Users can use Flexcil’s products and services in a variety of ways, including creating, editing, and sharing information and communicating with others. The collection of minimum personal information is essential to provide more convenient and optimized user experience. This Private Policy discusses how Flexcil uses, handles, and protects user information.
- Developer: Flexcil Inc. (hereinafter “company”, “we”, “us”, or “our”)
- Products and Services (hereinafter “App” or “services”)
① Flexcil – Notes & PDF Reader
② Flexcil 笔记和 PDF
Definition and Introduction
- Personal information refers to electronic or other types of information that can identify a natural person with the information alone or in combination with other information.
Collection of personal information
- We do not collect any personal information that can identify a natural person with the information alone or in combination of other information.
- We do not collect any information regarding your content on the App, such as your document, comment, or handwriting.
- We only collect the following anonymous additional information which is important for the statistics and improvement of our services.
- We collect minimum additional information for the product improvement and usage statistics and utilize the following third-party services to anonymize and efficiently collect the information.
- HUAWEI Mobile Services (HMS)
HUAWEI Mobile Services SDK serves the following purposes, and it does not collect information in mainland China:
SDK for purchasing content from HUAWEI within the app to sell digital products and content, and to apply HUAWEI’s payment environment.
SDK for mobile apps and web apps provided by HUAWEI to analyse user behavior and product optimization, user experience analysis, and product life cycle.
- HUAWEI AppGallery Connect
HUAWEI AppGallery Connect SDK serves the following purposes:
HUAWEI’s App Performance Management SDK collects performance data including ANR data, app environment data, app startup data, app screen rendering data, HTTP/HTTPS network data, foreground, and background activities, and uses it for product error and performance analysis.
- Google Firebase
The Google Firebase SDK is used for the following purposes:
Used to track the product’s abnormal stop stack to determine its cause, correct it, analyze error statistics, etc.
Google Analytics for Firebase
Used for statistics and analysis such as user behavior analysis and product optimization, user experience analysis, and device/OS environment.
Processing and retention period of personal information
Users’ additional information shall be destroyed immediately once the purpose of the collection and use of personal information is fulfilled. However, the following information can be retained for the period specified below:
- Information retention according to the company’s internal policy
① To analyze App usage and to prevent App crashing
– Cause of Retention: To analyze App usage and to prevent App crashing
– Retention period: 1 year
Destruction of personal information
Users’ additional information shall be destroyed immediately once the purpose of the collection and use of personal information is fulfilled. The procedure and method of destruction is as follows:
- Destruction procedure
The collected anonymous information will be transferred to a separate DB after the purpose is fulfilled (for paper, the information will be transferred to a separate document box) and will be destroyed after being stored for a certain period of time according to internal policy and other relevant information protection regulations. This information shall not be used for any purpose other than that held under law.
- Destruction method
Personal information printed on paper shall be shredded by a grinder or destroyed by incineration. Any personal information stored in electronic form shall be deleted from hard storage devices with technical method that renders it irrecoverable.
Rights of the user and how to exercise the rights
- We do not collect any personal information that can identify individuals.
- Users can stop the collection of anonymous additional personal information that we collect at any time by uninstalling Flexcil services installed on your device.
Processing information and provision to third parties
We do not provide any information to third parties without your consent. However, there are exceptions as follows:
① When a request is made from an investigative agency or other government agency to provide information;
② Where necessary to protect information, such as to confirm fraudulent conduct, including the user’s violation of regulation or terms and conditions;
③ Where required by other law.
In addition, we may delegate the collection of additional information through services that provide information collection services for efficiency.
Technical and administrative measures for protecting personal information
We enforce the following technical and administrative measures to secure the safety of the user’s personal information, so that it is not lost, stolen, leaked, altered or damaged when processed.
- Measures to prepare for hacking, etc.
We put our best effort to prevent the user’s additional information from being leaked or damaged by hacking or computer viruses.
① In case of information leakage, data is frequently backed up. We prevent the user’s information and data from being leaked or damaged by using the latest vaccine program, and personal information can be transmitted safely over the network through encrypted communication.
② We use intrusion prevention systems to block unauthorized access from the outside, and we strive to have all possible technical devices to ensure security in our systems.
- Minimization of personnel and Training
② We are trying to prevent information leakage by having all employees and associated affiliates of the company to sign the confidentiality pledge. We have our internal procedures to monitor employee compliance and correct the problem immediately.
③ The handover of information-related employees is conducted in a thorough manner under the highly secured environment and we clarify where the responsibility lies for information accidents after joining and leaving the company.
- Operation of a personal information organization
② However, we are not liable for any problems caused by the leakage of personal information such as users’ ID (e-mail address) and password due to users’ own negligence or network problems.
③ Users may report complaints related to personal information when using our service to the person or the department in charge of personal information management. We will promptly and fully answer to users’ complaints.
Director of Personal Information Management
Name: Ji-hoon, Park
We will try to answer your e-mail inquiries within 72 hours of receipt.
Limitations of responsibility for link sites
Date of enforcement: August 19, 2021