Onelap Global Privacy Policy
Effective Date: 31/Mar /2026
Last Updated: 31/ Mar /2026
Qingdao Onelap Technology Co., Ltd. (referred to herein as “Onelap”, “we”, “our”, or “us”) and its affiliates, recognizes the importance of protecting the personal data we may collect from visitors and any other individual or entity (“Users”, “you”, or “your”). This Privacy Policy applies to data collection and privacy practices of Onelap and when we collect and process personal data through your use of the website www.onelap.com, Onelap App, OnelapFit App, and other onelap-related sites, software and applications accessible on or by any top-level Onelap domain owned by us (each, a “Site” and collectively the “Sites”), through our social media pages that we control, and through email messages that we may send to you (collectively, the “Services”).
Our Privacy Policy explains: (1) what personal data we collect; (2) why we collect it; (3) how we use that data; (4) how we may share it; (5) the choices we offer, including how to access, update, correct and delete data; and (6) the measures we take to keep your data safe.
Specifically, our Privacy Policy covers the following topics:
1. When this Privacy Policy Applies
2. How We Process Your Personal Data
3. Our Legal Basis for Collecting Personal Data
4. Your Failure to Provide Personal Data
5. Our Retention of Your Personal Data
6. Recipients of Personal Data:
7. International Transfer of Personal Data
8. How We Protect Personal Data
10. Cookies and Similar Technologies Policy
16. Changes to this Privacy Policy
Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the People’s Republic of China, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer of Personal Data” section below. If you do not agree to the transfer, storage and use of your information in the People’s Republic of China, and any other country where we operate, please do not use the Sites or Services.
If you have any questions or comments about this Privacy Policy, please contact us as indicated in the “How to Contact Us” section below.
Our Privacy Policy applies to all of the Services offered by Onelap or use our Sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.
Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Sites or Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.
We collect information, including personal data, to provide better Services to all our Users. We use the term “Personal Data” or to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.
“Sensitive Personal Data” refers to a smaller subset of Personal Data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation.
When you use our Services, we collect Personal Data in the following ways:
· When you visit our website
When you visit our website at www.onelap.com, data is temporarily processed on our webserver in order to provide you with the requested content of the website. For this purpose, we may use cookies or similar technologies, web analysis tool such as Google Analytics to track statistics and user interests and behavior, as well as generate and store your web analysis profile. The types of analytical data that are collected include browsing history, user location, length of stay, IP address, and device identifier, etc. This allows us to improve our website and the goals of our website.
You may choose to provide us with email address by completing forms on our Sites or when creating and signing into your account. You may also use the email address to sign into your account of Onelap App and OnelapFit App.
· When you use our mobile applications
1. Create an account
When you use Onelap App and/or OnelapFit App, we will ask you to create a User account. Certain information is required when creating an account to use our Services on the mobile applications, such as your email address (as username) and password.
You may also log into and use Onelap App and/or OnelapFit App through third-party platform accounts (including Apple and Google accounts). When you register or log in via a third-party account, you authorize us to obtain the public information registered on that platform, such as your Apple ID or Google ID. This information will be used to generate a OnelapFit account bound to your third-party platform account, enabling you to log in directly and access our products and services.
2. Device pairing
If you want to track your training and make full use of our Services, you will have to pair your device with Onelap App and/or OnelapFit App. To pair your device, you will have to enable the Bluetooth function on your device to transmit the device ID, device brand and model.
3. Track training and daily use insights for Users
On Onelap App and OnelapFit App, in order to improve your experience with the Services, you may choose to provide additional information such as your gender, birth date, height, weight, location, country, FTP (Functional Threshold Power), physical activity, maximum heart rate, power, cadence. You can choose not to provide certain information, but then you may not be able to take advantage of some features of the Services.
To provide you with analytical data about your workout through the use of Onelap App and OnelapFit App, we process and analyze your sport data (incl. power, speed, pedal rate, heart rate) to reflect your training performance and trend.
4. Location Data
If you grant us access to your location when you use Onelap App and OnelapFit App, we may collect information about your location when you use our Services. Your location can be determined by: IP address, GPS, device permission and information about things near your device, such as Wi-Fi access points and cell towers. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Third party SDK providers (including mapbox) that are embedded on our Services may also collect and analyze your location data. The purpose to collect your location data is to improve our Services, marketing, customer relationships and experiences.
Some features within our applications may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. The specificity of the location data collected may depend on a number of factors, including the device you are using (e.g., laptop, smartphone or tablet) and how you are connected to the Internet (e.g., via cable broadband connection, WiFi). If you enable location services for our mobile applications, we may collect location data periodically as you use or leave open our mobile applications. We may associate such location data with Personal Data you provide to us. Depending on the platform you use to access our mobile applications (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your wireless device or the mobile applications.
5. Device Data
When using Onelap App and OnelapFit App, we or our service provider may collect your unique device ID, phone manufacturer, brand, model, OS version, Bluetooth information, IP address and log data. We may use such information for internal purposes and to provide you a better experience, such as to troubleshoot application problems you may experience. We may associate device ID with Personal Data you provide to us.
6. Email Direct Marketing
You may subscribe to EDM (Email Direct Marketing) to receive important notifications, marketing materials and activity information about the Services from time to time. If you provide your opt-in consent to receiving marketing information from us, we will also process your email address for the purpose of sending you marketing information about our products, services, and Apps, as well as newsletters. You may withdraw your consent at any time through the unsubscribe link at the bottom of our marketing emails.
7. Social Networking
When using our Services or when using certain third party social networking services (for example, Strava or TrainingPeaks) (each a “Social Network”), you may have the option to connect your information or activity on our Services with that Social Network and its users, and to access certain of your Social Network information, as disclosed to you at the time you consent to the connection. Information we may share with a Social Network may include, but is not limited to, technical information about your activity on our Services. Information we may access about you, with your consent, from a Social Network, may include, but is not limited to, your basic Social Network information, your location data, and certain information about your activities on the Social Network. If you permit a connection between a Social Network and our Services, we and that Social Network may be able to identify you and to associate information received pursuant to that connection with information we already have about you. We recommend that you familiarize yourself with the privacy policy and privacy control options of any Social Network with which you choose to share information or to connect our Services.
8. After-sale support
When you interact with our customer support representatives through Onelap App, we collect the device brand and model, images uploaded by you to help troubleshoot and resolve your issue.
9. Team Communication
To provide you with an enhanced training experience, we support the creation of training teams and competitions in Onelap App. You can communicate with your team members by voice during team training. We need to process and transfer your voice chat.
We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest | Sites |
To improve our website and the goals of our website (e.g. improving our visibility on the internet). | Browsing history | We have Legitimate Interest in improving our website and products. | |
To create user web analysis profile | Browsing history , length of stay IP address Device identifier | We will only process your data for analytical purposes if we obtained prior consent form you. | |
To create an account and register you as a new user | Email address | This is necessary to fulfil our contract with you. | Onelap.com； |
To support EDM (Email Direct Marketing) | Email address | We have a legitimate interest to provide you with information about or products including those that are the same or similar to the ones you have inquired about If we cannot rely on legitimate interest as our lawful basis for processing, then we will obtain consent from you | Onelap.com； |
To send you system notifications | Email address | This is necessary to fulfil our contract with you. | Onelap.com； |
To track your training and make full use of our Services, device pairing | Device ID | This is necessary to fulfil our contract with you. | Onelap App； |
To provide you with analytical data about your workout through the use of our Apps | Height | This is necessary to fulfil our contract with you. We will only process your health and sport data if we obtained Explicit Consent from you. | Onelap App； |
To improve our website and mobile interface adaptation | Phone manufacturer, Phone brand, Phone model, OS version, Bluetooth information, IP address | We have Legitimate Interests in improving our digital products
| Onelap App； |
To improve our products and services and customer relationships and experiences | Phone manufacturer, Phone brand, Phone model, OS version, Location, Coarse location | We have Legitimate Interest in developing and improving our service offering | Onelap App； |
To inform our marketing strategy and customer segmentation | Location, IP address, Coarse location, Bluetooth information | We have Legitimate Interest for internal analytics and segmentation. | Onelap App； |
To activate and connect devices | Phone manufacturer, Phone brand, Phone model, OS version, Bluetooth information | This is necessary to fulfil our contract with you. | Onelap App； |
To send message notifications | Phone manufacturer, Phone model, OS version | This is necessary to fulfil our contract with you. | Onelap App； |
To identify and connect any User’s sport devices | The name, manufacturer, category, model, unique identifier and other device information of the Sport devices | This is necessary to fulfil our contract with you. | Onelap App； |
To store, manage and analyze sport data | The sport data and Fit files generated by the sport devices and uploaded to Onelap App and OnelapFit App | This is necessary to fulfil our contract with you. We will only process your sport data if we obtain Explicit Consent from you. | Onelap App； OnelapFit App |
To help identify and resolve errors or syncing issues | Log data | This is necessary to fulfil our contract with you. | Onelap App； |
To provide quality product support | Log data | This is necessary to fulfil our contract with you. | Onelap App； OnelapFit App |
To improve customer relationships and experiences | Log data | We have Legitimate Interest in improving service quality. | Onelap App； OnelapFit App |
To communicate between members of the team during team training | Voice messages and chats generated during team training | We will only process your voice data if we obtained Consent from you. | Onelap App |
To help solve problems when providing after-sales services | Images information uploaded by Users | This is necessary to fulfil our contract with you. | Onelap App |
Assisting you with warranty issues | Images information uploaded by Users | This is necessary to fulfil our contract with you. | Onelap App |
Contacting you in relation to product recall | Images information uploaded by Users | We have a legal obligation to comply with any legal or regulatory requirements. | Onelap App |
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
You are not obliged to provide your Personal Data. However, your provision of Personal Data is required in order to use certain Services and programs. In some instances, if you fail to provide such Personal Data, you may not be able to access and use our Services, or parts of our Services.
As a matter of principle, we only retain your Personal Data for as long as necessary to fulfill the purpose for which it is being processed, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation). In addition, we may be allowed to retain Personal Data whenever you have given consent to such processing e.g. e-mail marketing as long as such consent is not withdrawn.
After expiry of the applicable retention periods, or after we confirm you request for deletion or cancellation, your Personal Data will be deleted or anonymized. If there is any data that we are unable, for technical reasons, to delete or anonymize entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
In order to operate our Website, Apps and provide you with our services we may need to share your Personal Data with third parties. This includes sharing your Personal Data with companies engaged by us to manage our relationship with you and provide you the services described above.
We may share your personal data with the following recipients:
· Sub-contractors: these include providers of cloud hosting, data storage, customer support, analytics, billing, and security services. All processors are bound by a Data Processing Agreement (DPA), which requires them to implement appropriate technical and organisational measures to protect your Personal Data and to process it solely on our documented instructions.
· Independent Controllers: In certain circumstances, we share your Personal Data with third parties who act as independent controllers, including our affiliate Qingdao Magene Intelligence Technology Co., Ltd., and business partners. Where Personal Data is shared with independent controllers, each party is independently responsible for compliance with applicable data protection law.
· Government and law enforcement agencies: where we are required to do so by law or to assist with their investigations or initiatives.
We do not disclose Personal Data to anyone else except as set out above unless we have your consent, or we are legally obliged to do so. These recipients will only process your Personal Data to perform tasks and duties on our behalf and in compliance with this Privacy Policy and governing data protection laws.
We use cloud services from third parties such as Microsoft Azure, Ali cloud and Qiniu cloud. We also appoint other types of third-party service providers. To offer complete Services and functions, Onelap may disclose Personal Data to service providers to act under Onelap’s instructions regarding the processing of such data. Any third party entrusted with processing Personal Data will be subject to obligations to implement appropriate technical and organizational security measures to safeguard the Personal Data.
Entrusted Third Party | Entrusted Assigned Task |
Alibaba cloud | Data storage and processing |
OSS cloud | Data storage |
Google Analytics | Google Analytics is an ad management and ad serving technology. Google Analytics places cookies on the Onelap Sites so that Onelap can record how many signups and leads originated from its marketing activity. |
Webpower | Email marketing services |
To offer our Services, we may transfer your Personal Data outside the European Union (EU), the European Economic Area (EEA), the United Kingdom (UK), or Switzerland and store in the data centers operated in Frankfurt, Germany. We may also share your Personal Data with our third party service providers and business partners in order to provide you with all necessary services and functions, therefore, your Personal Data may also be transferred to other countries and regions.
Onelap maintains administrative, technical and physical safeguards designed to protect the User's Personal Data and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use in compliance with applicable law. For example, we use commercially reasonable security measures such as encryption, firewalls, and 2048-bit Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.
Although we take reasonable steps designed to protect your Personal Data, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks). We cannot and do not guarantee or warrant the security of your Personal Data or any information you disclose or transmit to us. We are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied or otherwise, that we will prevent such access, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of Personal Data that may affect you so that you can take the appropriate actions.
For your own privacy protection, we urge you to keep all passwords confidential. We also recommend that you do not include sensitive information such as passwords, social security numbers, biometric information or payment information, in any emails that you send to us. If you become aware of any breach of the terms of this Privacy Policy or of the security of the Services, please notify us through the contact methods given at the end of this Privacy Policy.
The Sites and Services are not designed or intended to be used by anyone under the age of 16. If you are under the age of 16 (or a minor in the jurisdiction in which you are accessing our Sites or Services), do not use the Services, or make purchases via the Services, use any interactive features of the Services, or post any Personal Data to our Sites or submit any Personal Data via the Services. We do not knowingly or intentionally gather Personal Data about children who are under the age of 16. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the data deleted from our records. If you believe that we might have any data from a child under age 16 in the applicable jurisdiction, please contact us at privacy@onelap.com. If we learn that we have inadvertently collected the Personal Data of a child under 16, or equivalent minimum age depending on the jurisdiction, we will take steps to delete the data as soon as possible and cease the use of that data in accordance with applicable law.
We and our partners use various technologies to collect and store information when you visit one of our Services, and this may include using cookies or similar technologies to identify your browser or device.
The technologies we use for this automatic data collection may include:
Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.
For more information about our use of cookies and similar technologies, including details on how to opt-out of certain cookies and similar technologies, please see our Cookie Policy.
The Sites may contain links to webpages operated by parties other than Onelap. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party's website. Onelap strongly recommends that each User review the third party's terms and policies.
You may have certain rights relating to your Personal Data, subject to local data protection law. Whenever you use our Services, we aim to provide you with choices about how we use your Personal Data. Subject to applicable law, you may obtain a copy of the record of Personal Data about you that we have collected and processed. In addition, if you believe that Personal Data we maintain about you is inaccurate, subject to applicable law, you may have the right to access and change them by logging into with your account on your device, or request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.
The European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation in the United Kingdom and Switzerland, provide European, Switzerland and United Kingdom residents with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Union or European Economic Area, United Kingdom or Switzerland you may have the following rights:
· The right of access. You have the right to request a copy of your Personal Data which we hold about you.
· The right of correction. You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.
· The right to withdraw consent. You have the right to withdraw a previously given consent for processing your Personal Data for a specific purpose. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.
· The right to erasure or “Right to be forgotten”. You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Data will likely impact your ability to use our Services, and it may not be possible for us to delete corresponding information immediately from our backup systems due to applicable law and security technologies. In such case, we will ensure that your Personal Data is kept secure and prevent it from being subjected to any further processing until the backup can be cleared or anonymized.
· The right to object (opt-out). You have the right to opt-out of certain uses of your Personal Data, such as email direct marketing, at any time.
· The right to data portability. You have the right to a “portable” copy of your Personal Data that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers or information technology environment to another service provider’s servers or information technology environment.
· The right to refuse to be subjected to automated decision-making, including profiling. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
· Right of Limitation. You have the right to request the limitation of the processing of your personal data, in the form of (i) suspension of processing or (ii) limitation of the scope of processing to certain categories of personal data or purposes of processing.
· The right to lodge a complaint with a supervisory authority. You have the right to lodge complaints about our data processing activities by filing a complaint with us or with the relevant Supervisory Authority. A list of Supervisory Authorities is available here:http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
You may exercise any of the rights described in this section by sending an email to privacy@onelap.com or contact our representative in EU. The period for handling a request is 30 days unless it is a particularly complex request. Please note that we may ask you to verify your identity and request before taking further action on your request. We may respond to your request by letter, email, telephone or any other suitable method. If you completely delete all such information, or if you cancel the account, then your account may become deactivated and your Personal Data will be deleted or anonymized. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.
At Onelap, we are committed to protecting your privacy and ensuring transparency in how we handle your personal information. This section outlines your rights under the California Consumer Privacy Act (“CCPA/”CPRA”), the types of personal information we collect, how we use it, and your options for managing your personal information.
This section provides details about the categories of personal information we have collected from consumers over the past 12 months. It also outlines the sources of this information, the business or commercial purposes for its collection, and whether we have disclosed any categories of personal information to third parties during the same period.
Categories of personal information | Source from which we collected information | Purposes/Activities for collecting the information | Categories of this partied to whom the information was disclosed |
A. Identifiers, such as First and last name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address. | Directly from you | to define types of customers for our products and Services, to develop our business and to inform our marketing strategy | E.g. service technology providers |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, telephone number. | Directly from you | To provide you with analytical data about user's workout through the use of Onelap App and OnelapFit App | Affiliates, service providers, authorized third parties |
C. Protected classification characteristics under California or federal law, such as age, medical condition, sex (including gender, gender identity, gender expression). | Directly from you | To define types of customers for our products and Services, to develop our business and to inform our marketing strategy | Affiliates, service providers, business partners, authorized third parties |
D. Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Not collected | Not collected | Not applicable |
E. Internet or other similar network activity, such as browsing history, search history, information on a consumer's interaction with a website, application logs, device data and registration, social media account information or advertisement. | Directly from you, automatically collected | To define types of customers for our products and Services, to develop our business and to inform our marketing strategy | Affiliates, service providers, business partners, authorized third parties |
F. Biometric information, such as physiological, behavioral, and biological characteristics (heart rate, height, weight data). | Directly from you, generated during app usage | To provide you with analytical data about user's workout through the use of Onelap App and OnelapFit App | Affiliates, service providers, authorized third parties |
G. Geolocation Data (physical location or movements). | Directly from you, collected via device permissions | To define types of customers for our products and Services, to develop our business and to inform our marketing strategy | Affiliates, service providers, business partners, authorized third parties |
H. Sensory Data | Directly from you (uploaded images, voice chat) | Customer support, team communication, troubleshooting, service improvement | Affiliates, service providers, authorized third parties |
Sharing Personal Data
Some parts of the Services are provided by our affiliates (Qingdao Magene Intelligence Technology Co., Ltd.) or third-party service providers, which require us to provide some of your Personal Data to them. If we share your Personal Data with recipients, we will enter into a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except for the purposes set forth in the contract. In addition, we require all recipients to ensure the security of your Personal Data and to treat it in accordance with the applicable law. We do not allow recipients to use your Personal Data for their own purposes and only permit them to use and process your Personal Data for specified purposes and in accordance with our instructions.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Data for one or more business purposes:
· Identifiers;
· Email address;
· Commercial information;
· Internet or other network activity information;
· Biometric Information;
· Geolocation Data;
· Sensory Data.
We disclose your Personal Data for a business purpose to the following categories of third parties:
· Our affiliates;
· Service providers and other third parties we use to support our business, including without limitation those performing core services (such as billing, credit card processing, customer support services, customer relationship management, accounting, auditing, administering sweepstakes, surveys, advertising and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business and/or the Services, and making certain functionalities to our Users;
· Business partners;
· Third parties to whom you or your agents authorize us to disclose your Personal Data in connection with the Services we provide to you.
We may disclose your Personal Data for legal reasons. Specifically, we will share Personal Data with companies, organizations or individuals outside of Onelap if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
· Fulfill any purpose for which you provide it, such as activate the device and open an account, data analysis for fault checking or stocking;
· Meet any applicable law, regulation, legal process or enforceable governmental request;
· Enforce applicable Terms of Use, including investigation of potential violations;
· Detect, prevent, or otherwise address fraud, security or technical issues;
· Protect against harm to the rights, property, assets or safety of Onelap, our Users or the public, content found on the Services, or to protect the Services from unauthorized use or misuse, as required or permitted by law;
· Facilitate a business transfer, such as to a buyer or other successor in the event of merger, acquisition, consolidation, divestiture, change in control, dissolution or other sale or transfer of some or all of Onelap's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by Onelap about its Users will be among the assets to be transferred, and any such successor may use your information for the same purposes set forth in the Privacy Policy;
· For any other purpose disclosed when you provide the information; and
· When we obtain your consent to do so.
We attempt to notify you about legal demands for your Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Sale or sharing of personal information
We did not sell any personal information. However, we have shared personal information with third parties for the purpose of cross-context behavioural advertising, as defined in section 1798.140 (ah)(1) of the CCPA/CPRA.
California residents have the right to direct us to stop sharing their personal information. For more information on how to exercise this right, including how to opt out of sharing, please refer to the section “Consumer Rights under the CCPA/CPRA - Right to opt-out of third-party sales and sharing”.
Sensitive personal information
We use sensitive personal information only as necessary to provide the services you have requested and for the other limited purposes permitted under applicable California law. We do not offer a 'Limit the Use of My Sensitive Personal Information' link because we do not use sensitive personal information beyond those permitted purposes.
Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.
Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.
Right to Know and Access Your Data. You have the right to request that we disclose the categories and specific pieces of personal information we have collected about yu, the sources from which it was collected, the purposes for which it was collected, and the third parties with whom it was shared or disclosed.
Right to Data Portability. You have the right to receive a copy of the personal information you have provided to us in a readily usable format that allows you to transmit it to another entity.
Right to Delete Your Data. You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies.
Right to Correct Inaccurate Data. You have the right to request that we correct inaccurate personal information we hold about you, taking into account the nature of the information and the purposes for which it is processed.
Right to Opt Out of Sale and Sharing. You have the right to direct us to stop sharing your personal information with third parties for cross-context behavioural advertising. To exercise this right, please contact us at privacy@onelap.com.
Right to Limit Use of Sensitive Personal Information. You have the right to request that we limit the use and disclosure of your sensitive personal information to those purposes specified under applicable California law. As described in this Privacy Notice, we only use sensitive personal information for the purposes of providing the services you have requested, which are permitted purposes under California law.
Right to Opt Out of Automated Decision-Making. We do not use automated decision-making or profiling in connection with the provision of our services. Accordingly, this right does not apply to our processing activities.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.
Exercising Your Rights
If you are a California resident who chooses to exercise your rights, you can submit a request via email to privacy@onelap.com.
You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.
Our Response to Your Request
Upon receiving your request, we will confirm receipt of your request by sending you an email. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or service delivery. Where this is the case, we will inform you of specific details in response to your request.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
· Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
· Comply with a legal obligation; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Onelap is required to comply with the Hong Kong law in respect of its operations there. Onelap seeks to comply with the requirements of Hong Kong’s Personal Data (Privacy) Ordinance (“PDPO”).
Onelap’s Privacy Policy shall apply to its operations in Hong Kong, and this section should be read along with the Privacy Policy.
1. Use of Personal Data for Direct Marketing in Hong Kong
As in other jurisdictions, Onelap intends to use Personal Data collected from Hong Kong residents to send them marketing communications offering or advertising the availability of our Services (“Direct Marketing”). Under the PDPO, we may not use such Personal Data for Direct Marketing unless we have received consent from these individuals for that intended use.
a. Types of Personal Data
We may use your name, email address, mailing address and phone number and information about your preferences for Direct Marketing. These preferences may relate to both the business lines which you prefer for receiving Direct Marketing from us and the types of Services in which you are interested.
b. Classes of Marketing Subjects
Your Personal Data may be used for Direct Marketing in relation to the following:
· News and information;
· Services offered by Onelap.
c. Communication of Your Consent
You may communicate your consent to our use of your Personal Data for Direct Marketing when:
· Providing us with your Personal Data through our website, clicking on the button indicating your consent;
· Providing us with your Personal Data through a form, signing the form to indicate your consent;
· Following the instructions in the document on which you are providing your Personal Data to us.
If you do not agree to the use of your Personal Data for Direct Marketing, you may opt-out from receiving marketing communications from us at any time by following the opt-out instructions found in section “Our Opt-in/Opt-out Policy”.
2. Your Rights and Choices Under PDPO
The PDPO Hong Kong residents with specific rights regarding their Personal Data. This section describes PDPO rights and explains how to exercise those rights if they apply to you.
· Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection and use of your Personal Data. We have 40 days to produce this information. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
· The right to rectification: If the individual discovers that the information we hold on them is inaccurate or incomplete, they can request that it be updated. As with the right to access, we have 40 days to do this, and the same exceptions apply.
3. Exercising PDPO Rights
To exercise your rights, please submit your request to privacy@onelap.com or by using the contact information provided above and we will consider your request in accordance with applicable law. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Site, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.
We endeavor to respond to a verifiable consumer request within forty (40) days of its receipt consistent with applicable law.
We may charge a reasonable administrative fee to process or respond to your verifiable consumer request. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Our Privacy Policy may change from time to time as we develop new products, services, and Apps and improve our current offerings, and as technologies and laws change. We will not reduce your rights under this Privacy Policy without your explicit consent. We will provide notice to you if the changes are significant and, where required by applicable law, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes) and obtain your consent.
If you have any questions, comments or concerns about this Privacy Policy, or if you would like to exercise the choices discussed above, please contact us via the following ways:
Identity and contact details of the controller:
Qingdao Onelap Technology Co., Ltd.
Attn: Privacy Policy Inquiry
Room 207-2, Building 2, No. 130 Jiushui East Road, Licang District, Qingdao City, Shandong Province, China
+86 0532-80928696
Identity and contact details of the controller’s data protection representative:
Daniel Kluge
c/o valantic Management Consulting GmbH
Dreieich Plaza 2A
63303 Dreieich / Germany
Generally, your question will be answered within one (1) month after we receive it. Our dedicated response team will be able to handle any issues you may have about rights requests or questions about your Personal Data. If you are not satisfied with the response you receive, you may escalate your complaint to the applicable regulatory authority in your jurisdiction.