Contact email: nica@ltmromrecicling.com
This Privacy Policy (hereinafter “This Policy”) is designed to clearly explain to you the relevant rules regarding the collection, use, storage, sharing, transfer, and protection of your personal information by Myhub (hereinafter “This Service”), as well as the relevant rights you enjoy. Using this Service indicates that you have fully read, understood, and agreed to all terms of this Policy, and if you do not agree, you should immediately stop using this Service.
This Policy follows the International General Privacy Protection Principles (including, but not limited to, the OECD Privacy Principles) to ensure that your personal information is handled legally, fairly, and appropriately, and to protect your privacy rights and interests.
1. Definition and scope
1.1 Core Definitions
1.1.1 Personal Information: Means various information recorded electronically or in other ways that can identify a specific natural person individually or in combination with other information, including but not limited to email addresses, device information, file metadata, etc., excluding information that cannot be identified as a personal person after being anonymized.
1.1.2 Sensitive Personal Information: Means personal information that, if leaked, illegally provided, or misused, may lead to a violation of a natural person‘s personal dignity or a jeopardy of personal and property security, including but not limited to account passwords, payment-related information, confidential document contents, etc.
1.1.3 Anonymizing Processing: Means the process of processing personal information through technical means, making it impossible to identify a specific natural person, and unable to restore identification through reasonable means. The information after anonymizing processing does not belong to personal information.
1.2 Applicability Scope
1.2.1 This Policy applies to all processing activities such as the collection, use, and storage of your personal information during your use of all services on the Myhub Disk, including web, mobile, PC, and other related terminals.
1.2.2 This Policy does not apply to links, plug-ins or other services provided by third parties through this Service. The privacy protection rules for third-party services are determined by their own discretion and we take no responsibility for them.
2. Collection and Use of Personal Information
2.1 Collecting Principles
2.1.1 Necessity Principle: We collect only the personal information necessary to provide this Service, do not collect information unrelated to the Service, and ensure that the scope of collection is limited to the minimum necessary to achieve the purposes of the Service.
2.1.2 Voluntary Principle: Apart from necessary personal information, for unnecessary information, we will clearly inform you of the purpose for which we collect it, you will voluntarily choose whether to provide it, and we will not force you to provide unnecessary information.
2.2 Scope of Collection and Purpose of Use
2.2.1 Account Registration and Login Related Information: To complete account creation and authentication, we will collect the email address you provide, which is used to send registration verification emails, password retrieval, and account security notifications; the account password you set will be stored in an encrypted manner known only to you.
2.2.2 Device and Network Information: To ensure service stability, provide adaptive service and prevent security risks, we will automatically collect the device model, operating system version, network type, IP address, and device identifiers (such as Android ID, IDFV) when you use this service, to optimize service performance and identify abnormal login behavior.
2.2.3 File Related Information: To achieve core functions such as file storage, synchronization, preview, and transfer, we will collect metadata (including file name, size, format, upload time, and storage path) of files you upload, store, and transfer, without reading or extracting the file contents (unless you actively initiate actions such as preview, search, etc.).
2.2.4 Log information: We will record the operations of your use of this Service, including login times, types of operations, file operations records, etc., for troubleshooting, service optimization, and security audits, and the log information will be retained for the minimum amount of time necessary for the purpose.
2.3 How it is collected
2.3.1 Proactively provided: Related information that you voluntarily provide to us when you register an account, complete personal information, and upload files.
2.3.2 Automatic Collection: Through the technical components of this Service, information related to devices, networks and operations is automatically collected during your use of the Service.
2.3.3 Third-party assistance: If you sign in to this Service through a third-party account (e.g., Google account, Apple account), we will obtain your basic account information (e.g., account nickname, email address) through the third-party to complete the sign-in, and the collection of such information follows the third-party privacy policy.
3. Storage of Personal Information
3.1 Storage locations
3.1.1 We store your personal information in overseas servers that comply with international privacy protection standards. The specific storage location will be reasonably chosen based on your region and service optimization needs, ensuring that the data storage complies with local data protection relevant laws and regulations.
3.1.2 If the expansion of the service requires the transfer of your personal information to another country or region for storage, we will inform you in advance of the purpose, location, and security measures of the transfer, obtain your explicit consent before the transfer, and ensure that the transfer process complies with international data transfer regulations.
3.2 Storage period
3.2.1 We will store your personal information for “the shortest time necessary to achieve the service purpose”, and will promptly delete your personal information after the service purpose is achieved or after you sign out of your account, except as otherwise stipulated by law and regulations.
3.2.2 For log information, security audit information, etc., we will retain it for a reasonable period of time on the premise of meeting regulatory requirements and security assurance needs. After expiration, it will be anonymized or completely deleted.
3.3 Storage Security
3.3.1 We use world-leading security technologies such as end-to-end encryption, multi-node disaster-resistant backups, and access control to ensure that your personal information is not leaked, tampered with, or lost during storage.
3.3.2 We have established a well-established security management system, implemented strict permissions control and security training for employees who access personal information, signed confidentiality agreements, and prevented employees from illegally obtaining or disclosing personal information.
4. Sharing and Transfer of Personal Information
4.1 Sharing Rules
4.1.1 We will not sell, rent, or lend your personal information to any third party unless we obtain your explicit written consent, or otherwise required by law and regulation.
4.1.2 In order to provide this Service, optimize the quality of the Service, or comply with legal obligations, we may share necessary personal information with third-party service providers (such as server operators, security service providers), and only share the minimum amount of information necessary to realize the Service, and sign confidentiality agreements with third parties, requiring them to handle personal information strictly in accordance with this Policy and related agreements.
4.1.3 If you actively share files or information with third parties through the sharing feature of this Service, the sharing of the relevant information is under your control and we are not responsible for it.
4.2 Transfer Rules
4.2.1 If we need to transfer your personal information to a third party due to business adjustments such as corporate mergers, splits, acquisitions, and asset transfers, we will notify you 30 days in advance through platform announcements, email, and other means. Only after obtaining your consent can we proceed with the transfer and ensure that the third party continues to fulfill its privacy protection obligations.
4.2.2 When transferring personal information, we will evaluate the privacy protection capabilities of third parties to ensure that they comply with international privacy protection standards and can effectively protect the security of your personal information.
5. Protection and Security Measures for Personal Information
5.1 Technology Protection
5.1.1 Data Encryption: Use international standard encryption techniques such as AES-256 for your personal information (including account passwords, file data, and transfer content) to ensure that the data cannot be illegally read during transmission and storage.
5.1.2 Security Protection: Establish a comprehensive cybersecurity defense system to prevent security risks such as hacking attacks, virus invasions, data leaks, and conduct regular security checks and vulnerability fixes.
5.1.3 Anonymization and de-identification: For scenarios where personal identity is not required, we will anonymize or de-identify personal information to reduce the risk of privacy disclosure.
5.2 Management Protection
5.2.1 Permission Management: Implement minimal permissions management for employees who access personal information, clarify the scope of permissions, conduct regular permissions audits, and prevent infringing access.
5.2.2 Security Training: Regularly conduct privacy protection and data security-related training for employees, enhance employees‘ privacy protection awareness, and clarify confidentiality responsibilities.
5.2.3 Emergency Response: Establish an emergency response mechanism for personal information security. If security incidents such as personal information leakage or tampering occur, remedial measures will be immediately taken to mitigate the damage and you and relevant regulatory bodies will be promptly notified (as applicable).
5.3 Your Security Responsibility
5.3.1 You should safeguard your account information (especially your password), do not transfer or share your account, and should immediately notify us by contacting us via email if you discover any account theft, unusual login, etc. We will assist you in taking security measures.
5.3.2 You should use the sharing features of this Service with caution, avoid the disclosure of personal information due to improper sharing, and assume the privacy risks caused by your own improper operation.
6. Your Rights to Personal Information
6.1 Access and Query Rights
6.1.1 You have the right to access and query your personal information (including account information, file information, operation logs, etc.) through the “Personal Center” or related settings of this Service, and we will provide you with convenient query channels.
6.2 Correction and Supplementary Rights
6.2.1 If you find that your personal information is incorrect or incomplete and have the right to request correction or supplementation of your personal information through the relevant features of this Service or by contacting us via email, we will process it promptly after verification.
6.3 Right to Delete
6.3.1 You have the right to request the deletion of some or all of your personal information, including uploaded files, account information, etc. We will, after verification, promptly delete the relevant information, provided that it complies with legal and regulatory requirements, and those that cannot be deleted will be anonymized.
6.3.2 If you sign out your account, we will delete all your personal information, except as otherwise prescribed by law and regulations.
6.4 Revocation of the Right to Consent
6.4.1 You have the right to withdraw your consent to the collection, use, and sharing of personal information. Upon withdrawal of consent, we will stop processing the relevant personal information, but this does not affect the legality of processing activities previously completed based on your consent.
6.4.2 You may withdraw your consent to device permissions and information collection through device settings, in-service settings, etc., which may affect the normal use of some service functions.
6.5 Complaints and Rights to Complaint
6.5.1 If you believe that our personal information processing activities violate your privacy rights, or you object to the processing of your personal information, you can submit a complaint or complaint by contacting us via email, and we will respond to it within 7 business days after receiving it.
7. Privacy Policy Updates and Notifications
7.1 Policy Updates
7.1.1 We have the right to amend this Policy in accordance with updates to international privacy protection laws and regulations, and to adjust the functionality of the Service. The revised Policy will be published in a prominent position on this Service Platform, and the date of update will be clearly marked.
7.1.2 If there are significant changes to this Policy (including but not limited to significant adjustments to the scope of personal information collection, use purposes, and sharing rules), we will notify you in advance through platform announcements, email, etc., to ensure you are aware of the changes.
7.2 Notification Methods
7.2.1 Updates to this Policy, important privacy-related reminders, will be delivered through the service‘s site letter, bulletin board, and email address provided when you register, and will be considered valid upon delivery.
7.2.2 You should periodically review this Policy and related notifications, and if you continue to use this Service, it is considered that you agree to the revised Policy.
8. Dispute Resolution and Disclaimer
8.1 Dispute Resolution
8.1.1 Any disputes arising from or related to this Policy should first be resolved by friendly negotiation; if negotiation fails, either party has the right to bring a lawsuit to the court with jurisdiction in your region, or to submit to arbitration under a mutual agreement.
8.1.2 The establishment, execution, interpretation and dispute resolution of this Policy are governed by the applicable laws of your region, excluding the application of any conflicting law rules.
8.2 Disclaimer
8.2.1 We are not responsible for the leakage, loss, or alteration of personal information resulting from irresistible forces (including, but not limited to, earthquakes, typhoons, floods, wars, network disruptions, third-party service failures, etc.).
8.2.2 We do not take responsibility for personal information security risks that are not caused by us, such as your own misconduct, account information leakage, or third-party unauthorized intrusion.
8.2.3 We provide reasonable guarantees for the privacy protection of this Service, but do not commit to absolute security. If personal information is leaked due to technical limitations, cyber attacks, or other factors beyond our control, we will endeavor to take remedial measures and cooperate with relevant investigations.
8.2.4 This Policy only regulates our behavior in processing personal information. We are not responsible for the privacy protection of third-party services, third-party links, and you should review the third-party privacy policies on your own.