permitted by law.
（3） The Internet is not an absolutely secure environment, and it is uncertain whether email, instant messaging, social software and other communication methods with other users are fully encrypted. We recommend that you use complex passwords when using such tools to help us ensure the security of your account. We will try our best to ensure the security of any information you send us.
After an unfortunate personal information security incident, we will timely inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce risks, and the remedial measures for you in accordance with the requirements of laws and regulations. We will timely inform you of the relevant information of the event by means of application push, e-mail, SMS, telephone, etc. when it is difficult to inform the personal information subject one by one, we will take a reasonable and effective way to publish the announcement. At the same time, we will also report the disposal of personal information security incidents in accordance with the requirements of regulatory authorities.
5、 How do you manage your personal information
You can access and manage your personal information in the following ways:
（1） Access your personal information
You have the right to access your personal information, except for exceptions provided by laws and regulations. You can access your personal information by yourself in the following ways:
Account information - you can access the personal information in your lubpur account by logging in to your account registered on our platform ("lubpur"), including binding mobile phone number, avatar, my customer service, wechat, QQ number, address, company name, company address and position. The specific operation path is: Home Page - logged in.
Publish purchase requirements - you can propose purchase requirements to the platform. The specific operation path is: Home Page - personal Center - purchase message.
Dynamic information - you can query your footprints, your collections and your published purchase needs through relevant pages. The specific operation path is: Home Page - personal Center - my collection / my footprints / my purchase panel.
If you cannot access such personal information through the above path, you can contact us at any time through our customer service.
（2） Correct or supplement your personal information
When you find that there are errors in your personal information processed by us, you have the right to ask us to make corrections or supplements.
（3） Delete your personal information
You can delete some of your personal information by the methods listed in "(I) access to your personal information" in this article.
You can request us to delete your personal information in the following cases:
1. If our handling of personal information violates laws and regulations;
2. If we collect and use your personal information without your explicit consent;
3. If our handling of personal information seriously violates the agreement with you;
4. If you no longer use our products or services, or you voluntarily cancel your account;
5. If we never provide you with products or services.
If we decide to respond to your deletion request, we will also notify the subjects who obtain your personal information from us as much as possible and require them to delete it in time, unless otherwise provided by laws and regulations or these subjects have obtained your independent authorization.
（4） Change the scope of your authorization and consent
Each business function needs some basic personal information to be completed. In addition, for the collection and use of additional personal information, you can contact us to give or withdraw your authorization consent.
When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous personal information processing based on your authorization.
（5） Personal information subject cancels account
You can submit an account cancellation application by contacting us by email: advise@lubpur.com .
After you voluntarily cancel your account, we will stop providing you with products or services, delete your personal information or anonymize it according to the requirements of applicable laws.
（6） Automatic decision making of constraint information system
In some business functions, we may only make decisions based on non manual automatic decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for explanation, and we will also provide appeal methods without infringing on the trade secrets or other user rights and interests of us and our affiliated companies and the social and public interests.
（7） In response to your above request
For security, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.
We will not be able to respond to your request in accordance with laws and regulations in the following cases:
1. Related to national security and national defense security;
2. Related to public safety, public health and major public interests;
3. Related to criminal investigation, prosecution, trial and execution of judgment;
4. There is sufficient evidence to show that the subject of personal information has subjective malice or abuse of rights;
5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations;
6. Involving trade secrets.
6、 How do we handle personal information about minors
Minors may not create their own user accounts without the consent of their parents or guardians. If you are a minor, it is recommended that you ask your parents or guardians to carefully read this Privacy Policy and use our services or provide information to us with the consent of your parents or guardians.
In the case of collecting personal information of minors by using our products or services with the consent of parents or guardians, we will only use, share, transfer or disclose this information if permitted by laws and regulations, expressly agreed by parents or guardians or necessary to protect minors.
7、 How does your personal information move around the world
Personal information collected and generated during our operations in the people's Republic of China is stored in China, except for the following circumstances:
1. There are clear provisions in laws and regulations;
2. Obtain your explicit authorization;
3. You conduct cross-border live broadcasting / dynamic release and other personal initiatives through the Internet.
In view of the above circumstances, we will ensure that your personal information is adequately protected in accordance with this privacy policy.
8、 How is this Privacy Policy updated
With the update of laws and regulations and the business development of the platform, we may update this policy from time to time. However, we will not reduce your rights under this policy without your express consent. We will publish the revised version on the website and mobile terminal, and remind you of the changes of relevant contents in an appropriate way. If such updates result in a substantial reduction or significant change in your rights under this policy, we will obtain your consent again by setting pop-up reminders, etc.
After the policy is updated, if you continue to use our website, application or service, you agree to be bound by the updated policy. Unless otherwise specified, this policy and the updated version of this policy shall take effect from the date of issuance.
9、 How to contact us
If you have any questions, comments or suggestions about this policy, you can contact us through the following ways:
Email: info@lubpur.com (business cooperation)
advise@lubpur.com (complaints and suggestions)
Landline telephone: 021-20247731
Emergency handling: 13636625873 (Marketing Department)
Business cooperation: info@lubpur.com
Landline telephone: +8621-20247731
Emergency handling: +86 13636625873 (Marketing Department)
Legal Affairs: Lubpur Trading (Shanghai) Co., Ltd. authorizes Shanghai Zhengchuanben Law Firm to provide full legal support.
Contact lawyer: 13917036104
