Wing Intelligence Co., Ltd. (hereinafter referred to as "Wing Intelligence" or "we") understands the importance of personal privacy to you and will do our best to protect the security of your personal privacy. To provide you with a better browsing experience, we have established this General Privacy Statement (hereinafter referred to as "this Policy") to help you fully understand our rules for processing personal information, including how we collect, use, share, store, and protect your personal information during your browsing of the FlexGalaxy.AI website (https://flexgalaxy.ai) (hereinafter referred to as "this Website") and your use of related service features, the purposes, methods, and scope of our processing of your personal information, and how you may manage your personal information.
Please be sure to carefully read and fully understand all contents of this Policy. In specific scenarios, we may explain the purposes and methods of personal information processing through page prompts, pop-ups, feature update notes, and other means. Content communicated to you through these means constitutes part of this Policy and has the same effect as this Policy. If you have any questions, opinions, or suggestions regarding the contents of this Policy, you may contact us through the means specified in Section 10 of this Policy.
Special Notice
By agreeing to this Policy, you confirm that you have fully understood the information necessary for browsing this Website and using the service features involved (which may include personal information and/or sensitive personal information) and provide written consent for us to process such information.
Definitions of terms used in this Policy:
- "Personal Information": Information that can identify an individual when used alone or in combination with other information;
- "Sensitive Personal Information": Personal information that, once leaked or illegally used, may easily lead to infringement of a natural person's dignity or endanger personal and property safety, including biometric data, religious beliefs, specific identity, medical health, financial accounts, location tracking, and other information, as well as personal information of minors under the age of fourteen;
- "Processing": The collection, storage, use, processing, transmission, provision, disclosure, deletion, and other handling of personal information;
- "Automated Decision-Making": Activities that automatically analyze and evaluate an individual's behavioral habits, interests, or economic, health, or credit status through computer programs and make decisions accordingly;
- "Anonymization": The process by which personal information is processed so that it cannot identify a specific natural person and cannot be restored.
1. Scope of This Policy#
1.1 This Policy applies only to the content, links, and related service features displayed on the FlexGalaxy.AI website (https://flexgalaxy.ai) operated by Wing Intelligence Co., Ltd. If other products or services provided by us and our affiliated companies have separate privacy policies or similar legal documents, such separate privacy policies or legal documents shall take precedence.
1.2 This Policy does not apply to any products or services provided to you by any third party. We do not assume any legal liability for any third party's improper processing of personal information. For example, products or services provided by third parties in Marketplace on this Website are not subject to this Policy.
1.3 Depending on the use of various products or services, we may provide specific explanations regarding the processing of certain personal information through updates to this Policy, page prompts, pop-ups, feature update notes, and other means as appropriate.
2. How We Collect and Use Your Personal Information#
2.1 When you browse this Website or use related service features, we will strictly comply with relevant laws and regulations and collect your personal information through the following means:
2.1.1 Collecting personal information you actively provide to us. In the following scenarios, we may request you to provide necessary personal information to implement specific service features, and we will collect such personal information that you actively provide:
(1) When you use the "Contact Us" feature of this Website (or other similar features) or download certain content from this Website, we may ask you to provide your contact information, such as name, position, company name, address, phone number, email address, etc.;
(2) When you voluntarily submit certain information to us, such as filling out a survey about your user experience, we will collect the information you provide.
2.1.2 Automatically collecting personal information generated when you browse this Website. When you browse this Website, we may collect the following information through Cookies, web beacons, or other similar technologies:
(1) Device information: We will receive and record information related to the device you use when browsing this Website (such as device model, operating system version, device settings, unique device identifiers, and other hardware and software characteristic information), and location-related information of the device (such as IP address, GPS location, and sensor information from Wi-Fi access points, Bluetooth, and base stations that can provide relevant information);
(2) Log information: When you use the services provided by this Website, we will automatically collect detailed usage information about our services as network logs. This usage information may include IP address (or proxy server address), device and application identifiers, browser type, mobile carrier, pages and files viewed, search queries, system configuration information of the operating system you use, and your language, access date and time, etc.;
(3) Browsing behavior data: We may record your browsing behavior on this Website, including links clicked and pages viewed;
(4) Timestamps and session information: We may record your access time, dwell time, and page visit order, and other timestamp and session information;
(5) Referrer information: We may record which website or source you used to access this Website;
(6) Geolocation information: We may obtain your precise or approximate geographic location through location information provided by your device or browser;
(7) Interaction data: We may record the ways you interact with this Website, including but not limited to filling out forms, submitting comments, participating in surveys, etc.;
(8) Device sensor data: We may access data from device sensors (such as accelerometers and gyroscopes) to provide specific features or services;
(9) Advertising identifiers: If your device has advertising identifiers (e.g., IDFA on iOS or Advertising ID on Android), the website may automatically collect these identifiers for advertising targeting and analytics;
(10) Social media information: If you choose to log in through a social media account or connect with the website, we may access and collect information related to that social media account.
2.1.3 Collecting relevant information from third-party sources. We may obtain information from third-party commercial information providers, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, and other information, which may contain personal information or sensitive personal information. We will strictly require any third party providing information to us to comply with relevant legal requirements, obtain necessary consent and authorization before providing information to us, and anonymize or otherwise technically process the information. However, we shall not be responsible for any third party's violation of laws and regulations in processing personal information or infringing on personal privacy.
2.2 We collect your personal information only for the following purposes. If you choose not to provide information necessary for certain service features of this Website, it may affect your use of the corresponding products or services, but will not affect your browsing of this Website's content or use of this Website's basic features:
(1) Operating and managing this Website, providing you with the content you access and request (such as downloading certain content from this Website), and providing you with certain service features of this Website;
(2) Maintaining the security of services, systems, and applications related to this Website, and protecting the legitimate rights and interests of you and others;
(3) Managing registered users' account information and fulfilling user agreements and terms of service;
(4) Providing sales services and verifying your purchases and payments on this Website;
(5) Developing and improving this Website;
(6) Evaluating and improving user experience;
(7) Reviewing the performance of relevant terms in applicable customer contracts;
(8) Assessing capacity requirements for our services and new potential customer opportunities;
(9) Conducting marketing research, displaying personalized advertising and content, and sending marketing information from us and our affiliated companies and partners;
(10) Complying with obligations prescribed by laws and regulations, or relevant rulings, orders, or requirements of government departments and judicial authorities.
2.3 Information collected through the means described in this Policy may contain your sensitive personal information. Before collecting your sensitive personal information, we should obtain your separate consent. Please carefully consider whether you agree. If you agree to our collection or provision of such sensitive personal information, it shall be deemed that you have fully understood that the leakage or illegal use of such sensitive personal information may lead to infringement of your dignity or endanger your personal and property safety, and that you have fully understood the purposes and necessity of our processing of such sensitive personal information.
2.4 We will conduct a personal information protection impact assessment in advance and utilize the collected personal information for automated decision-making on the premise of recording the processing situation, ensuring the transparency and fairness of decision-making results, not imposing unreasonable differential treatment on you regarding transaction prices and other transaction conditions, and ensuring that options not targeted at your characteristics are simultaneously provided, or providing you with a convenient way to refuse. When decisions that have a significant impact on your personal rights and interests are made through automated decision-making, you have the right to require us to provide an explanation and have the right to refuse decisions made solely through automated decision-making. Under this premise, we will carry out the following activities based on the results of automated decision-making:
(1) Conducting marketing research and displaying personalized advertising and content;
(2) Sending you emails, text messages (including commercial text messages), push notifications, and other communications to promote or publicize products or services of Wing Intelligence and its affiliated companies and partners;
(3) Using Cookie data to better understand your behavior, improve feature design, and optimize user experience;
(4) Other activities based on automated decision-making.
3. How We Use Cookies and Similar Technologies#
3.1 We use Cookies and similar technologies (such as web beacons, tags, and JavaScript that can be used independently or in conjunction with Cookies) to aggregate information about the use of this Website and interactions with emails we send.
3.2 When you visit this Website, we or authorized third parties may place a Cookie on your browser and/or device that collects information about your online activities over time and across different websites (which may include personal information). Cookies allow us to track usage, determine your browsing preferences, and improve and customize your browsing experience.
3.3 We use both temporary and persistent Cookies on this Website. Temporary Cookies exist only during the session and disappear from your computer when you close your browser or turn off your computer. Persistent Cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of Cookies in your browser, but choosing to disable Cookies may limit your use of certain features or functions of this Website or services. Currently, various web browsers including Google Chrome, Edge, Internet Explorer, Firefox, and Safari offer a "Do Not Track" (DNT) option that sends a signal to websites visited by users about the user's DNT settings. We respect "Do Not Track" signal identifiers or similar technologies. If your device has deployed such a "Do Not Track" (DNT) browser mechanism, we will not track, use Cookies, or display advertising.
3.4 We also use web beacons in this Website and email communications. For example, we may place web beacons in marketing emails so that when you click on a link in the email that points to one of our websites, we receive a notification. This technology will be used to improve this Website and provide email communication services.
3.5 This Website may use social media features, such as Weibo and WeChat "like" or "share" buttons and other sharing widgets (hereinafter referred to as "Social Media Features"). You may use the options provided by such Social Media Features to publish your activity information on the website to your personal page on third-party social media networks and share it with others in your network. Social Media Features are hosted by the corresponding social media network or directly on this Website. If you click to access these features through this Website, such networks may receive information showing that you visited this Website. If you are logged into a social media account, the corresponding social media network may link your visit to this Website with your social media profile. Your interactions with Social Media Features should be governed by the privacy policy of the company providing the relevant Social Media Features, and this Policy does not apply.
3.6 Research on information collected by Cookies and related technologies is solely for the purpose of improving service/product quality and optimizing user experience. We will not use it for any purpose beyond those described in this Policy. Furthermore, for third-party partners who integrate their websites or services into our products or services, we commit to making every effort to require them to comply with the requirements regarding the application of Cookies and related technologies under this Policy, informing you of the name or names, contact information of third parties when necessary, as well as the purposes and methods of processing information collected by Cookies and related technologies, and obtaining your separate consent.
3.7 If you do not agree with our use of Cookies and similar technologies as described above, you should immediately stop browsing or using related service features and exit this Website. Under this premise, your continued browsing or use shall be deemed as your granting of consent.
4. How We Protect Your Personal Information#
4.1 Information Security Technical Measures
4.1.1 We will adopt security protection measures that comply with industry standards and implement security technologies to prevent unauthorized access, use, or modification of your information, and to avoid data corruption or loss.
4.1.2 Our network services employ encryption technologies such as Transport Layer Security protocols, providing browsing services through https and other means to ensure the security of information during transmission.
4.1.3 When using information, such as information display and information correlation calculations, we will employ various de-identification technologies including content replacement and indexing (e.g., SHA256) to enhance the security of information in use.
4.1.4 We employ strict data access permission controls and multi-factor authentication technologies to minimize unauthorized access, use, or modification of information.
4.1.5 We employ automated code security checks and data access log analysis technologies for information security audits.
4.2 Other Security Measures We Take to Protect Information
4.2.1 We protect your information security through the establishment of reasonable institutional norms, including but not limited to: data classification and grading systems, data security management standards, data security development standards, and determining specific permissions for viewing information based on the different roles of data viewing personnel.
4.2.2 We conduct security controls on data through the signing of confidentiality agreements, supervision monitoring, and audit mechanisms.
4.2.3 We conduct security and privacy protection training courses to strengthen employees' security awareness and understanding of information protection policies and related procedures.
4.2.4 We will take measures at the organizational, technical, and practical operational levels to prevent personal information from being accidentally or illegally destroyed, lost, altered, or disclosed or accessed without authorization. Although we follow some generally accepted standards to protect personal information, you should fully understand that no storage or transmission method is 100% secure, and you must be responsible for protecting your own passwords, restricting others from accessing your devices, and taking necessary personal information protection measures.
4.3 Unless otherwise provided by laws and regulations, we will only retain your personal information for the shortest period necessary to achieve the purposes described in this Policy.
4.4 In the event of a personal information security incident (leakage, loss, etc.), we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic circumstances and potential impact of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the provisions of laws and regulations and the requirements of regulatory authorities.
5. Your Rights#
5.1 We attach great importance to your management of information and make every effort to safeguard your rights to access, correct, delete, withdraw consent, and other statutory rights regarding your information, so that you have sufficient ability to protect your privacy and information security.
5.2 Accessing and Correcting Your Information
5.2.1 Except as provided by laws and regulations, you have the right to access or correct your information at any time, specifically including:
(1) Account information;
(2) Device information;
(3) Device usage record information.
5.2.2 If you need to access or correct other information generated during your use of our devices and services, please contact us at any time. We will respond to your request in accordance with the methods and timeframes specified in this Privacy Policy.
5.3 Deleting Your Information
5.3.1 In the following circumstances, you may submit a request to us to delete information through the means specified in this Privacy Policy:
(1) If our processing of information violates laws and regulations;
(2) If you no longer use our devices and services, or you cancel your account;
(3) If we cease providing devices and services, or the retention period has expired;
(4) If you withdraw your consent;
(5) If the purpose of our processing of information has been achieved, cannot be achieved, or is no longer necessary to achieve the processing purpose.
5.4 Changing or Withdrawing Your Consent
5.4.1 You may change the scope of your authorization for us to continue collecting information or withdraw your authorization consent by deleting information, turning off device features, adjusting privacy settings on the FlexGalaxy.AI website, and other means. You may also withdraw all authorization consent for us to continue collecting your information by canceling your account. When you cancel your account, we will stop using and delete your information.
5.4.2 Please understand that certain features of the FlexGalaxy.AI website may require the collection of necessary information to function. When you withdraw your authorization consent, we will be unable to continue providing the services corresponding to the withdrawn authorization consent, but this will not affect the information processing activities previously carried out based on your authorization.
5.5 Canceling Your Account
5.5.1 You may cancel your previously registered account at any time through the following methods:
(1) Online cancellation through the FlexGalaxy.AI console (https://console.flexgalaxy.ai);
(2) Contacting customer service to assist you in canceling your account.
5.5.2 After you cancel your account, the content, information, data, records, etc. under that account will be deleted or anonymized (except as otherwise required by laws and regulations or regulatory authorities). At the same time, once your account is canceled, it cannot be recovered.
5.6 Responding to Your Requests
5.6.1 If you are unable to exercise your rights in the above manner, you may contact us using the contact methods specified in this Privacy Policy. To protect the security of your account, we may first require you to verify your identity when you submit the above requests to us.
5.6.2 For your reasonable requests, we generally do not charge fees, but for requests that are repeatedly made multiple times or exceed reasonable limits, we will charge certain costs as appropriate. For requests that are groundlessly repetitive, require excessive technical means, pose risks to the legitimate rights and interests of others, or are highly impractical, we may refuse them.
5.6.3 Exceptions to Response
In the following circumstances, we will be unable to respond to your request:
(1) Related to our fulfillment of obligations prescribed by laws and regulations;
(2) Directly related to national security or national defense;
(3) Directly related to public safety, public health, or major public interests;
(4) Directly related to criminal investigation, prosecution, trial, and enforcement of judgments;
(5) We have sufficient evidence to show that your request involves subjective malice or abuse of rights;
(6) For the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property;
(7) Responding to your request would cause serious harm to the legitimate rights and interests of other individuals or organizations;
(8) Involving trade secrets.
5.7 In accordance with relevant laws and regulations, national standards, and common practices, we safeguard your right to exercise the following rights over your personal information:
(1) You have the right to restrict or refuse our processing of your personal information;
(2) You have the right to access and copy your personal information;
(3) You have the right to transfer your personal information to a designated entity;
(4) If you find that your personal information is inaccurate or incomplete, you have the right to request us to correct or supplement it;
(5) You may access, modify, and delete the personal information you have provided on your own, or contact us in the manner specified in this Policy to assist you in accessing, modifying, and deleting personal information;
(6) If you believe that we have processed your personal information in violation of laws and regulations, any applicable agreements, commitments, or the provisions of this Policy, you may contact us through the means specified in this Policy to request that we correct or delete your personal information.
5.8 You fully understand that, due to technical limitations, legal or regulatory requirements, we may not be able to satisfy all your requests, but we will provide you with a response within a reasonable period.
5.9 If you are in Japan. In addition to the rights above, under the Act on the Protection of Personal Information you may, in the cases the Act provides, ask us to disclose the retained personal data we hold about you and the records of its provision to third parties; to correct, add to or delete it; and to stop using it, erase it or stop providing it to third parties. Send your request to the contact in Section 10. If you are not satisfied with our response, you may consult the Personal Information Protection Commission of Japan.
5.10 If you are in the European Economic Area, the United Kingdom or Switzerland. We process your personal information on the basis of your consent (for example, for optional cookies and marketing), the performance of a contract with you (for example, managing your account), our legitimate interests in operating, securing and improving this Website (which we balance against your rights), or compliance with our legal obligations. You have the rights of access, rectification, erasure, restriction of processing, data portability and objection, and you may withdraw your consent at any time without affecting processing carried out before the withdrawal. You also have the right to lodge a complaint with the data protection supervisory authority in the country where you live or work, or where an alleged infringement took place.
6. How We Share, Transfer, and Publicly Disclose Your Personal Information#
6.1 We will process your personal information in accordance with laws and regulations and the relevant provisions of this Policy, following the principles of legality, legitimacy, and good faith.
6.2 We will strictly limit the sharing of information in accordance with laws and regulations. With your prior separate consent, we may share your personal information with third parties in the following circumstances:
(1) Sharing your personal information externally as required by laws and regulations, litigation or arbitration needs, or requirements lawfully made by administrative or judicial authorities;
(2) To facilitate transactions or assist in resolving disputes, where sharing your personal information is necessary to facilitate transactions or handle disputes between you and others;
(3) We may entrust trusted partners to provide services and share certain personal information with them. We will inform you of the partner's name, contact information, processing purposes, processing methods, and types of personal information, agree with the partner on the purpose, duration, processing methods, types of personal information, protective measures, and the rights and obligations of both parties, and supervise the partner's personal information processing activities.
6.3 We only provide your personal information to third parties for lawful, legitimate, necessary, specific, and explicit purposes, and will strictly require third parties to process personal information in accordance with agreements, not exceeding the agreed processing purposes, processing methods, etc. Without our consent, they may not provide or entrust others to process your personal information.
6.4 When it is necessary to transfer your personal information due to mergers, divisions, dissolution, or declaration of bankruptcy, we will inform you of the name and contact information of the receiving party and require the receiving party to continue to fulfill all personal information protection obligations.
6.5 We will not transfer your personal information to any company, organization, or individual unless the following conditions are simultaneously met:
(1) Your separate consent has been obtained and all notification obligations have been fulfilled in accordance with relevant laws and regulations;
(2) The receiving party is required to continue to be bound by this Policy.
6.6 We will only publicly disclose your personal information in the following circumstances:
(1) Your separate consent has been obtained;
(2) As necessary for the performance of statutory duties or obligations;
(3) As necessary for responding to public health emergencies, or for protecting the life, health, and property safety of natural persons in emergencies;
(4) For the implementation of news reporting, public opinion supervision, and other acts in the public interest, personal information is disclosed within a reasonable scope;
(5) Processing personal information that you have already made public on your own or other personal information that has been lawfully made public, within a reasonable scope.
7. How We Protect Minors' Personal Information#
This Website is not intended for use by minors. We will not actively collect or process personal information of minors under the age of fourteen, or under a higher minimum age set by the law of your country or region (for example, sixteen in parts of the European Economic Area). If you are a parent or other guardian of such a minor and believe that personal information of the minor has been provided to us without your consent, please contact us through the means specified in this Policy, and we will delete the relevant personal information. Please note that your request cannot guarantee that such personal information will be completely or comprehensively deleted, as some content may have already been reposted to this Website by other visitors.
8. How Your Personal Information Is Transferred Globally#
8.1 Where your information is stored. This Website and the FlexGalaxy.AI Global partition are operated from data centers in Japan (Tokyo region), and the personal information collected through them is stored there. The FlexGalaxy.AI China partition is operated separately within the People's Republic of China, under its own privacy statement and the Personal Information Protection Law of the People's Republic of China.
8.2 Access from other countries and regions. Our affiliated companies and the service providers who help us operate this Website may access personal information from other countries or regions, including the People's Republic of China, only for the purposes described in this Policy and under written obligations that protect it. Those countries or regions may have different data protection laws, or none. Whenever we transfer personal information across borders or allow it to be accessed from abroad, we do so in a manner permitted by applicable data protection law — for example, using the standard contractual clauses approved by the European Commission for transfers from the European Economic Area, the United Kingdom or Switzerland, and the consent or equivalent-protection measures required by the Act on the Protection of Personal Information for transfers from Japan. On request, we will tell you which countries are involved and which safeguards apply.
8.3 Where the law of your country or region requires your separate consent before your personal information is transferred abroad, we will first inform you of the recipient's name and contact information, the processing purposes and methods, the types of personal information, and how you can exercise your rights with the recipient, and obtain your separate consent.
9. How This Policy Is Updated#
We will update this Policy from time to time to reflect the latest changes in our processing practices, technology, legal requirements, and other factors. In such cases, we will update the "Last Updated" date at the top of this Policy. If you continue to browse this Website or use related service features, it shall be deemed that you agree to be bound by the revised Policy. If we make material updates, we may post a notice on this Website before the update takes effect, or notify you through other means.
10. How to Contact Us#
If you wish to exercise your rights regarding your personal information, or have any questions, opinions, or suggestions about this Policy, you may contact us through the following means:
Address: Suite 1101, Building C, Sanlitun SOHO Office, No. 8A Gongti Beilu, Chaoyang District, Beijing
Email: privacy-policy@flexgalaxy.ai
If you have any complaints or concerns regarding privacy rights, we commit to cooperating with you to reach a fair resolution. However, if you believe that we are unable to assist in handling your complaint or concern, you have the right to file a complaint with the competent authority where you live — for example, the Personal Information Protection Commission in Japan, your data protection supervisory authority in the European Economic Area, the United Kingdom or Switzerland, or the cyberspace administration in the People's Republic of China.