Europe Trade SL Privacy Policy


Update Date: April 6th, 20233

Effective Date: April 6th, 2023


Europe Trade SL. (hereinafter referred to as "we") is well aware of the importance of personal information to you, and will try our best to protect the safety and reliability of your personal information. We are committed to maintaining your trust in us, abide by the following principles, and protect you Personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of least sufficiency, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. At the same time, we promise that we will take corresponding security protection measures to protect your personal information according to the mature security solutions in the industry. In view of this, we have formulated this "Europe Trade SL Privacy Policy" (hereinafter referred to as "this Policy/this Privacy Policy") and remind you:

This policy applies to Europe Trade SL products or services. If the products or services of our affiliates use products or services provided by Europe Trade SL (such as logging in directly with a Europe Trade SL account) without an independent privacy policy, this policy also applies to those products or services.

It should be noted that this policy does not apply to services provided to you by other third parties, nor does it apply to products or services in Europe Trade SL for which privacy policies have been independently set.

Before using various Europe Trade SL products or services, please be sure to read and thoroughly understand this policy, and use the relevant products or services after confirming your full understanding and agreement. Once you start using Europe Trade SL products or services, it means that you have fully understood and agreed to this policy. If you have any questions, comments or suggestions about the content of this policy, you can contact us through the various contact methods provided by Europe Trade SL.

This Privacy Policy section will help you understand the following:

1、How we collect and use your personal data

2、How we use cookies, similar technologies and SDK technologies

3、How we share, transfer, and publicly disclose your personal information

4、How we protect your personal information

5、How you manage your personal information

6、How we process personal information of minors

7、How your personal information is transferred around the world

8、How this Privacy Policy is Updated

9、How to contact us


1、How we collect and use your personal data

Personal data refers to various information recorded electronically or in other ways that can identify the personal identity of a natural person alone or in combination with other information, including but not limited to the natural person's name, date of birth, ID number, personal biometric information, address, telephone number Number. For Rabbit Doubt, personal data includes but is not limited to personal sensitive information.

You understand and agree that:

1. We will use the personal data collected in accordance with the provisions of this Privacy Policy and in order to realize the functions of our products and or services.

2. After collecting your personal data, we will de-identify the data through technical means, and the de-identified information will not be able to identify the subject. Please understand and agree that in this case, we have the right to use the de-identified information, and without disclosing your personal data, we have the right to analyze the user database and make commercial use.

3. Please note that all personal data you provide when using our products and/or services will continue to be authorized by us during your use of our products and/or services unless you delete or refuse our collection through system settings. When you cancel your account, we will stop using and delete your personal data.

4. We will collect statistics on the usage of our products and or services, and may share these statistics with the public or third parties to show the overall usage trends of our products and or services, but these statistics do not contain any of your identity identifying information.

5. When we display your personal data, we will desensitize your information by means of content replacement and anonymization to protect your information security.

6. When we want to use your personal data for other purposes not specified in this policy, or use the information collected based on a specific purpose for other purposes, we will ask for your prior consent in the form of a check. .

When you use our products and or services, we need your personal data that may need to be collected and used, including the following two:

1. In order 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 the corresponding information, you will not be able to use our products and or services normally;

2. In order 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 it, you will not be able to use the relevant additional functions normally or achieve the functional effects we intend to achieve, but it will not affect your normal use of the basic functions of our products and services.

We collect and use your personal data for the following purposes described in this policy:

(1) Help you become our user

To complete the account creation, you will need to provide the following information: your email address, and create a username and password.

The above information you provide will continue to authorize us to use it during your use. When you voluntarily cancel your account, we will anonymize or delete your personal information as soon as possible in accordance with the requirements of applicable laws and regulations.

(2) Display and push products or services for you

In order to improve our products or services and provide you with personalized information search services, we will extract your browsing, search preferences, behavior habits, location information and other characteristics based on your browsing and search records, device information, and location information. Perform indirect crowd portraits based on feature tags and display and push information.

If you do not want to accept the commercial advertisements we send you, you can cancel at any time through the corresponding product unsubscribe function.

(3) To provide you with goods or services

1、Order and payment for virtual goods

Paid virtual goods in this app, including but not limited to offline package purchases, require you to pay the corresponding amount of currency to place an order and use it after payment is complete. After placing the order, you can choose to use the account balance or the payment services provided by the third-party payment institutions that cooperate with us (non-balance payment methods such as Google in-app purchases, hereinafter referred to as "Google in-app purchases"). Collect your registered account number, but we need to share your order number and transaction amount with these payment institutions to confirm your payment instructions and complete the payment.

2、Order management function

In order to facilitate you to understand and query the order information and manage the order information, we will collect the order information generated during the use of our services to show you and facilitate your order management.

(4) When you use the core functions of the APP

In order to better provide related services such as hardware device connection (recording pen, translation stick, earphone, etc.), recording, translation, speech-to-text, text-to-speech, offline translation and other related services, we will collect necessary information according to the specific functions of the service you use. User Info:

1. location information. For intelligent allocation of optimal servers.

2. System default language. Used to match the APP default language and translate the default language for you.

3. Information about other Bluetooth devices being connected. Used to determine whether the headset function can be performed normally.

in addition:

1. When you use the voice translation service, we will ask you to authorize the microphone and voice-related permissions. If you refuse to authorize the service, you will not be able to use this function, but it will not affect your normal use of other functions of the APP.

2. When you update your information on the personal information page, we will ask you to authorize camera and storage permissions. If you refuse to authorize the service, you will not be able to use this function, but it will not affect your normal use of other functions of the APP.

3. When you use offline translation, we will request your device information permission to obtain your device information as a unique identifier of your device to verify the normal use of offline translation. If you refuse to authorize the service, you will not be able to use this function, but it will not affect your normal use of other functions of the APP.

(5) To provide you with security

In order to improve the security of your use of the services provided by us and our affiliated companies and partners, to protect the personal and property safety of you or other users or the public, and to better prevent phishing websites, fraud, network vulnerabilities, computer viruses, and network attacks , network intrusion and other security risks, to more accurately identify violations of laws and regulations or Europe Trade SL related agreement rules, we may use or integrate your user information, transaction information, device information, relevant network logs and our affiliates, partners to obtain your Authorized or legally shared information to comprehensively judge your account and transaction risks, perform identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

(6) Other purposes

When we use the information for other purposes not specified in this policy, or use the information collected for a specific purpose for other purposes, we will ask for your prior consent.

(7) Exceptions to authorization and consent

According to relevant laws and regulations, the collection of your personal information does not require your authorization and consent in the following situations:

1、related to national security and national defense security;

2、Those related to public safety, public health, and major public interests;

3、related to criminal investigation, prosecution, trial and execution of judgments;

4、In order to protect the personal information subject or other individuals' life, property and other important legitimate rights and interests, but it is difficult to obtain your consent;

5、The collected personal information is disclosed to the public by you;

6、Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

7、Necessary to enter into a contract at your request;

8、Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and disposing of faults in the products or services;

9、necessary for legitimate news reporting;

10、When it is necessary for academic research institutions to carry out statistical or academic research based on public interests, and when providing academic research or description results, the personal information contained in the results is de-identified;

11、Other circumstances stipulated by laws and regulations.

If we stop operating Europe Trade SL products or services, we will promptly stop the collection of your personal information, notify you of the cessation of operations in the form of one-by-one delivery or announcement, and delete or anonymize the personal information we hold .


2、How we use cookies, similar technologies and SDK technologies

(1) Cookies

To ensure the website works properly, to provide you with an easier experience, and to recommend to you content that may be of interest to you, we store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of cookies, websites can store data such as your preferences.

(2) Web beacons and pixel tags

In addition to cookies, we also use other similar technologies such as web beacons and pixel tags on our website. For example, an email we send you may contain an address link to the content of our website, and if you click on the link, we will track the click to help us understand your product or service preferences so that we can proactively improve customer service experience. A web beacon is usually a transparent image embedded in a website or email. With the help of pixel tags in emails, we can tell if an email has been opened. If you do not want your activity to be tracked in this way, you can unsubscribe from our mailing list at any time.

(3) SDK technology

The SDK technology is provided by the third-party agencies we work with, and we are only aware of the permissions that require authorization. Third parties will need to collect your information, and we cannot obtain your information unless the third party explicitly discloses to us the sensitive information to be collected. For the permissions requested by third-party organizations and the sensitive information collected explicitly disclosed to us, please refer to the "SDK Technical Documentation" for details.

The refusal of the third-party agency to provide information will only make you unable to use the functions carried by the technology provided by the third-party agency, but will not affect your use of other functions of Europe Trade SL.

(4) Third-party SDK directory

We will strictly test the access to the third-party SDK, and give you the latest information on the access to the SDK in a timely manner. For details, please refer to the official privacy policy of the third-party SDK.

name:MobSDK

purpose of usage:obtain SMS verification code

usage instructions:Send verification code when user registers

Third-party SDK privacy policy or official website

name:FaceBook SDK

purpose of usage:Used to authorize login

usage instructions:The account that the user fills in when registering the APP

Third-party SDK privacy policy or official website

name:WeChat SDK

purpose of usage:Used for in-app product payment and WeChat authorized login

usage instructions:The account that the user fills in when registering the APP

Third-party SDK privacy policy or official website

name:Alipay SDK

purpose of usage:For in-app product payments

usage instructions:The account that the user fills in when registering the APP

Third-party SDK privacy policy or official website

name:BrainTree SDK

purpose of usage:For in-app product payments/p>

usage instructions:The account that the user fills in when registering the APP

Third-party SDK privacy policy or official website

name:Google SDK

purpose of usage:For in-app product payments

usage instructions:The account that the user fills in when registering the APP

Third-party SDK privacy policy or official website

name:Microsoft SDK

purpose of usage:for voice function

usage instructions:The account that the user fills in when registering the APP

Third-party SDK privacy policy or official website

name:iFLYTEK SDK

purpose of usage:For offline package download statistics

usage instructions:unique device identifier

Third-party SDK privacy policy or official website


3、How we share, transfer, and publicly disclose your personal information

(1) Sharing

We will not share your personal information with companies, organizations and individuals other than Europe Trade SL service providers, with the following exceptions:

1、Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

2、Sharing under statutory circumstances: We may share your personal information externally in accordance with laws and regulations, litigation and dispute resolution needs, or as required by administrative and judicial authorities.

3、Sharing with affiliated companies: In order to facilitate us to jointly provide services to you based on associated accounts, recommend information that may be of interest to you, or protect the personal and property safety of Europe Trade SL affiliates or other users or the public, your personal information may be shared with you. Shared by our affiliates. We will only share necessary personal information (for example, in order for you to use the Europe Trade SL account to use our affiliated company's products or services, we will share your necessary account information with the affiliated company), if we share your personal sensitive information or the affiliated company changes personal information Your authorization and consent will be sought again for the purpose of use and processing of the information.

4、Sharing with Authorized Partners: Some of our services will be jointly provided by us and authorized partners only for the purposes stated in this Privacy Policy. We may share some of your personal information with our partners to provide better customer service and user experience. For example, arranging partners to provide services. We will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and only share personal information necessary to provide services. Our partners are not authorized to use the shared personal information for other purposes unrelated to the product or service.

At present, our authorized partners include the following types: (1) Authorized partners for advertising and analysis services. Unless we have your permission, we will not use your personally identifiable information (referring to information that can identify you, such as name or email address, through which you can be contacted or identified) with the provision of advertising, analytics services partner sharing. We provide these partners with information about the reach and effectiveness of their advertising without providing your personally identifiable information, or we aggregate this information so that it does not personally identify you. For example, we may only tell advertisers how effective their ads are, or how many people viewed their ads or installed apps after seeing them, or to partner with them only after they agree to abide by our advertising guidelines. Partners provide non-personally identifiable statistical information (eg "Male, 25-29 years old, located in Beijing") to help them understand their audience or customers. (2) Suppliers, service providers and other partners. We send information to suppliers, service providers and other partners who support our business, including providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customer service, payment facilitation Or conduct academic research and surveys.

For companies, organizations and individuals with whom we share personal information, we will sign strict data protection agreements with them, requiring them to process personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

(2) Transfer

We will not transfer your personal information to any companies, organizations and individuals, except in the following cases:

1、Transfer with express consent: We will transfer your personal information to other parties with your express consent;

2、In the case of merger, acquisition or bankruptcy liquidation, or other situations involving merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require new companies and organizations that hold your personal information to continue to be bound by this policy, Otherwise, we will require the company, organization and individual to seek authorization from you again.

(3) Public disclosure

We will only publicly disclose your personal information in the following circumstances:

1、With your explicit consent or based on your active choice, we may publicly disclose your personal information;

2、If we determine that you have violated laws and regulations or seriously violated the rules of the relevant agreements of Europe Trade SL, or to protect the personal and property safety of Europe Trade SL and its affiliates users or the public, we may obtain legal notices from you in accordance with laws and regulations or the rules of relevant agreements of Europe Trade SL Disclosure of personal information about you with your consent, including related violations and actions Europe Trade SL has taken against you.

(4) Exceptions to prior authorization and consent when sharing, transferring, and publicly disclosing personal information

In the following situations, sharing, transferring and publicly disclosing your personal information does not require your prior authorization and consent:

1、related to national security and national defense security;

2、Those related to public safety, public health, and major public interests;

3、related to criminal investigation, prosecution, trial and execution of judgments;

4、In order to protect your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain my consent;

5、Your personal information disclosed to the public by yourself;

6、Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

According to the law, sharing and transferring de-identified personal information and ensuring that the recipient of the data cannot recover and re-identify the subject of the personal information is not an external sharing, transfer or public disclosure of personal information. Storage and processing will not be required to notify you and obtain your consent.


4、How we protect your personal information

(1) We have taken reasonable and feasible security protection measures in line with industry-wide solutions to protect the personal information provided by you and prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information. For example, when data (such as credit card information) is exchanged between your browser and the server, it is encrypted and protected by the SSL (Secure Socket Layer) protocol; we will use encryption technology to improve the security of personal information; we will use trusted protection mechanisms To prevent personal information from being maliciously attacked; we will deploy access control mechanisms and try our best to ensure that only authorized personnel can access personal information; and we will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

(2) We have an industry-leading data security management system with data as the core and around the data life cycle, which improves the security of the entire system from multiple dimensions such as organizational construction, system design, personnel management, and product technology.

(3) We will take reasonable and feasible measures to try our best to avoid collecting irrelevant personal information. We will only retain your personal information for as long as is necessary to achieve the purposes described in this policy, unless an extension of the retention period is required or permitted by law.

(4) The Internet is not an absolutely secure environment and we strongly recommend that you do not send personal information using communication methods other than those recommended by Europe Trade SL. You can connect and share with each other through our services. When you create a communication, transaction or sharing through our services, you can choose the object of communication, transaction or sharing independently, as a third party who can see your transaction content, contact information, exchange information or shared content and other related information.

The Internet is not an absolutely secure environment and we strongly recommend that you do not send personal information using communication methods other than those recommended by Europe Trade SL. You can connect and share with each other through our services. When you create a communication, transaction or sharing through our services, you can choose the object of communication, transaction or sharing independently, as a third party who can see your transaction content, contact information, exchange information or shared content and other related information.

Please note that the information you share voluntarily or even publicly when using our services may involve your or others' personal information or even personal sensitive information, such as when you post news or choose to upload personal information in public places such as group chats and circles picture of. Please consider more carefully whether to share or even publicly share relevant information when using our services.

Please use a complex password to help us keep your account secure. We will do our best to keep any information you send us secure.

At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.


5、How you manage your personal information

You can access and manage your personal information in the following ways:

(1) Access to your personal information

You have the right to access your personal information, subject to exceptions provided by laws and regulations. You can access your personal information yourself by:

Account Information - If you wish to access or edit personal information in your account, bind your phone, change your password, add security information or close your account, etc., you can perform such operations within the app by logging in to your account.

Profile - If you wish to access or edit your nickname, avatar, nationality, location, self-introduction or other information in your profile, you can do so within the app by logging into your account.

Dynamic Information - You can log in to your account to access or clear your dynamic posting history through your "Personal Home Page".

If you cannot access such personal information through the above path, you can contact us through Europe Trade SL customer service at any time. We will respond to your request for access within 30 days.

For other personal information generated during your use of our products or services, we will provide you with the relevant arrangements in "(7) Responding to your above-mentioned requests" in this article.

(2) Correcting or supplementing your personal information

You have the right to ask us to make corrections or supplements when you find that the personal information we process about you is inaccurate. You can apply for correction or supplementation through the methods listed in "(1) Access to your personal information" in this article.

(3) Delete your personal information

You can delete some of your personal information through the methods listed in "(1) Accessing your personal information" in this article.

You may request us to delete personal information in the following circumstances:

1、If our processing of personal information violates laws and regulations;

2、If we collect and use your personal information without your express consent;

3、If our processing of personal information is in serious breach of our agreement with you;

4、If you no longer use our products or services, or you voluntarily cancel your account;

5、If we permanently cease to provide you with products or services.

If we decide to respond to your deletion request, we will also try our best to notify the subjects who have obtained your personal information from us and require them to delete it in a timely manner, unless otherwise provided by laws and regulations, or these subjects obtain your independent authorization.

When you delete information from our services, we may not delete the corresponding information from the backup system immediately, but will delete the information when the backup is updated.

(4) Change the scope of your authorization and consent

Each business function requires some basic personal information to be completed (see "Article 1" of this Privacy Policy). In addition, for the collection and use of additional personal information, you can contact Europe Trade SL customer service to give or withdraw your authorization.

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 previous processing of personal information based on your authorization.

(5) The personal information subject cancels the account

If you need to cancel your Europe Trade SL account, you can apply for cancellation according to the following path, enter Europe Trade SL - click Settings in the upper right corner - User Feedback, submit the account information you need to cancel, and we will do it for you within 15 working days after verification log out. After the cancellation is completed, your account data and related rights will not be restored.

(6) Constraining the automatic decision-making of the information system

In some business functions, we may only make decisions based on non-human automatic decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will also provide a way to appeal without infringing on Europe Trade SL's trade secrets or other user rights and public interests.

(7) Responding to your above request

For security, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

We will respond within 30 days. If you are not satisfied, you can also file a complaint through Europe Trade SL customer service.

For your reasonable requests, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost as appropriate. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, the need to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical.

In the following cases, we will not be able to respond to your request in accordance with the requirements of laws and regulations:

1、related to national security and national defense security;

2、Those related to public safety, public health, and major public interests;

3、related to criminal investigation, prosecution, trial and execution of judgments, etc.;

4、There is sufficient evidence to show that the subject of personal information has subjective malice or abuse of rights;

5、Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

6、involving trade secrets.


6、How we process personal information of minors

Minors may not create their own user accounts without the consent of their parents or guardians. If you are a minor, it is recommended that you ask your parents or guardians to read this Privacy Policy carefully, and use our services or provide us with information with the consent of your parents or guardians.

For the collection of minors' personal information using our products or services with the consent of parents or guardians, we will only use, share, and transfer minors' personal information permitted by laws and regulations, express consent of parents or guardians, or necessary to protect minors or disclose this information.


7、How your personal information is transferred around the world

Personal information collected and generated during our operations in the People's Republic of China is stored in China, except in the following cases:

1、Laws and regulations have clear provisions;

2、with your express authorization;

3、You conduct cross-border live broadcasts/post news and other personal active behaviors through the Internet.

In response to the above situations, we will ensure that your personal information is adequately protected in accordance with this Privacy Policy.


8、How to contact us

Our Privacy Policy is subject to change.

We will not limit your rights under this Privacy Policy without your express consent. For major changes, we will provide prominent notices (including that we will notify you through Europe Trade SL publicity or even provide you with pop-up prompts).

Material changes referred to in this policy include, but are not limited to:

1、There has been a major change in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;

2、We have significant changes in control and so on. Such as changes in owners caused by mergers and acquisitions, etc.;

3、Changes to the main objects of personal information sharing, transfer or public disclosure;

4、material changes in your rights to participate in the processing of personal information and the way they are exercised;

5、When our responsible department responsible for handling personal information security, contact information and complaint channels change;

6、When the personal information security impact assessment report indicates that there is a high risk.

We will also archive older versions of this Privacy Policy for your review.


9、How to contact us

You can contact us in the following ways and we will respond to your request within 30 days:

1、If you have any questions, comments or suggestions about the content of this policy, you can contact Europe Trade SL customer service;

2、We have also established a dedicated department for personal information protection, which you can contact.

If you are not satisfied with our response, especially if you believe that our processing of personal information has harmed your legitimate rights and interests, you can also seek a solution by filing a lawsuit with a court of competent jurisdiction where the defendant is domiciled.