This Privacy Policy is made and concluded between Arogal members (hereinafter referred to as "members") and CONICO (HK) TECHNOLOGY CO., LIMITED (hereinafter referred to as "Arogal") concerning members' use of services provided by Arogal. This policy clarifies the rights and obligations between Arogal and its members with respect to personal information processing.
Please be aware that we will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes. For companies, organizations, and individuals with whom we share personal information solely for the purposes stated in this policy, we will sign strict information protection and confidentiality agreements with them, requiring them to comply with the agreements and take relevant security measures to protect your personal information.
To provide localized services and comply with regional regulations, we use IPInfo services to identify your approximate geographic location based on your IP address. IP address data is powered by IPInfo.
(B) Transfer
As our business develops, we and our affiliates may undergo mergers, acquisitions, reorganizations, asset transfers, or similar transactions. If personal information is involved in such a transfer, we will require the company or organization receiving your personal information to continue to be bound by this Privacy Policy; otherwise, we will require that company or organization to re-seek your authorized consent.
Except for the situations described above, we will not transfer your personal information without your explicit consent.
(C) Public Disclosure
We will only publicly disclose your personal information in the following circumstances, and only after taking security measures that comply with industry standards:
1. Based on your needs, disclosing the personal information you specify in a manner to which you have explicitly consented;
2. When required to provide your personal information by law, regulation, mandatory administrative enforcement, or judicial requirements, we may publicly disclose your personal information based on the type of personal information requested and the method of disclosure. Subject to laws and regulations, when we receive such requests for disclosure, we will require the issuance of corresponding legal documents, such as subpoenas or investigation letters.
(D) Exceptions to Prior Authorized Consent for Sharing, Transfer, and Public Disclosure
In the following situations, sharing, transferring, or publicly disclosing your personal information does not require your prior authorized consent:
1. Related to national security and defense security;
2. Necessary for public safety, public health, and major public interests;
3. Necessary for criminal investigation, prosecution, trial, and judgment execution;
4. Necessary to protect your or other individuals' major legitimate rights and interests, such as life and property, but where it is difficult to obtain the person's consent;
5. Necessary for other situations to maintain public interest, for example, where your credit evaluation information must be publicly disclosed/shared;
6. Personal information that you have disclosed to the public yourself;
7. Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure, etc. However, this does not apply if you explicitly refuse or if processing this information infringes upon your major interests;
8. Other situations where authorization is not required by law.
According to the law, if personal information that has undergone de-identification processing is shared, transferred, or publicly disclosed, and the data recipient cannot restore and re-identify the personal information subject, we are not required to separately notify you and obtain your consent for the processing of such data.
(A) Storage of Personal Information
To ensure your personal experience and to comply with applicable laws and regulations, we have implemented partitioned storage for personal information. Depending on your location, your personal information may be stored on servers in your country or region, or on servers in other countries or regions.
We will only retain your personal information for the period necessary to achieve the purposes described in this policy, unless there is a mandatory retention requirement by law or regulation. We primarily refer to the following standards to determine the storage period for personal information, and choose the longer period: ensuring the security and quality of the services we provide to you; whether you agree to a longer retention period; whether there are other special agreements or legal and regulatory provisions regarding the retention period.
After the retention period expires, we will delete your personal information or anonymize it in accordance with applicable legal requirements. When you actively cancel your account, we will process the data in accordance with legal and regulatory requirements.
If we cease operations, we will notify you at least 30 days in advance and process your personal information in accordance with legal and regulatory requirements after the cessation of operations.
(B) Protective Measures for Personal Information
Data Security Measures: To ensure the security of your information, we strive to take various physical, electronic, and administrative security measures that comply with industry standards to protect your personal information. We have established data classification and grading systems, data security management specifications, and data security development specifications to manage and regulate the storage and use of personal information. We implement comprehensive security controls on data through information contact confidentiality agreements, monitoring, and audit mechanisms to prevent your personal information from being accessed, publicly disclosed, used, modified, damaged, or lost without authorization. For example, we use SSL encryption protection technology for data exchange (such as credit card information) between your browser and the "Service"; use encryption technology to ensure data confidentiality; use trusted protection mechanisms to prevent data from malicious attacks; deploy access control mechanisms to ensure that only authorized personnel can access personal information; and hold security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information.
Please be aware and understand that the internet is not an absolutely secure environment. We strongly recommend that you use secure methods and complex passwords to help us ensure the security of your account. If you discover that your personal information has been leaked, especially your account or password, please contact us immediately through the contact methods provided in this Privacy Policy so that we can take appropriate measures.
Security Incidents: In the unfortunate event of a personal information security incident, we will immediately establish a special emergency response team, activate our emergency plan to prevent the incident from escalating, and promptly inform you in accordance with legal and regulatory requirements of: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant situation of the incident by email, letter, phone, push notification, etc. When it is difficult to inform personal information subjects one by one, we will adopt a reasonable and effective way to issue a public announcement. At the same time, we will also proactively report the disposal of the personal information security incident in accordance with the requirements of regulatory authorities.
You have the following rights over your personal information:
(A) You have the right to access, correct, and delete your personal information, except in cases stipulated by law and regulation.
You can manage your information in the following ways:
Accessing and Managing Personal Information:
● You can access, modify, and manage your personal information.
● For smart device data, you can access, modify, and manage your personal information through the settings interface.
Please be aware that according to legal and regulatory requirements and the technical conditions of different information types, we may not be able to immediately and completely delete the corresponding information you wish to delete from our systems. Before then, we will only store the corresponding information and take necessary security protection measures in accordance with regulatory requirements.
Obtaining a Copy of Personal Information: If you wish to obtain a copy of your personal information, or if you are unable to manage this personal information through the links above, you can contact us at any time via email at [support@arogal.ai]. We will respond to your request in a timely manner.
(B) Changing the Scope of Your Authorized Consent or Withdrawing Authorization
You can change the scope of your consent or withdraw your authorization by deleting information, changing privacy settings on this Platform, or disabling device permission functions in your system.
Please understand that when you perform the above operations, we will be unable to continue providing you with the services corresponding to the withdrawn consent or authorization, but this will not affect the personal information processing that has already been carried out based on your prior authorization.
If you need our assistance in withdrawing your consent, you can contact us at any time via email at [support@arogal.ai]. We will respond to your request in a timely manner.
(C) Close Your Account
You have the right to cancel your Platform account. After your account is successfully closed, we will delete your personal information or anonymize it, unless otherwise stipulated by law, regulation, and corresponding national standards.
If you are unable to access, correct, or delete your personal information, withdraw consent, or cancel your account through the methods above, or if you believe that this Platform is collecting or using your personal information in violation of the law, you can contact us through our customer service or other methods provided in this Privacy Policy. To ensure security, we may require you to provide corresponding proof of your identity and the legitimacy of your request. We will respond to your request in a timely manner after receiving your feedback and verifying your identity. We generally do not charge a fee for your reasonable requests, but for multiple, repetitive requests that exceed a reasonable limit, we will charge a certain cost fee as appropriate. We may refuse requests that are groundlessly repetitive, require excessive technical means (for example, requiring the development of a new system or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on backup tapes).
We place great importance on the protection of minors' personal information. We do not use age identification as a prerequisite for providing products or services to users, but the nature of our products and/or services requires that you be an adult with full civil capacity.
If we discover that we have collected the personal information of a minor without first obtaining verifiable consent from a parent or legal guardian, we will seek to take appropriate measures to process the relevant data as soon as possible.
Our Privacy Policy may change. Without your explicit consent, we will not diminish the rights you are entitled to under this Privacy Policy. We will promptly update the policy if there are changes to our basic situation, the purpose, method, type, and retention period of your personal information processing, the way you manage your personal information, or our contact information. We will display the changed content to you through push notifications, pop-ups, or other appropriate forms that comply with legal requirements when you log in and when the version is updated.
In the aforementioned circumstances, if you continue to use our services, it means you agree to accept and be bound by the revised policy.
You can contact us through the following methods, and we will respond to your request in a timely manner:
● You can contact us through the Platform's online customer service system.
● We have also established a dedicated personal information protection team. You can contact us via email at support@arogal.ai.
If you have any concerns about our personal information processing activities or believe your legitimate rights and interests have been affected, we welcome you to communicate with us. We are committed to resolving any issues through friendly negotiation.
If you are unable to resolve the dispute through negotiation with us, you may report it to the relevant government departments or seek resolution by filing a lawsuit with the court of competent jurisdiction of Hong Kong High Court.
Last Updated: January 29, 2025