Digital Dunhuang Privacy Policy
Welcome to the Dunhuang Academy Digital Dunhuang (hereinafter referred to as “we”)! In order to protect the privacy of users and optimize user experience, Dunhuang Academy has formulated the Dunhuang Academy “Digital Dunhuang” Privacy Policy (hereinafter referred to as “this Policy”/“this Privacy Policy”) in accordance with relevant existing laws, regulations and policies. This Policy details Digital Dunhuang's rules for handling personal information and helps users fully understand Digital Dunhuang's policies and practices with respect to the collection, use, disclosure, storage and protection of users’ personal information. This Policy applies to all products and services on the Digital Dunhuang platform.
In order to protect your rights, please read, understand and agree to the terms of this Policy prior to using Digital Dunhuang.
Your acceptance of this Privacy Policy means that you understand the necessary personal information required by Digital Dunhuang and that you have granted us the right to collect and use such information. However, if the processing of personal information requires your separate consent under relevant laws and regulations, we will seek your consent depending on the actual situation.
If you have any questions, comments or suggestions about this policy, you can contact us via the contact information provided at the end of this Policy.
I. Collection of Personal Information
On the principle of legitimacy, fairness, necessity and good faith, we will collect only the following personal information necessary for you to properly use Digital Dunhuang.
1. Personal information that you voluntarily submit when using Digital Dunhuang
(i) The personal information you fill in when registering your account
E.g., your name, mobile phone number, email address, security questions and answers, etc. that you provided.
(ii) Personal information you submit via our staff or when you participate in our events
E.g., the survey questionnaire that you fill out may contain your name, mobile phone number, e-mail address, mailing address, etc.
(iii) Sensitive personal information that you voluntarily submit
When you become our customer, user or partner, or when you need to use certain Digital Dunhuang features , you may be required to submit specific sensitive personal information, such as your ID number, occupation, employer, work samples, award certificates or third-party login information, etc.
If you elect not to submit such information, you may not be able to use some or certain Digital Dunhuang features, but it will not affect your ability to use other Digital Dunhuang features.
Your voluntary submission of your sensitive personal information will mean that you consent to our processing of such information for the purposes and in the manner described in this Policy.
(iv) Third-party information that you voluntarily submit
If the information you submit contains the personal information of any third party, you need to ensure that you have obtained valid authorization from such third party prior to submitting the information.
2. Information we obtain when you use Digital Dunhuang
(i) Log information
When you use Digital Dunhuang, we may automatically collect and store relevant log information.
(ii) Device information
E.g., the device model, operating system version, and unique device identifier with respect to your use of Digital Dunhuang.
(iii) Software information
E.g., version number and browser type. We may collect information regarding the mobile applications and other software that you use in order to ensure the security of the operating environment or as necessary to provide licensed materials.
(iv) IP address
The Internet Protocol (IP) address is a number for each device that accesses the Internet.
(v) Location information
We may record information regarding the location of your device with which you use Digital Dunhuang in order to provide you with relevant services.
(vi) Usage information
E.g., search and query records and data that you generate when you use Digital Dunhuang.
3. Information you provide when you become our partner
The personal information that you provide to us when we cooperate or conduct a transaction with you under an agreement or other arrangement, such as the agreement for authorization and use of image data.
4. Information we obtain from third-party partners
We may obtain the information that you provide or generate when using the products and services of third-party partners. Please read the third-party partner's privacy policy carefully.
5. Information that has been disclosed by state power agencies, administrative agencies, judicial agencies, procuratorial agencies, public security agencies, supervisory agencies, autonomous agencies, military commissions and other state agencies.
Personal information contained in the information that is disclosed, published, and released by state agencies by operation of law, such as judicial cases, similar case searches, and law journal articles.
In order to balance the public interest and the privacy of individuals related to the information disclosed, published and released by state agencies by operation of law, we will, when necessary, establish processes and take measures to further protect your personal information and privacy contained therein.
II. Use of Personal Information
We will strictly abide by relevant laws and our agreements with customers and users, and use the collected information to:
1. Provide you with image licenses
For example, registration is required to view, download, and use certain Digital Dunhuang features.
2. Meet your individualized needs
For example, language choice, personalized subscription service.
3. Recommend data and information that may be of interest to you
E.g., recommend relevant data and information to you based on your occupation.
4. Evaluate, iterate, and update our products and services
E.g., the type, frequency, failure information, and performance data with respect to your use of Digital Dunhuang's products and services,.
5. Ensure security
E.g., we will use your information for identity authentication.
If we use your information for purposes other than those listed above, we will explain the use again to you and obtain your consent. Digital Dunhuang will not disclose your personal information to any third party without your permission, except under the following circumstances:
(i) Digital Dunhuang has obtained authorization from you or your guardian;
(ii) The information is related to our performance of obligations stipulated by laws and regulations;
(iii) Judicial or administrative authorities require disclosure by Digital Dunhuang in line with relevant legal processes;
(iv) Digital Dunhuang initiates a lawsuit or arbitration against the user to protect its own legitimate rights and interests;
(v) The disclosure is made in accordance with the relevant Terms of Service and Application License Agreement between you and Digital Dunhuang;
(vi) Personal information that you disclose to the public on your own; or the personal information legitimately collected from public information, such as legitimate news reports, information disclosed by the government, etc.;
(vii) Other circumstances as set forth in relevant laws and regulations.
III. Sharing and Disclosure of Personal Information
We will abide by relevant laws and will not share or disclose your personal information to the public, except under the following circumstances:
1. Prior consent
With your prior consent, we may share your personal information with third parties.
2. Share information that has been processed
We may share anonymized, de-identified or desensitized information with third-party partners. We will not share with any third party the information that can be used to ascertain your identity (such as your name or email address) unless you agree or authorize us to do so.
We will require the third party to strictly abide by our data protection measures and instructions, including but not limited to processing data in compliance with data protection agreements, letters of undertaking and relevant data processing laws and policies, in order to avoid identification of individuals and safeguard data security.
Such sharing is mainly used to:
(i) Provide you with our products and services.
(ii) Achieve the purposes described in the “Use of Personal Information” section.
(iii) Fulfill our obligations and exercise our rights under this Policy.
(iv) Evaluate, iterate, and update our products and services.
3. Mergers and acquisitions
As our business grows, we may transfer your personal information in the event of a merger, acquisition, transfer of assets, etc., in which case, we will inform you of the circumstances through push notifications, announcements, etc., and continue to protect or require new administrators to continue to protect your personal information in accordance with the relevant laws and regulations and the standards no less than those specified in this Policy.
4. We will use the collected information for big data analysis
E.g., we may use the information to formulate a big data analysis report for certain types of materials that do not contain personal information, and make such report publicly available.
We may disclose and share statistically processed, non-personally identifiable information with our partners to understand how our customers and users use Digital Dunhuang or to inform the public regarding Digital Dunhuang’s overall situation.
5. We may disclose your personal information as required by applicable laws or legal proceedings to:
(i) Comply with applicable laws, regulations and other relevant rules.
(ii) Comply with court decisions, rulings or other legal proceedings.
(iii) Comply with the requirements of relevant government agencies or other legally authorized organizations.
(iv) Protect public interests and other legitimate rights and interests.
(v) Protect, to the extent necessary and reasonable, life, health and property or other legitimate interests in an emergency.
6. We do not need your consent prior to collecting and using your personal information under the following circumstances:
(i) The information is related to national security and national defense security;
(ii) The information is related to public security, public health or major public interests;
(iii) The information is related to criminal investigation, prosecution, trial and execution of judgment;
(iv) The information is for the purpose of protecting the life, property or other important legitimate rights and interests of the data owner or other individuals, and it is difficult to obtain the consent of the data owner;
(v) The personal information is disclosed to the public by the owner of such information.
(vi) Your personal information is collected from legally disclosed information, such as legal news reports, information disclosed by government, etc.;
(vii) The information is necessary for executing the contract according to your requirements;
(viii) The information is necessary to maintain the safe and stable operation of the products and/or services, such as discovering and handling the failure of the products and/or services;
(ix) The information is necessary for legitimate news reports;
(x) The information is necessary for academic research institutions to carry out statistical or academic research based on public interests, provided that the personal information contained in the results thereof disclosed to the public is not personally identifiable.
IV. Protection of Personal Information
We will provide appropriate security safeguards for your information to protect it from loss, misuse, unauthorized access or disclosure.
We will take various measures to the extent reasonable to ensure the security of the information.
We will establish special management systems, processes and organizations to ensure the security of the information. E.g., we will strictly limit the scope of people who have access to the information, require them to abide by confidentiality obligations, and review their performance.
In the event of a personal information breach or other security incident, we will activate an emergency response plan to prevent deterioration of the incident and inform you via push notifications, announcements, etc.
We will make every effort to protect the personal information we obtain from our users. In order to prevent unauthorized access, reproduction, modification, transmission, loss, destruction, handling or use of your personal information, Digital Dunhuang will continue to take the following measures to protect your personal information.
(i) Encrypting the user's personal information in an appropriate manner.
(ii) Using passwords at appropriate locations to protect users' personal information.
(iii) Restricting access to users' personal information.
(iv) Other reasonable measures.
Although we take reasonable and effective measures described above and comply with the standards specified by relevant laws and regulations, we cannot guarantee the security of your personal information when it is communicated via insecure channels. Therefore, users shall take active measures to ensure the security of their own personal information, such as regularly changing account passwords and not disclosing such passwords and other personal information to others. If you are aware that your personal information, especially your account number and password, has been divulged, please contact us immediately via the contact information listed at the end of this Policy so that we can take appropriate measures.
Please note that the protective measures for the personal information provided by Digital Dunhuang apply only to Dunhuang Academy's Digital Dunhuang platform. Once you leave Digital Dunhuang, browse or use other platforms, services or contents, we have no ability or obligation to protect any personal information you submit on the Digital Dunhuang platform, regardless of whether you accessed or browsed the aforementioned platforms via link or leads provided by Digital Dunhuang.
V. Location and Duration of Personal Information Storage
1. Location of Personal Information Storage
We will abide by the relevant laws and regulations and store in China the personal information we collect in China.
2. Duration of Personal Information Storage
In general, we will store your personal information only for the shortest time necessary to achieve relevant purposes. However, we may, in accordance with relevant legal requirements, change the storage time of your personal information to:
(i) Abide by applicable laws and regulations.
(ii) Abide by court decisions, rulings or other legal proceedings.
(iii) Abide by the requirements of relevant government agencies or other legally authorized organizations.
(iv) Protect public interests and other legitimate rights and interests.
(v) Protect, to the extent necessary and reasonable, life, health and property or other legitimate interests in an emergency.
In the event Digital Dunhuang ceases operation, we will notify you within a reasonable period of time via push notifications, announcements, etc., and delete, anonymize or desensitize your personal information.
VI. Use of Digital Dunhuang's Identifier and Technical Measures
To ensure the proper functioning of the networks and processes in respect of the products and services we provide, we, or our third-party partners, may collect information about your access preferences and setting preferences in using Digital Dunhuang via security-related identifiers, web beacons, pixel tags and other similar technologies, to improve your experience and provide you with more individualized services.
VII. Digital Dunhuang Push Notifications
1. Push notifications
When you use Digital Dunhuang, we may send you emails, messages, information or push notifications.
You may elect to cancel the push notifications on your device by following our relevant prompts.
2. Announcements related to Digital Dunhuang
We may issue announcements related to Digital Dunhuang when necessary (e.g., in case of system updates).
You may not be able to cancel the announcements that are not advertisements.
VIII. Protection of Minors
We attach great importance to the protection of the personal information of minors.
If you are a minor, we recommend that you read this Policy together with your parent or other guardian(s). If you are a child under the age of 14, you shall read this Policy carefully with your parent or other guardian(s) prior to using Digital Dunhuang, and, subject to their consent to this Policy, you may use Digital Dunhuang safely under their guidance. We will fulfill our obligations to protect the information of minors strictly in accordance with relevant laws and regulations and will only use the information collected with the consent of their guardians to the extent permitted by law or as necessary to protect the interests of minors.
If you have any questions or claims with regard to the protection of the personal information of you or the minor in your custody, please contact us via the contact information listed at the end of this Policy, and we will address the issues and respond within a reasonable timeframe.
IX. User Personal Information Management
When using Digital Dunhuang, you may access, modify and delete the personal information you provide, or you may request us to do so via the contact information set forth in this Policy. The scope and manner in which you can access, modify and delete your personal information will depend on the specific products and services you use.
We will collect and use your personal information solely for your normal use of Digital Dunhuang as described in this Policy. If you find that we have violated applicable laws or agreements in collecting or using your personal information, you may request us to delete such information.
If you are aware that the personal information we have collected and stored about you is incorrect, you may also request us to correct it.
Please contact us via the contact information listed at the end of this Policy.
In the event that you request access to, modify and delete relevant information, we may ask you to verify your identity for security purposes.
Please understand that due to legal/regulatory requirements or technical limitations, we may not be able to fulfill all of your requests. We will respond to your requests within a reasonable timeframe.
X. Changes to this Privacy Policy
We may modify the provisions of this Policy from time to time.
If such modifications or changes materially impair your rights under this Policy, we will, prior to the effectiveness thereof, notify you by prominently displaying a notice on the web page or sending you a message.
In such cases, your continued use of Digital Dunhuang will constitute your consent to our updated Privacy Policy.
XI. Scope of Application of this Privacy Policy
This Policy applies to all of our products and services.
Please note that this Policy does not apply to the products and services provided by other companies or individuals. Your use of such third party's products and services shall be subject to their privacy policies (and not this Policy).
XII. Contact
If you have any questions about this Policy or other related matters, please write us at ip@dha.ac.cn and we will respond as soon as possible.