Privacy Policy
Effective on: December 5, 2020
Version No.: 2020 V4
REMINDER
Your trust is very important to us. We are well aware of the importance of personal information to you. We will take appropriate security measures as required by applicable laws and regulations and do our utmost to ensure that your personal information is secure and controllable. In view of this, Youku service provider ("we" or "us") has formulated this Privacy Policy (this "Policy" or this "Privacy Policy") and reminds you:
This Policy applies to all products and services provided on the Platform. This Privacy Policy applies when you access the Platform, use the services provided by the Platform, and the Platform's websites and servers without a separate privacy policy, and/or log into related clients. If the products or services of us and our Affiliates (see Definitions for details) use the products or services provided by Youku, but lack a separate privacy policy, this Policy shall also apply to such products and services. If there is a separate privacy policy for the products or services that we and our Affiliates provide to you, such privacy policy shall apply to such products or services.
If you need to log into the Youku Intellectual Property Protection Platform (ipp.youku.com) to complain about infringing content uploaded by users, you also need to carefully read and follow the Privacy Policy for Youku Intellectual Property Protection Platform.
Please note that this Policy does not apply to services provided by any third party to you, and such services shall be subject to the privacy policy of the third party made available to you. Before using a Youku product or service, you must carefully read and thoroughly understand this Policy, especially the terms in bold/in bold and underlined, and be sure that you have fully understood and agreed to them. If you have any questions, comments, or suggestions about the content of this Policy, you can contact us through contact methods provided by Youku.com.
Part I Definitions
1. "Personal Information" means various information recorded electronically or otherwise that can identify a specific natural person or reflect the activity of a specific natural person, either alone or in combination with other information.
2. "Personal Sensitive Information" includes ID number, personal biometric information, bank or other fund account number, property information, track of whereabouts, transaction information, and personal information of children under or at the age of 14. Sensitive information are highlighted in bold and underlined in this Policy.
3. "Personal Information Deletion" means the act of removing personal information in systems involved in daily business operations, so as to keep such information irretrievable or inaccessible.
4. "Platform" includes websites such as Youku (youku.com), Tudou (tudou.com), Laifeng (laifeng.com), Soku (soku.com), and Paike (paike.com), Youku Video Open Platform (open.youku.com), the Over-the-Top (OTT) TV service platforms on which we provide content services (including the platforms jointly developed by Youku and OTT TV broadcast control integration agencies and OTT TV content license holders and the platforms jointly developed by Youku and smart TV manufacturers), and their clients, such as the Youku app, Tudou app, Laifeng app, Youku Kids app, IKU app, Kumiao app, and paike.com app (including but not limited to the app, APK, SDK, and API on the mobile, PC, and large-screen devices). If a separate privacy policy is not available for an audio/video product or service of an Affiliate ( see Definitions for details of the scope thereof) that uses the products or services provided by the Platform (e.g., login using a Youku account), this Policy also applies to such audio/video product or service.
5. "We" ("us") means the Platform operators that provide audio and video content services on the Internet, i.e., Youku Information Technology (Beijing) Co., Ltd. and Youku Network Technology (Beijing) Co., Ltd. that run Youku.com, Paike.com, and the clients launched by Youku (Youku app, IKU app, Youku Kids app, Kumiao app, and paike.com app); Shanghai Quan Tudou Culture Communication Co., Ltd. that runs Tudou.com and the Tudou app; Hangzhou Laifeng Technology Co., Ltd. that runs the Laifeng app; and Youku's Affiliate Zhejiang Tmall Technology Co., Ltd. that runs the OTT large-screen TV business for content services provided by Youku.
6. "Platform Services" means the services that we provide to you on the Platform's websites and clients (including apps\APKs\SDKs\APIs) through the Internet in a variety of forms (including new service forms resulting from the future technological development), such as content distribution, communication via information networks, and OTT TV services.
7. "Platform Rules" includes all the rules, user service agreements, interpretations, announcements, and other content published and to be published on all the websites of the Platform, as well as various rules, implementation rules, product descriptions, announcements, etc. that each platform publishes on its channels, activity pages, help centers, etc.
8. "Affiliates" means the affiliates of Alibaba Group Holding Limited which are disclosed in the group's latest annual report.
Part II Privacy Policy
This Privacy Policy will help you understand the followings:
Privacy Policy
Reminder
Part I Definitions
Part II Privacy Policy
I. How we collect and use your personal information
II. How we use cookies and similar technologies
III. How we share, transfer, and disclose your personal information
IV. How we store your personal information
V. How we protect your personal information
VI. Protection of minors
VII. How to manage your personal information
VIII. Amendments and updates to this Privacy Policy
IX. How to contact us
I. How we collect and use your personal information
When you use our products or services, we need or may need to collect and use your personal information under the following two circumstances:
1. To provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide your information, you will not be able to use our products and/or services normally.
2. To provide you with additional functions of our products and/or services, you may choose to authorize us to collect and use the information. If you refuse to provide your information, you will not be able to use the additional functions or achieve the expected functions. But your use of the basic functions will not be affected.
You understand and agree that:
1. We are committed to developing various products and services to meet your demands. Due to a wide variety of products and services with which we provide you, and the different scope of specific products/services that different users choose, the basic/additional functions and the types and scope of personal information collected and used may differ accordingly, and are subject to the specific product/service functions.
2. In order to bring you a better product and service experience, we are striving to improve our technology, and we may introduce new or optimized functions from time to time, so we may need to collect and use new personal information or change the purpose or method of using personal information. To this end, we will further explain to you why, to what extent, and how we will collect and use your information through updates to this Policy, pop-up windows, page prompts, etc., you may decide whether to consent to such collection and use, and we may collect and use your information only after obtaining your express consent. If you have any questions, comments, or suggestions, you may contact us through the contact methods provided by Youku.com, and we will answer your questions as soon as possible.
To help you become our registered user and member, offer content display, playback, and video-on-demand services, and provide better and more personalized services for you, we will collect the following information based on the service you use:
(I) Create and register an account
1. Create a basic account
To register as a member and use our membership services, you need to provide (1) your mobile phone number; and create your (2) username and (3) password to be used to create an account on the Platform.
When you log in with a Taobao or Alipay account or a third-party account (WeChat, Weibo, QQ, or Huawei account), if you choose to bind your Youku account to such account, the third-party platform will share some of your information with us, such as your mobile phone number, profile picture, nickname, or ID, upon your authorization.
2. Basic information maintenance and authentication
[Basic Information Maintenance] To maintain your basic information and improve your service experience, you need to fill in and/or improve your information necessary for us to provide the service, which may include your email address, gender, location, profile picture, nickname, birthday, and bio. If you refuse to provide such information, you can still use core functions of the Platform and our clients normally.
[Authentication] If your account is lost, we provide three ways to verify your identity. You can reset your password after passing the authentication by mobile phone or through customer service. During this process, you need to provide some information to verify your identity. When retrieving the password, we may need you to provide your frequent login location and device for verification.
(II) Upload or publish information and videos
To upload videos or photos, post bullet subtitles or comments, or leave or post messages in the community, in addition to creating and registering an account, you may need to provide the following information:
1. Necessary identity information
a. To ensure secure content and protect users and viewers against the interference by suspicious accounts and ensure a clean cyberspace, we may require users who upload spam advertisements, videos, or illegal content on a regular basis or in batches, to upload their ID number and photo of them holding their ID card for further authentication. If they refuse to provide such information, we have the right to temporarily disable the upload service for them.
b. Please note that overseas Youku accounts should be registered with real names according to the requirements of China's regulators. Therefore, we may require these users to provide additional information. Only after their accounts and information are approved by the regulators, can they upload or publish videos.
2. Make posts or comments
Content you provide when using our services (including but not limited to comments, replies to posts, bullet subtitles, and community messages), such as information you post on the Platform, or in the Platform's forums, Youku Star, or communities.
The above information is necessary for you to upload and publish videos, photos, and information on the Platform. However, if you do not need to upload or publish any content on the Platform, you do not need to provide the above information. Not providing the above information will not prevent you from using the core functions of the Platform.
3. Establish contacts and share information
You may establish contacts and share some content through our services. When you create a communication or transaction or share some content through our services, you may choose the counterparties for the communication, transaction, or sharing. These counterparties are able to view your membership level, nickname, the content of communication, the content you share, etc.
When using the Platform and the Platform Services for video storage, distribution, content on-demand, watching, or posting comments or bullet subtitles, you may disclose personal information of yourself or others, which may include personal sensitive information. Please protect your personal information properly and provide and display your information to others only when necessary. You shall not disclose others' personal or private information without their permission. Please consider more carefully whether to disclose or even publicly share your personal information when you use our services. If you discover that your personal information, especially your account and/or password, has been leaked, or the content you provide contains personal or private information of others, please contact our customer service immediately, so that we can take measures to tackle the issue.
Public information refers to any information you publicly share, such as comments, bullet subtitles, replies to posts, profile picture, nickname, user name, photos, and videos.
Please note that the content and information you share when using our services may involve your personal sensitive information. If it contains personal information of others, make sure you have obtained their authorization. Please consider more carefully whether to disclose or even publicly share your personal sensitive information when you use our services.
(III) Participation in operational and interactive activities
When participating in operational and interactive activities on the Platform, such as lucky draw, guessing, quizzes, and questionnaires, you may need to submit relevant information. For example, you may need to submit your ID card information to withdraw red packets, claim prizes, and pay taxes to tax authorities. If prizes or gifts need to be shipped, you shall also provide your address.
(IV) Content recommendation
To improve content recommendations, optimize search results, understand the product's compatibility with different devices, ensure a secure operating environment, and identify account exceptions, we collect and associate information about how you use our products or services, including:
1. Device information: We will, according to your specific operations in software installation and/or use, receive and record information about the device that you are using (including its model, operating system version, settings, mobile equipment identifier, network device information, necessary information about the list of mobile apps, and other software, hardware, and environment information), and information about the location of the device (including your authorized GPS location, WLAN access point, base station, and other sensor information).
2. Log information: When you use the products or services on our websites or clients, we will automatically collect, as saved network logs, detailed information about your use of our services, including your search and browsing records, content you have followed, recently played videos, visits, play duration, IP address, WLAN, telecom carrier network, language used, and access date and time.
Please note that device or service log information alone is not sufficient to identify a specific natural person. Where we use such non-personal information in combination with other information to identify a particular natural person or use it in combination with personal information, such non-personal information shall be considered as personal information during the combined use. In this case, we will anonymize and de-identify such personal information except with your authorization or as otherwise required by laws and regulations.
In order to provide you with information display, search, and push services that are more convenient and more suitable for your individual needs, we will extract your preference features based on your device information and service log information, and generate indirect consumer crowd profiles based on feature tags, which will be used to display and push the relevant information and possible commercials.
We strive to provide you with the best browsing experience. If you do not want to receive commercials from us, you can unsubscribe from or close them by replying a text message according to the instruction or by taking other methods we provide. On the recommendation page, you can click the drop-down button of each video and choose to close the recommended content and preferred categories.
In addition, we will use your aforementioned information to further improve and optimize the foregoing functions.
To improve your experience, we may adopt new technologies in addition to server-client transmission technology to improve data transmission efficiency. For this purpose, we may use your terminal device and content access information.
(V) VIP membership or subscription services
When you pay VIP membership fees, we will record your payment method and account number for after-sales services such as making a refund according to the original payment method, withdrawing red packets, and cancelling membership auto renewal. Depending on the payment method you choose, we will share your payment information, order security-related device information, and other necessary information required by anti-money laundering laws with Alipay or other third-party payment companies through the software development kit (SDK) of Alipay and other third-party payment tools embedded in the app. At the same time, we will record and show you the information of orders in your account, including purchasing membership, on-demand videos, comics, virtual coins, and props.
(VI) Customer services and dispute settlement
To provide customer services for you, we will record your contact information and communication/call records and content so that we can contact you and solve your problem. We may also record how your problem is solved and the result.
To confirm your transaction status and provide after-sales VIP member services and dispute resolution services for you, we will collect your transaction and payment information (such as transaction and charge vouchers for IAP payment on IOS devices) based on the payment institution and payment method you have selected.
(VII) Security assurance
Risk identification: We may use your personal information to prevent, detect, and investigate frauds, behaviors endangering security, unlawful behaviors, or breaches of agreements, policies, or rules of us or our Affiliates, such as abnormal account activities, multi-terminal logins, abnormal traffic, recurring refund requests, or low-cost transfer of membership cards, to protect the legitimate rights and interests of you, other users, us, or our Affiliates.
To improve the security of your use of services provided by us, or our Affiliates and partners, ensure a secure operating environment, identify account exceptions, protect the personal and property safety of you, other users, or the public, better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, cyber attacks, and network intrusions, and more accurately identify violations of laws and regulations or the Platform Rules, we have embedded a security SDK developed by our Affiliate in the app to collect your device information and service logs, and may use or integrate your account information, transaction information, payment information, device information, related network logs, and information that our Affiliates and partners have obtained with your authorization or shared in accordance with the law, to assess your account and transaction risks, authenticate your identity, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.
(VIII) Other additional services
In order to provide you with more convenient, better, and personalized products and/or services, and improve your user experience, we may collect and use your personal information when providing you with the following additional services. If you do not provide such information, it will not affect your use of the basic services such as browsing, searching, and purchasing on the Platform, but you may not be able to enjoy the user experience offered by these additional services. Such additional services include:
1. Camera-based additional services: You may use this function after enabling the camera permission. We access your camera with your authorization so that you can scan QR codes to log into your Youku account, make payments in certain scenarios, or participate in activities, or take photos or videos to upload, use UGC related functions, or display content on the Platform. Please be aware that: to deliver greater user experience, our client will obtain the position of your face in the world coordinate system using TrueDepth APIs in the eye protection mode on some iOS devices. The information is used to calculate your gaze point on the screen in real time and give interactive feedback. We will not store or share the information with third parties, or use it for any other purposes. You may disable this function at any time. The client will stop calling TrueDepth APIs and collecting data immediately after the function is disabled.
2. Image/video access and uploading services based on album (image/video library): You may use this function to upload your photos/images/videos and audio and video files in the local cache after enabling the album permission, so that you may change your profile picture, make or share comments or posts, save QR codes for activities, or provide evidence during the communication with the customer service. We may identify the link of activities you want to participate in or the link of video services you want to use from the photos/images you upload, or use the comments that include photos or images you upload. We may read the last image link you saved on your device so that you may share it with your friends or participate in promotional activities.
3. Voice services based on microphone: After enabling the microphone permission, you may search for movies, TV series, and programs by voice, publish video posts on Youku Star, and communicate with customer service agents or robots by voice. Please be aware that even if you have agreed to enable the microphone permission, we will only obtain voice information via the microphone after you click the microphone icon in the client or when you record a video.
4. Calendar-based additional services: After you enable the permission for us to read/write your calendar, we will access your calendar information to help you subscribe to live programs and remind you when they start.
5. Address book permission: To share videos or the Platform's activities with your friends, you need to enable the address book permission so that we can send the link of the video or activity to your friends by SMS or via social network.
6. Location permission: After enabling the location permission, you will obtain local news and information, related audio and video content, movie theater and restaurant recommendations in frequently visited places, and other local life service information.
7. Phone status permission: To ensure your account and use security, you need to authorize us to read the IMEI number of your device.
You understand and agree that the above additional services may require you to enable the permissions to access your camera, album (image library), microphone (voice), calendar, location information and/or phone status on your device, so that we may collect and use the information involved in these permissions. You may check the status of the above permissions in "Settings" on your device or in "Me -> Settings -> Privacy -> System Permission" on our app, and can enable or disable these permissions at your discretion anytime. If the option to disable the address book permission cannot be found under the above path on the app due to version issues, you need to close the permission for Youku app in "Settings" on your device. Please note that, by enabling any of the permissions, you authorize us to collect and use relevant personal information to provide you with the corresponding service. Once you disable any of the permissions, it means that you revoke the authorization, we will no longer continue to collect and use relevant personal information based on the corresponding permission, nor will we be able to provide you with the corresponding service. However, your decision to disable the permissions will not affect the previous collection and use of information based on your authorization.
8. Instructions on the use of get_accounts permission: Youku has registered an application account in Android system. With Android's account sync mechanism, the application account will wake up users' Youku app when it receives a system notice. This increases the reachability of push notifications and ensures that important messages will reach users' mobile devices. Currently, we need to apply for the permission on devices with Android 5.1 or earlier. The permission is only supported on Android earlier than 8.0. So far, Youku has not used the permission to obtain any user information.
(IX) Technical connection support
When you use an applet on the Platform, to provide technical connection support, we need to obtain necessary information (such as device information and operation logs) from the developer and technical service provider of the applet (such as Alipay applet platform operator). When you use the applet service through the Platform, your information will be governed by the privacy policy of the developer and technical service provider of the applet, and we recommend that you read and confirm your understanding of the relevant agreement before accepting the relevant service.
In addition, if your Youku account is bound to a Taobao account, you can directly log in to the Taobao touch screen version, Taobao applet, Taopiaopiao applet, Ele.Me H5, and Shuqiw.com applet (collectively, "applets " or "H5"); the behavior data and trading data arising from such login to the applets with your Taobao account and all your actions committed in applets or H5 shall belong to the developers of the applets (such as Taobao, Taopiaopiao, Ele.Me, and Shuqiw.com), and Youku only provides information display portals and display services. To ensure the security of your operations and data security on these applets and H5 pages, please do not share your Youku account and the Taobao account bound to your Youku account with others. If you share your Youku account with others, and thereby a third party can log into the aforementioned applets and H5 pages to place orders and conduct transactions using your account, you shall be liable for any losses sustained by you arising therefrom.
(X) Miscellaneous
1. If the information you provide contains the personal information of other users, you must ensure that you have obtained the legal authorization before providing us with such personal information. If any personal information of a child is involved, you must obtain the consent of the child's legal guardian before posting the information. In such cases, the legal guardian has the right to request the correction or deletion of the child's personal information by contacting us through the channels described in Section IX of this Policy.
2. We will obtain your consent in advance, if we use the information for purposes other than described in this Policy, use the information collected for specific purposes for other purposes, or intend to collect your personal information from a third party.
If we obtain your information indirectly from a third party, we will ask the third party in writing to collect your personal information after obtaining your consent in accordance with the law, and inform you of the content of the shared information. In the case of sensitive information, the third party will be required to explicitly confirm your consent before providing the information to us, and will be required to make a commitment to the legitimacy and compliance of the source of the personal information. If the third party violates the law, we will explicitly require the third party to bear the corresponding legal responsibility; at the same time, our professional security team will conduct security reinforcement of personal information (including sensitive information reporting, encrypted storage of sensitive information, access control, etc.). We will protect the personal information we indirectly obtain with the means and measures that are in no event less stringent than those we use to protect the personal information of our users.
3. Exceptions to obtaining authorization and consent
You fully understand and agree that we will collect and use your personal information without your authorization or consent under the following circumstances, and we may not respond to your request for corrections/modifications, deletions, cancellation, withdrawal of consent, or access to information:
(1) Concerns over national security and defense are involved;
(2) Public safety, public health, or major public interests are involved;
(3) Criminal investigation, prosecution, judgment, enforcement, or other judicial or administrative law enforcement is involved;
(4) For the purpose of protecting the life, property, and other major legitimate rights and interests of you or any other individuals, where it is difficult to obtain your prior consent;
(5) Personal information that you have voluntarily disclosed to the public;
(6) Personal information collected from the information disclosed through legitimate public channels, such as lawful news reports or information disclosure by the government;
(7) Information necessary to sign and perform agreements or other written documents with you;
(8) For the purpose of maintaining the safe and stable operation of the provided products and/or services, for example, to detect and cope with faults in the products and/or services;
(9) For the purpose of reporting news on a legal basis;
(10) For the purpose of statistical or academic research conducted by academic research institutions in the public interest, where the personal information contained in the published results of academic research or descriptions has been de-identified;
(11) Other circumstances stipulated by laws and regulations.
Please note that according to applicable laws, if we need to process personal information by means of technical measures and other necessary measures so that the data recipient cannot re-identify a specific individual or restore the data, or if we use the information we collect for de-identified research, statistical analysis, and forecasting for the purpose of improving the content and layout of the Platform, providing product or service support for business decisions, and improving our products and services (including machine learning or model algorithm training with anonymous data), we will conduct such processing in accordance with the relevant laws and regulations.
4. If we stop operating the products or services of the Platform, we will stop collecting your personal information in a timely manner and notify you of the cessation of operation individually or through an announcement, and delete or anonymize all personal information related to the ceased business that we hold.
II. How we use cookies and similar technologies
(I) Cookies
In order to ensure the normal operation of the website, allow your easier access, and recommend content that may be of interest to you, we will store on your computer or mobile device cookies, flash cookies, or other local storage that is provided by browsers or associated applications and usually contains identifiers, site names, and some numbers and characters (collectively, "Cookies"). With cookies, websites can store data such as your preferences or the items in your shopping cart.
You can customize the level of cookies that are created or block cookies for our website if your browser or browser-attached services allow you to do so. For more information, see AboutCookies.org. However, if you do so, this may in some cases affect your access to our website securely and may require you to change your user settings each time you visit our website.
(II) Similar technologies
In addition to cookies, we also use other similar technologies such as web beacons and pixel tags on our website. For example, the email that we send to you might contain an address link to the content of our website. If you click the link, we will track it. This helps us understand your product or service preferences so that we can proactively improve the customer service experience. Web beacons are usually transparent images embedded in websites or emails. Pixel tags in emails enable us to tell whether the emails have been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.
An ETag (entity tag) is an HTTP protocol header transmitted between your web browser and the web server, which can replace cookies. An ETag can help us avoid unnecessary server load, improve service efficiency, and save resources and energy. In addition, we may use ETags to record your identity, so that we can better understand and improve our products or services. Most browsers provide an option to clear the cached data. You can perform data clearing operations in browser settings. However, please note that if you disable ETags, you may not be able to enjoy the best experience with our products or services.
III. How we share, transfer, and disclose your personal information
(I) Sharing and disclosure
We will not share your personal information with any other third party unless in the following circumstances:
1. Share your information with your explicit consent or authorization or at your option. We may share your personal information with any other company, organization, or person upon your authorization or explicit consent. For example, if we entrust a third party to provide you with products or services (e.g., user bonuses, delivery of lucky draw prizes, and point-to-gift redemption), we will share the aforesaid information with a third party upon your consent, and if you refuse to provide such information, we will be unable to complete the relevant delivery service. We will not share your personal sensitive information unless you choose to give your consent. We may disclose your personal information to the public with your explicit consent or at your option.
2. Share and disclose information under statutory circumstance. We may share your personal information in accordance with relevant laws and regulations, litigation and dispute resolution needs, or legitimate requests of administrative and judicial authorities. For example, if we have confirmed that you have violated laws and regulations or seriously violated the relevant Platform Rules, or for the purpose of protecting the personal and property safety of the users of the Platform's websites and Affiliates, or the public, we may disclose your personal information in accordance with relevant laws and regulations or the relevant Platform Rules with your consent. The information to be disclosed may include the relevant violations you committed and the measures the Platform has taken against you. For example, if you or the account that you use uploads illegal or unlawful videos in serious violation of the Platform Rules, applicable laws and regulations, and/or public order and good customs, thereby causing huge negative impacts on society or loss of reputation to the Platform, we may disclose your information and penalties.
3. Share your personal information with our Affiliates. Sharing with Affiliates: For the convenience of providing services to you based on your associated accounts, recommending information that may be of interest to you, identifying member account exceptions, or ensuring personal and property security of our Affiliates or other users or the public, we may share your personal information with our Affiliates. We will only share necessary personal information (for example, to make it easier for you to use your Youku account to log in to and use the products or services provided by our Affiliates, we will share the necessary personal information with our Affiliates), and are bound by the purposes stated in this Privacy Policy. If we need to share your sensitive personal information, or our Affiliates change the purpose of using and processing your personal information, we will seek your authorization or consent once again.
4. Share information with authorized partners. We may entrust authorized partners to provide you with certain services or perform functions on our behalf. We will only share your information for the lawful, legitimate, necessary, specific, and express purposes stated in this Privacy Policy. Authorized partners can only access the information they need to perform their duties and shall not use such information for any other purpose.
At present, our authorized partners include the following types:
(1) Authorized partners providing advertising monitoring, data statistics, and data analysis services. To maintain or improve our products and services and provide you with better content, we may access the designated partners providing such services, such as Advertising Alliance, IResearch, and our affiliate Umeng to read your device identification number and network-connection-related information, so as to analyze your use of our services and optimize advertisement relevance.
Except in the aforesaid circumstances in which your permission is obtained, we will not share the information about your personal identity (which means information that can be used to identify you, such as name or email address, and with this information, we can contact or identify you) with partners that provide advertising and analysis services. We will entrust these partners to process the information related to advertising coverage and effectiveness, but will not provide your personal identity information, or we will de-identify such information, so that it will not identify you personally. Such partners may use the above information with other data they have legally obtained to implement the advertising services or decision-making suggestions we entrust.
(2) Suppliers, service providers, and other partners. We may send your information to suppliers, service providers, and other partners that support our business (e.g., OTT TV broadcast control licensees, content licensees, hardware vendors, and telecom operators). Their support includes providing technical infrastructure services under entrustment from us, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customer service, facilitating payment, or conducting academic study and research.
(3) Use of SDKs. SDKs or other similar applications of our authorized partners will be embedded in our application to ensure the stable operation and feature realization of our client, so that you can use and enjoy more services and features. Click to view the details of SDKs of our authorized partners that are embedded in our application.
We perform strict security testing on APIs and SDKs with which our authorized partners obtain relevant information, and agree upon strict data protection measures with our authorized partners, so that they process their personal information in accordance with this Policy and by means of other relevant confidentiality and security measures.
5. Assist in resolving disputes. If you are a qualified intellectual property complainant and have filed a complaint, we will disclose your information to the respondent at the request of the respondent, so that they may handle possible disputes over rights. Only by sharing your information can we provide the services you need or handle disputes or conflicts between you and others. For example, where the content of a video you created on the Platform is accused of having infringed upon others' intellectual property rights or having violated relevant rules, if a request for disclosure is made by any complainant in a transaction, a judicial body, or an administrative law enforcement agency, as appropriate, we will provide the above-mentioned agencies with the necessary information such as the contact information of the user against whom the complaint is filed to facilitate the settlement of the transaction dispute. The Platform shall bear the corresponding legal responsibility as expressly provided by law.
(II) Transfer
We will not transfer your personal information to any company, organization, or individual, except in the following cases:
1. Transfer with your explicit consent: We will transfer your personal information to any other party with your explicit consent.
2. In the event that a service provider of the Platform faces an acquisition, merger, or insolvency liquidation, or other circumstances involving a merger, acquisition, or insolvency liquidation, when user information transfer is involved, we will require the new company, organization, and person in possession of your information to continue to be bound by this Policy; otherwise, we will require such company, organization, and person to ask for your authorization or consent once again.
(III) Exceptions to seeking prior authorization and consent for the sharing, transfer, or disclosure of personal information
Under the following circumstances, your personal information can be shared, transferred, or disclosed without your prior authorization or consent:
1. Concerns over national security and defense are involved;
2. Public safety, public health, or major public interests are involved;
3. Criminal investigation, prosecution, judgment, and enforcement are involved;
4. For the purpose of protecting the life, property, and other major legitimate rights and interests of you or any other individuals, where it is difficult to obtain your prior consent;
5. Personal information that you voluntarily disclose to the public;
6. Personal information collected from the information disclosed through legitimate public channels, such as lawful news reports or information disclosure by governments;
7. Such disclosure is relevant to our performance of the obligations stipulated by laws and regulations.
In accordance with the law, sharing or transferring de-identified personal information in such a manner that data recipients will not be able to recover and re-identify the personal information subjects is not an activity of sharing, transfer, or public disclosure of personal information, and the saving and processing of such data is not subject to further notification to you and your consent.
If you do not agree to our provision of your personal information to a third party in accordance with the above provisions, please immediately stop using the Platform Services.
IV. How we store your personal information
(I) Location of information storage
The personal information collected and generated during our operation in the People's Republic of China is stored in China, except in the following circumstances:
1. It is expressly stipulated by laws and regulations;
2. Your explicit authorization has been obtained.
Under the above circumstances, we will ensure an adequate level of protection for your personal information in accordance with this Privacy policy.
(II) Information retention period
We will retain your personal information only for the period necessary to achieve the purposes stated in this Policy, unless a longer retention period is required by law. The criteria for judging the aforementioned periods include:
1. Completing the service associated with you, maintaining the corresponding service and business records, and responding to your possible queries or complaints;
2. Guaranteeing the security and quality of our services provided to you;
3. Whether you consent to a longer retention period;
4. Whether there is any other special agreement on the retention period.
After the retention period of your personal information expires, we will delete or anonymize your personal information according to applicable laws.
(III) Information deletion and anonymization
When a Platform Service is decided to be ceased, we will stop collecting your personal information after the cessation of the service. We will inform you of the cessation of the service in the form of an announcement. Your personal information we hold will be deleted or anonymized. If any personal information of a child is involved, we will also inform the child's guardian of the cessation of the service in a timely manner.
V. How we protect your personal information
In order to ensure the security of your personal information we collected, we undertake to maintain a reasonable level of security. Our specific security measures and security capabilities are as follows:
(I) Technical security measures: To safeguard your information, we strive to take various reasonable physical, electronic, and administrative security measures that meet industry standards to protect your information from being leaked, damaged, destroyed, or lost. The measures include, but are not limited to, SSLs, encrypted information storage, and access control of data centers. We will use encryption technology to strengthen the security of personal information; we will use trusted protection mechanisms to prevent malicious attacks on your personal information; and we will deploy access control mechanisms and try our best to ensure that only authorized personnel have access to your personal information.
(II) Security system guarantee: We have an industry-leading data security management system with data as its core and data lifecycle as its focus, which aims to enhance the security of the whole system from the aspects of organizational construction, system design, personnel management, product technology, etc. To better ensure secure use of the services provided by us and our Affiliates and partners, protect the personal and property safety of you or other users or the public from infringement, and better prevent phishing websites, frauds, network vulnerabilities, computer viruses, cyber attacks, network intrusions, and other security risks, and more accurately identify violations of laws and regulations or the relevant Platform Rules, the Platform is implementing classified protection of the system. Our essential information system has passed the Classified Protection of Cybersecurity evaluation, being graded Class III or higher, and obtained ISO 27001 certification.
(III) Management of personnel safety:We carry out strict management of employees or outsourced personnel who may access your information. The measures include, but are not limited to, adopting different permission controls for different positions, signing non-disclosure agreements with them, and monitoring their operations. We provide corresponding security measures to protect your information and provide reasonable security guarantee based on existing technology, and we will do our utmost to prevent your information from being leaked, damaged, or lost. We provide security and privacy protection training courses to enhance employees' awareness of personal information protection.
(IV) Sensitive information and password protection tips
a) Precautions on the protection of sensitive personal information: The information that you voluntarily share or even publicly share when using our services may involve the personal information or even sensitive personal information of you or others such as your profile pictures and pictures containing personal information that you choose to upload in your comments, posts, or bullet subtitles. Please consider more carefully whether to share or even publicly share relevant information when you use our services.
b) Please use a complex password to help us make your account more secure. We will try our best to ensure the security of any information you send to us. We will bear the corresponding legal responsibility if your legitimate rights and interests are damaged by unauthorized access to, public disclosure, tampering, or destruction of information due to the destruction of our physical, technical, or management protection facilities.
c) Your account has built-in security features. Please keep your account and password information secure. We will protect your information from being lost, abused, or altered through security measures, such as backing up and storing your data on other servers and encrypting user passwords. Notwithstanding the aforementioned security measures, please understand that there is no "perfect security measure" on the information network.
(V) Information disclosure and password leakage: Please note that the Internet is not an absolutely secure environment. Please protect your personal information properly and provide it to others only when necessary. If you discover that your personal information, especially your account and/or password, has been leaked, please contact our customer service immediately, so that we can take corresponding measures.
(VI) Information security incidents: In the event of a personal information security incident, we will, as required by relevant laws and regulations, inform you of the basic information and possible impact of the incident, the measures we have taken or will take, suggestions for you to prevent and reduce risks, remedial measures for you, etc. We will inform you of the incident-related information by email, telephone, push notification, or other means. When it is difficult to inform the subjects of personal information one by one, we will publish an announcement in a reasonable and effective manner. At the same time, we will report the handling of the personal information security incident in accordance with the requirements of regulatory authorities.
(VII) Security of children's personal information: We enforce strict access control on children's personal information, apply the minimum necessary standard to staff who may have access to children's personal information, and take technical measures to record and control the staff's handling of children's personal information to avoid illegal copying and downloading of children's personal information.
We have developed an emergency response plan for children's personal information security incidents, and we carry out regular emergency response training and emergency drills among relevant internal personnel to familiarize them with their job responsibilities and emergency response strategies and procedures. In the event of a children's personal information security incident, we will, as required by relevant laws and regulations, inform the relevant child and his/her legal guardians of the basic information and possible impact of the incident, the measures we have taken or will take, suggestions for such child and his/her legal guardians to prevent and reduce risks, remedial measures for such child and his/her guardians, etc. We will promptly inform the children and their guardians of the incident-related information by app push notification, email, SMS, etc. Where it is difficult to inform all children and their guardians one by one, we will publish relevant warning information in a reasonable and effective way. At the same time, we will voluntarily report the incident handling process in accordance with the requirements of regulatory authorities. If the legitimate rights and interests of children and their legal guardians are damaged, we shall bear the corresponding legal liability.
VI. Protection of minors
We attach great importance to the protection of personal information of minors. If you are a minor, you should request your parent or other legal guardian to carefully read this Privacy Policy, and you should not use our services or provide information to us without the consent of your parent or other legal guardian.
We have products or services intended for children aged below 14, products or services that include functional modules intended for children, and products or services that require age verification.
If we identify you as a user below the required age, we will notify your parent or other legal guardian and request your parent's or other legal guardian's consent to our rules for the collection and use of children's personal information. For the personal information we collect from children who use our products or services with the consent from their parents or legal guardians, we will use, share, transfer, or disclose such information only to the extent permitted by laws and regulations, explicitly agreed upon by the parents or legal guardians of the minors, or necessary to protect the minors.
If you are a child's parent or other guardian, please pay attention to whether the child under your guardianship uses our services after obtaining your authorization or consent. If you have any questions about the personal information of the child under your guardianship, please contact us through the contact information described in Section IX.
VII. How to manage your personal information
In accordance with the requirements of the Cybersecurity Law of the People's Republic of China, we offer you convenient methods of accessing, correcting, or deleting your account information or other personal information that you provide when using our services. You can access and manage your personal information in the following ways:
(I) Access your personal information
You have the right to access your personal information, except as otherwise required by applicable laws and regulations. You can access your personal information at your discretion in the following ways:
Account Information — If you want to access or edit the basic profile information and payment information in your account, change your password, add security information, or close your account, you can sign in to your account and go to "Account Management" to perform such operations; for example, you can log in to the PC client or APP and go to to "My Account" to check and modify your personal information, privacy settings, security settings, and your personal registration information.
(II) Correct or supplement your personal information
If you discover any error in your personal information that we process, you have the right to request us to make a correction or supplement. You may apply for a correction or supplement in the ways described in "(I) Access your personal information".
(III) Delete your personal information
You can delete part of your personal information in the ways described in "(I) Access your personal information".
You may request us to delete your personal information, if:
1. We handle your personal information in violation of laws and regulations;
2. We collect and use your personal information without your explicit consent;
3. We handle your personal information in serious violation of the agreement with you.
4. You no longer use our products or services, or you have voluntarily closed your account; or
5. We no longer provide you with products or services.
If we decide to respond to your request for deletion, we will use our best efforts to notify the subjects that have obtained your personal information from us to delete your personal information in a timely manner, unless otherwise provided by laws and regulations or such subjects have separately obtained your authorization.
When you delete some information from our service, we may not immediately delete the corresponding information from the backup system, but we will delete it when the backup is updated.
(IV) Change the scope of your authorization or consent
Each service function cannot work unless some basic personal information is provided. In addition, you can adjust your settings in "Me -> Settings -> Privacy -> System Permission" to control how additional personal information is collected and used, or give or withdraw your authorization or consent by contacting the Platform's customer service.
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 personal information previously processed under your authorization.
(V) Subjects of personal information close their accounts
At present, we have managed to, by technical means, allow you to apply for account closure at the "Account Closure" page (on Youku app, go to "Me -> Settings -> Security Center -> Account Closure"; on Youku for web, go to "Me -> Account Settings -> Security Settings -> Account Closure"). You can also contact the Platform's customer service to request account closure. After verifying your identity, the customer service personnel will remove the mobile phone number and email address associated with the account.
After you have voluntarily closed your account, we will stop providing our products or services to you and delete or anonymize your personal information as required by applicable laws. For videos you have uploaded on the Platform, if you do not want them to continue to spread on the Platform, please delete them by yourself. If you choose not to delete such videos, you will be deemed to have given the Platform your consent and authorization to continue spreading such video online. If you choose not to delete the relevant videos uploaded by you, after you close your account, your information as the uploader will be anonymized or desensitized when such video is displayed on the Platform.
(VI) Constrain the automated decision-making of information systems
To realize some service functions, we may make decisions based solely on non-manual automated 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 an explanation, and we will inform you of the appeals process without infringing upon our trade secrets, other users' rights and interests, or social public interests.
(VII) Unsubscribe
If you find that you have received push notifications about video content, products, and services that you have not voluntarily searched for or browsed, and you do not want to receive such information, you may unsubscribe from push notifications through the original path. For example, you can reply with the relevant unsubscribe keyword directly to the corresponding SMS push message. If you want to cancel your membership auto renewal, you may call the customer service hotline to make an unsubscribe request.
(VIII) Respond to your above requests
To ensure 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.
VIII. Amendments and updates to this Privacy Policy
We have the right to amend this Privacy Policy and notify you via an announcement on the Platform or in other appropriate manners before such amendment takes effect. In such case, your continued use of our services constitutes your acceptance of the amended Privacy Policy of the Platform.
We will not restrict your rights under this Privacy Policy without your explicit consent. We will post any changes and updates to this Privacy Policy on the special links of Youku.com, Tudou.com, and Laifeng.com. For major changes, we will provide more noticeable notifications (including posting announcements on the Platform or even sending you pop-up notifications).
Major changes as defined in this Policy include but are not limited to:
1. Major changes in our service model. For example, changes to the purpose of processing personal information, the type of personal information being processed, and the way we use personal information;
2. Major changes in control and other aspects. Change in ownership resulting from an M&A or reorganization;
3. Changes of the main objects of personal information sharing, transfer, or public disclosure;
4. Major changes in your right to participate in the handling of personal information and the way you exercise such right;
5. Change of the department responsible for personal information security, its contact information, or complaint channels;
6. Personal information security considered to be highly risky as a personal information security impact assessment report indicates.
We set up a special portal for access to the old version of the Platform's User Service Agreement and Privacy Policy in the footer of Youku.com and Tudou.com for your reference.
IX. How to contact us
You can contact us in the following ways and we will reply to your request within fifteen (15) working days:
1. We have a full-time personal information protection department. If you have any questions, opinions, or suggestions on Youku's privacy policy and handling of children's personal information, you can contact the online customer service of Youku.com or Tudou.com; or by calling the customer service hotline at 400-810-0580-400 (for free services) or 810-3568 (for membership services) or sending emails to pipwg@service.alibaba.com.
2. If you are not satisfied with our reply, especially if you believe that our handling of personal information has damaged your legitimate rights and interests, you may also seek a solution by filing a lawsuit with the competent court of the place where the defendant resides.
3. Our mailing address: Youku Legal Department, 28/F, Block B, Wangjing, Ali Center, Building 4, Area 4 of Wangjing East Park, Chaoyang District, Beijing, 100102, China.
The Chinese version of this Privacy Policy shall always prevail in case of any inconsistency between the Chinese version and the English version.