RBA Voices Privacy Policy

Latest Update：June 22th, 2022

Welcome to RBA Voices!

RBA Voices is a social networking service provided by Responsible Business Alliance Financial Consulting Suzhou Co., Ltd. (with its Address at Room 1910, South Building, Suyue Plaza, No.119 west Suzhou Avenue, Suzhou Industrial Park, Suzhou city, Jiangsu Province China, hereafter refer to as “We” or “Us”).

1. Before you start using our products and services, it is important that you read and understand this Privacy Policy (“Policy”) carefully, with particular emphasis on our bold terms and conditions to ensure that you fully understand and agree to them before you start using them.

2. In order to provide you with the services you have chosen to use, or to ensure the quality and experience of the services, you may be required to authorize the granting of operating system privileges. If you do not agree to authorize RBA Voices to obtain the relevant operating system permissions, you may not be able to access the user experience provided to you by the additional services.

3. Whilst using some features, we will collect your sensitive information (the details thereof refer to as below) after obtaining your consent. Unless it is required by the relevant laws and regulations to collect such information, refusing to provide such information will only result in your not being able to use the specific functions relating to such information, but does not affect your normal use of other functions of RBA Voices.

4. In accordance with this Policy, in order to collect your information, or provide service to you, optimize our service and protect the security of your account, we will require relevant permissions from you; sensitive permissions such as contact, precise geographical location, camera, microphone, photo album, etc., will be disabled by default and will only be enabled if you give us your express consent.Before logging into the account, you can choose to allow RBA Voices to take photos, record videos, obtain geolocation information, access photos, media content, files on your device and device information, or refuse authorization. If you refuse authorization, we will not be able to provide you with the functions that require such authorization. You may also decide to turn off the corresponding permission after granted.

5. At present, unless otherwise stipulated in this Policy, RBA Voices will not actively share or transfer your personal information to any other third parties outside of Responsible Business Alliance Financial Consulting (Suzhou) Co., Ltd.. Where the sharing or transferring of your personal information arises in some other situation or you require us to share or transfer your personal information to a third party outside of us or other entities provided in this Policy, we will directly obtain, or verify the third party has obtained your prior express consent to such share or transfer of your personal information. In addition, we will evaluate the risks of such sharing or transferring.

6. At present, RBA Voices will not actively obtain your personal information from a third party outside of Responsible Business Alliance Financial Consulting (Suzhou) Co., Ltd.. If there is a requirement to obtain your personal information indirectly from a third party for future business development purposes, we will clarify with you the source, type and scope of such personal information. For example, if the processing of personal information for a specific development is beyond the scope of what you originally agreed to provide to a third party, we will obtain your prior express consent before processing your personal information, and we will strictly abide by the relevant laws and regulations and require that the third party guarantees the legitimacy of the information provided.

7. You can access, correct and delete your personal information through the instructions listed in this Policy, and you can also withdraw your consent, cancel your account, report complaints.

8. This Policy applies to RBA Voices services provided by Responsible Business Alliance Financial Consulting (Suzhou) Co., Ltd., its affiliate and subsidiary companies and joint venture (“RBA Services”, as provided by our software). However, this Policy does not apply to any third party’s service provided by any third party through RBA Voices (collectively referred to as "Third Party Service"). Before choosing to use any Third Party Service, please read and fully understand the Third Party Service’ product function and privacy policy.

9. We may revise this Policy in due course. In the event where the terms of this Policy are amended, we will show you amended Policy by way of push notifications, pop-up windows or other suitable ways when you log in and when the APP version has been updated.

10. If you have any concerns, opinion or suggestion regarding any content of this Policy, you can contact us through the various contacts provided in this Policy.

This part will help you understand the followings:

1. Usage Information

We may collect information that you submit or generate when you use the RBA Services, and information submitted or generated by you as an end user of RBA Voices business or organizational users when using the RBA Services. If you use RBA Voices to chat (including participating in topic discussions, group chats, or answering questions), we need to record your chat information and voice call status information (not the content of the call) to enable the transfer and interaction of information. If you need us to recommend contacts in your cell phone address book who logins with RBA Voices so that you can add friends or colleagues, you need to authorize us to access and collect your cell phone address book information; in "People you may know", we may recommend friends for you based on your friend relationship, organization relationship, your interaction behavior with other users, etc. We will record your annual leave, provident fund, salary and other entitlements as requested by the company you work for. In order to record such entitlements, we will be commissioned by the company you work for to record the necessary information, such as the date your salary is paid, the number of days of attendance, and technical allowances.
You can post information publicly through the Q&A, comments and other information posting functions we provide for you, including posting graphics/video/content, links, posting comments and replies as a user of RBA Voices. When you follow other users or accounts, we will show you the content of the corresponding content publisher, and when you post, comment, like, retweet or recommend, we will collect your aforementioned information and show the corresponding content for your friends.
Please note that the information you post publicly may contain personal information or even personally sensitive information about you or others, such as pictures you choose to upload containing personal information when you post comments. Please consider more carefully when using our services.
We may provide you with information about new features of RBA Voices when you access or use it. we collect and use your browsing information (including information such as clicks, follows, favorites, searches, shares, posts, likes, comments, etc.), device information (such as device model, operating system version, device settings, MAC address and hardware and software such as IMEI, IDFA, OAID device identifier, etc.), network information (including IP address, browser type, telecommunication carrier, language of use, date and time of access), basic information you submit and information about you in the company you work for (e.g. industry, role).

2. Device Information

In order to provide you with our services and for security purposes, we will receive and record information about the devices you use according to the specific permissions you grant during the installation and use of the software (e.g., device model, operating system version, device settings, unique device identifier and other information of software and hardware features) and the location of such device (e.g., IP address, GPS/Triones location information and Wi-Fi access points capable of providing relevant information, Bluetooth, base station and other sensor information).

3. Log Information

When you use RBA Services, we will automatically collect the details of your use of our Services and keep them as relevant web logs, such as the content you search, IP addresses, types of browsers, telecommunication service providers, languages, visit dates and times, web pages you visited, your approval log information, attendance log information, payment information, office payment information and other operation log information.
Please note that information such as device information or log information alone cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person or use it in combination with personal information, such non-personal information may be treated as personal information during the period of combined use, and we will anonymize, de-identify such personal information unless we obtain your authorization or unless otherwise required by laws or regulations.

4. Data Controlled by Enterprise Organization

If you, as a company administrator of RBA Voices, choose to open and manage the services provided by RBA Voices, we will record the information and data submitted or generated in the process of using the relevant functions/applications of RBA Voices as an individual user of RBA Voices as directed by the company administrator in RBA Voices (hereinafter referred to as "Data Controlled by Enterprise Organization").
You understand and agree that the enterprise organization user is the controller of the data controlled by the above-mentioned enterprise, and we only open, manage and use the above-mentioned application services to process the data controlled by the enterprise organization of RBA Voices or your personal information according to the instructions of the administrator of the enterprise organization user. Before uploading personal information such as intelligent personnel information and external business contact information, the enterprise organization user shall ensure that it has obtained the prior express consent of the individual user of RBA Voices, and shall only collect end-user information necessary to achieve the purpose of enterprise operation and management, and has fully informed the end-user of the purpose, scope and usage of the relevant data collection, etc.
Data Controlled by Enterprise Organization may include:
a) your position, department, industry, office email account, office phone number and other information assigned to you by your enterprise organization, as well as the signature image, facial recognition image, facial features, sign-in face photo, geographic location and other sensitive personal information, and attendance information, approval records, posting log information, schedule information, etc. that you request or generate to complete the daily operation and management of your business organization to open the attendance, approval, sign-in and log functions.
b) If the administrator of your enterprise organization selects RBA Voices online services such as attendance, approval, check-in and log function, you need to provide your identity information (name, ID card information, household registration, etc.), enterprise employment information (department, position, rank, etc.), labor contract status information, enterprise and your personal contact information (cell phone, landline phone, email address), enterprise and personal contact addresses (home address, office address, etc.) as required by the enterprise organization users, contact address (home address, office address), academic information (school, major, education), payroll bank card information, emergency contact information and/or business card information of external business contacts that you keep, and other information or your personal information that the enterprise organization user submits or requests you to provide that the enterprise distributes to you.
c) Other data containing your personal information submitted by enterprise organization users, such as RBA Voices enterprise address book, including employment information, contact information, and personal identification information and other information of enterprise organization users.

5. Information You Provide to Us

In the process of using RBA Voices, you can give us feedback on your experience with RBA Voices 's services to help us better understand your experience and needs in using our products or services, and to improve our products or services, for which we will record your contact information, feedback questions or suggestions so that we can further contact you for feedback on our handling ((See "G. Customer Service Handling" for the contact process.).

6. Information Provided by Third Parties

We will collect information about you from other users when they perform operations related to you, and we may also collect personal data information about you from our affiliates, third parties, or through other lawful means. For example, in order to login your account, you agree to RBA Voices sending SMS verification code to carrier based on your personal cell phone number.
Unless having required your consent, RBA Voices cannot obtain the information generated by you when using third party services. However, if you have expressly agreed the third party to obtain your location information, the third party will obtain your location information through RBA Voices’s application programming interface. Such information is sensitive information, refusing to provide such information may result in you being unable to use the above third party services, but does not affect your normal use of RBA Voices’s functions.

7. Customer Service Handling

When you contact us, in order to protect the security of your account and system, we need you to provide the necessary personal information to verify your account identity.
To facilitate contacting with you, to help you solve problems as soon as possible or to record the solutions and results of related problems, we may keep records of your correspondence/calls with us and related contents (including account information, work order information, other information you provide to prove relevant facts, or contact information you leave), and if you make inquiries, complaints or provide suggestions for specific orders, we will use your account information and work order information. We may also use other information about you that is reasonably necessary to provide and improve the quality of our services, including information you provide when you contact customer service and information you send to us in response to a questionnaire.

8. In accordance with relevant laws and regulations and national standards, we may process your relevant personal information without your consent. For example, information related to the performance of the obligations of the controller of personal information under laws and regulations, information directly related to national security and national defense security, information necessary for the conclusion and performance of a contract based on the request of the subject of personal information, etc.

3) You can view the status of your permissions in your device settings, and you can turn them on or off at any time at your discretion.
4) Please note that by turning on any of the permissions, you authorize us to process the relevant personal information to provide you with the corresponding services, and by turning off any of the permissions, you cancel your authorization, and we will no longer process the relevant personal information based on the corresponding permissions, nor will we be able to provide you with the services corresponding to the permissions. However, your decision to turn off the permission will not affect our prior collection and use of information based on your authorization.
5) In the event that our products or services cease to operate, we will notify you by notification, announcement, etc., and delete your personal information within a reasonable period of time or anonymize it in accordance with applicable laws and regulations.
2. How We Use SDK Technology
In order to ensure the realization of relevant functions of RBA Voices and the safe and stable operation of the application, we may access the software development kits (SDK) provided by third parties and affiliated parties to achieve relevant purposes. At the same time, we will conduct strict security monitoring of the software development kits (SDK) from which our partners obtain information in order to protect data security.
Please note that third-party SDK and affiliated parties may have certain changes in the type of data processing due to their version upgrades, policy adjustments, etc. Therefore, we may adjust the third-party SDK we access when meeting new service requirements and business function changes.
At present, the third-party SDKs accessed by RBA Voices are as follows:
1) Umeng
Purpose of use: Statistical analysis, pushing information
Collecting personal information type: Device identification information, application list
Official description or privacy policy: https://www.umeng.com/page/policy

2) Ali Mobile Push
Purpose of use: To provide users with message push and related functions
Collecting personal information type: device identification information
Official description or privacy policy: https://develop.aliyun.com/tools/sdk

3. How We Use the Personal Information  
1) In order to ensure the security of our services, and to enable us to better understand the operations of our applications, we may record information such as your frequency of using our applications, crash logs, overall usage, performance data, and the sources that apps are installed from. We will not combine the information stored in the analytics software with any personal identification information you provide in the application.
2) For the purpose of providing Services to you, we will entrust Micro Benefits Financial Consulting (Suzhou) Co. Ltd. to process your personal information. Such service provider will process personal information in strict accordance with the purpose of our commission and the relevant consignment agreements, and will take necessary measures to safeguard the safety of the personal information it handled in accordance with the relevant Chinese laws and administrative regulations. We will conduct an impact assessment of personal information protection prior to the commission and supervise the activities of processing of personal information carried out by the service provider.
3) Where we utilize your personal information beyond the scope of our collection statement or a direct or reasonable connection, we will inform you and obtain your prior express consent again before using your personal information in such situations.
4. The Storage and Security of the Personal Information
1) The storage of personal information

1. We will act in accordance with laws and regulations and store personal information collected within the territory in China. We will strictly abide by the law when your personal information is transferred from China to an overseas storage location. If we are required by law or regulation to pass the security assessment before providing users' personal information outside the territory of China, we will conduct a security assessment in accordance with the requirements of the law or regulation.

2. We will take reasonable and practicable steps to store your personal information and make every effort to avoid collecting irrelevant personal information. We will only retain your personal information for as long as is necessary to achieve the purposes described in this Policy and as required by applicable laws and regulations. After your personal information has been retained beyond that period, we will delete or anonymize your personal information as required by applicable law.

2) The security of personal information

1. We endeavor to safeguard the security of your information to prevent loss, misuse, access or disclosure of information without authorization. We strengthen the security capability of the software installed on your device side through continuous improvement of technical means to prevent the leakage of your personal information, including protection of technical security, certification of security system, personnel security management, password protection tips, and development and organization of contingency plans for personal information security incidents.

2. In order to improve the security of your use of the services provided by us and our affiliates and partners, to protect your personal and property safety or that of other users or the public from infringement, to better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusion, and to more accurately identify violations of laws and regulations or relevant rules of RBA Voices, we embed in our applications the SDK developed by our affiliates to collect your personal information, service usage information, device information, and service log information, and may use or integrate your membership information, transaction information, and information that our affiliates and partners obtain your authorization or shared by them according to the law to comprehensively determine your account and transaction risks, conduct identity verification, detect and prevent security events, and record, audit, analyze, and dispose in necessary according to laws and regulations.

3. You understand and agree that we may need to provide personal information outside of China for business purposes. Only when the requirements of Chinese laws and regulations are met, will we provide personal information outside of China. At that time, we will inform you of the name of the overseas receiving party, contact information and the purpose of processing by appropriate means. In the meanwhile, we will protect your personal information rights and interests to a standard no less than that required by Chinese laws and regulations.

4. We will endeavor to protect your personal information. In the meanwhile, please understand that no security measures can be entirely flawless.

Your Rights
1) Managing, visiting and updating your information
You can manage your personal information and relevant information of your personal account, including personal image, gender, birthday, hometown, telephone number, etc., by managing “personal information” on RBA Voices.
2) Exporting and deleting your information

1. You can delete some of your information in the way described in "1) Managing, visiting and updating your information" above.

2. You may request us to delete personal information if our process of personal information violates laws and regulations, we collect or use your personal information without your explicit consent, our process of personal information seriously violates our agreement with the enterprise you work for, you no longer use our products or services, or we no longer provide services to you.

3. If we decide to respond to aforesaid enterprise’s request for deletion, we will also notify the entities who received your personal information from us, if possible, and ask them to delete it promptly (unless otherwise required by laws or regulations, or if these entities have independently obtained your authorization).

4. After you or we assist you in deleting the relevant information, we may not be able to immediately delete the corresponding information from the backup system because of applicable laws and security technologies, and we will securely store your personal information and isolate it from any further processing until the backup can be erased or anonymity is achieved.

3) Change or withdraw your consent
Some services require some basic personal information to complete (see "1. The Personal Information We Collect" and "2. How We Use the Personal Information" in this Privacy Policy), except that you can change your authorization Scope of consent by contacting the enterprise you work for.

4) Cancel your account
You can log into your RBA Voices account , submit a cancellation request through My - Settings - My Account - Application for Cancellation, and we will cancel your account within 15 business days after confirming with the company you work for. Before submitting your cancellation request, please read the "Important Reminder" we send to you carefully. After cancelling your RBA Voices account, we will stop providing services to you and delete or anonymize your personal information as required by applicable laws.

6. If you have any questions, comments or complaints about the Policy and the data process of RBA Voices, or if you believe that we have not complied with this Privacy Policy or the applicable laws and regulations, please contact compliance@microbenefits.com, or call us by 400-961-5626.