Privacy Policy (Version 3)

General description

Effective Date: 12th, September, 2023

This Personal Information Processing Rules is applicable to the services provided by Vorwerk Household Appliances Manufacturing (Shanghai) Co., Ltd. (registered place Building B No. 8777 Songze Avenue, Qingpu Industrial Park, Shanghai), Vorwerk Household Appliances Co., Ltd. (registered place Building B No. 8777 Songze Avenue, Qingpu Industrial Park, Shanghai) and other Vorwerk entities (hereinafter collectively referred to as “Vorwerk” or “We”) as the brand licensor of the Cookidoo platform, and Beijing Zhenchuang Hulian Information Technology Co., Ltd. (“Zhenchuang Hulian”, with registered place as K1130 Floor 1 No. 1089 South Huihe Street, Banbidian Village, Gaobiedian Township, Chaoyang District, Beijing) as the publishing agent and direct service provider of the Cookidoo platform, in China mainland when users (hereinafter referred to as “user” or “you”) use the “Thermomix electronic recipe platform (“Cookidoo” or “Cookidoo” platform). Our personal information processing rules (hereinafter referred to as “these rules”) explain the purpose, methods and scope of our processing (the “processing” referred to herein includes our act to collect, store, use, process, transmit, provide, publicize and delete your personal information), how you exercise your right enjoyed on your personal information, and our appropriate procedures to protect your personal information. We are responsible for the collection and processing of your personal information. These rules apply to any personal information collected through Cookidoo's platforms, (including but not limited to Cookidoo's websites, mobile Apps, social media, offline stores, etc.). We recommend that you read these rules completely to help you understand how to protect your privacy and personal information.

When you agree to our terms of use or when you access or download the Cookidoo platform, or when you actually use any of the services we provide, you confirm that you have read and understood the terms of these Rules, particularly those in bold. If you do not agree with these Rules or any part thereof, you may not be able to use some or all of the Services. These Rules are formulated in accordance with applicable laws and regulations as of the effective date, as well as with reference to applicable national and industrial standards, international protocols and practices. If national laws and regulations have separate provisions on the contents of these Rules, or any other specific agreement signed by us with you when we provide specific products or services to you are inconsistent with these Rules, such separate stipulations and provisions shall prevail.


Our Commitments

  1. Your legal rights must be guaranteed.

    We promise to protect all your legal rights in accordance with laws and regulations and our agreement with you.

  2. We will only collect and process your personal information to the minimum extent necessary and reasonable

    We collect and process your personal information for the purpose of complying with national laws and regulations and providing you with better products or services through our platform (including supporting us in developing new products and services or improving the functions of existing products and services). In data processing, necessary data must be processed or used based on the purpose of collection, such as: as little data as possible; use anonymity or a pseudonym whenever possible.

  3. We will only collect and process your personal information only with your knowledge and consent

    We promise to inform you openly and honestly of what kind of personal information is collected and processed, and why and how. We respect your choice. We will promptly inform you of any significant change in the scope, purpose and method of collecting and processing your personal information. If you object to the use of your personal information for commercial purposes, we promise to respect your personal wishes in accordance with the law.

  4. 4. We will take necessary measures to ensure the security of your personal information.

    We promise to take all necessary security measures within our ability to protect the security of your personal information, including the protection of the security of your personal information through physical, electronic and procedural protection procedures in accordance with applicable laws, regulations and standards; in addition, we sign confidentiality agreements with relevant employees and urge them to abide by these rules by training them. Only authorized personnel are allowed to access data within the business scope, and authorization restrictions are made according to the nature and scope of the issues in different situations.

The Rules covers the following:
  1. How do we collect and use your personal information
  2. How do we store your personal information
  3. How do we share, transfer or publicly disclose your personal information
  4. How do we protect your personal information
  5. How do we use automatic collection tools such as cookies
  6. How you should manage your personal information
  7. Special agreements on personal information of minors
  8. Disclaimer
  9. Notification of version updates and changes
  10. How to contact us
  11. Governing law and dispute resolution channels

If you have any objections, comments, suggestions, concerns, complaints or reports regarding any aspect of those rules or our collection and processing of your personal information, please contact us in the following ways:
Contact department: [call center]
Contact call: [400-820-7711 (8:00-20:00 Monday to Sunday, except for national holidays)]
Contact E-mail of Service Center: [[email protected]]
Contact E-mail of person in charge of personal information protection: [[email protected]]


How we collect and use your personal information

“Personal information” as termed in these Rules refers to all kinds of information recorded electronically or by other means relating to identified or identifiable natural persons, excluding information after anonymization.


1. In the course of your use of Cookidoo's services, we will collect information that you voluntarily fill in, submit and/or otherwise provide while using the Services, and information that is generated as a result of your use of the Services, to provide you with recipe products and services, improve and enhance service quality and user experience, and protect the security of your account:

1.1 Information required by account service

1) We serve you under the Cookidoo account. In order to create a Cookidoo account, you need to register with Cookidoo and provide us with your mobile phone number. To ensure that we are serving you personally, we will send a verification code to your mobile phone to verify your identity. Once you have registered, you can create a Cookidoo account. If you refuse to provide information or provide incorrect information, we may not be able to provide all or part of the products or services.

2) If you use a third-party account to log into Cookidoo account, you agree that we will collect your third-party account personal information, including Wechat nickname, head portrait, OpenID, UnionID and other information, in order to know your identity. If you refuse to authorize such information, you will not be able to use a third-party account to log into Cookidoo account, but it will not affect the normal use of other functions provided by us. When you log into your Cookidoo account for the first time using a third-party account, we will ask you to verify your identity to protect the security of your information and to complete the binding of the third-party account to your Cookidoo account.

3) If you want to use your Cookidoo account on the TM device, you agree that we can obtain your device information, including hardware serial number, device MAC address and other information, in order to support the binding of your Cookidoo account to the TM device.

4) To maintain your basic information, you can choose to edit your personal information, and we will obtain the information you fill in when you edit it, including your head portrait and name (no need to fill in your real name) and other information.


1.2 Information required by Vorwerk products or applications

1) After your successful registration of a Cookidoo account, we will collect and use your browsing history, query history and cooking history for data analysis to optimize Cookidoo platform content and recommend popular recipes to you based on massive users' cooking history in order to show you recipes and services that better fit your needs.

2) You can use the Cookidoo platform to create and edit your own recipes, as well as guided cooking using your bound TM device. When you use the self-created recipe function, we will collect and store the recipe information (including text or pictures) you create and edit, and we will ask you to authorize the camera and/or album permission according to the type of function you use. If you do not agree or cancel the authorization, you will not be able to use the corresponding functions, but it will not affect your normal use of other functions. You can also delete your recipe information at any time.

3) In order to provide you with reminder of subscription expiration and possible promotion information related to subscription, we may make decisions only based on non-manual automatic decision-making mechanisms such as information systems and algorithms. If you do not want to receive the above information, you can turn it off with the corresponding setting function. After you turn off relevant functions, we will not recommend information or content that you may be interested in based on the beginning and end of your subscription period; you may still receive other recommendations or content, but such recommendations are not related to your personal characteristics.

4) You can contact us via our 400 customer service, email, official website and social media channels, and we will collect your email address, social media account information, your free time, message feedback content, time to participate in activities, products you want to know, experience and feeling of using our products or services and other information.

5) In addition, to monitor the performance and stability of our products and applications, optimize performance, support and improve online service quality, we will collect log information related to our services including but not limited to your IP address, device identifier, hardware model, and operating system version. This part of information is not your personal information, as it cannot identify the identity of a specific natural person. If we use non-personal Information in combination with personal Information, such information will be treated as personal information for the duration of such combined use and we will strictly comply with all commitments of these Rules.


2. Application permission request and use

1) In order to ensure the functional realization and safe and stable operation of Cookidoo platform related products and applications, we may apply for or use relevant permissions of your device.

2) To protect your right to know, the permissions that may be applied for and used by related products and applications are presented in the list below. You can view the status of related permissions one by one in the Settings of your device and manage related permissions according to actual needs.

3) The type and purpose of application and permission may change according to the upgrade of products and applications. We will adjust the list based on these changes in time to ensure that you are informed of the application and use of permissions in a timely manner.

4) Please note that if you open any permission, you authorize us to collect and use relevant personal information to provide corresponding services for you. If you close any permission, you cancel your authorization, and we will no longer collect and use relevant personal information based on the corresponding permissions, nor will we continue to provide you with the services corresponding to the permissions. Your decision to turn off your permission will not affect the collection or use of information previously obtained under your permission.


List of APP Cookidoo application permissions
Device permission Corresponding service function Functional scenario description Can it be turned off?
Storage Picture and document buffer Local buffer of pictures and documents in APP Yes, after it is turned off, pictures in the APP cannot be loaded, and other APP functions are not affected.
Network permission Network access function The network access function is turned on, for real-time reading and update Yes, after it is turned off, the APP content cannot be read and updated in real-time, and APP cannot be used normally

3. The collection and use of your personal information does not require your consent under the following circumstances:
  1. Those related to Vorwerk’s performance of obligations specified by laws and regulations;
  2. Those related to national security and national defense security;
  3. Those related to public security, public health or major public interests;
  4. Those relating to criminal investigation, prosecution, trial and execution of judgments;
  5. Those for the protection of the life, property and other important legal rights and interests of your or other individuals, difficult to get your consent;
  6. The collected personal information is disclosed to the public by you;
  7. Personal information collected from legally publicly disclosed information, such as legal news reports and government information disclosure channels;
  8. Those necessary for signing the contract as you require;
  9. Those necessary to maintain the safe and stable operation of the provided products and/or services, such as finding and disposing of faults in products or services;
  10. Those necessary for academic research institutions to carry out statistical or academic research in the public interest, and when the results of academic research or description are provided externally, the personal information contained in the results shall be de-labeled.
  11. Other circumstances prescribed by laws and regulations.

4. Please understand that the products and services we provide to you are constantly updated and developed, if a product or service (such as a small scale test, experimental search, etc.) has not in the foregoing statement informed of the processing rules of collecting and using your information, we will inform you separately of the objective, way and scope of the information collection via page prompts, interaction text, website announcement and voice, to obtain your approval.


How do we store your personal information

1. We will only hold your personal information for the period necessary for the purposes described in these Rules and for the time required by laws, regulations and regulatory stipulations, unless an extended retention period is required or it is permitted by law. After the expiration of the above period, we will delete your personal information as required by law, or anonymize it if permitted by law.

2. In principle, we will store your personal information in the People's Republic of China. However, under some special circumstances (such as disaster recovery and backup, improving user connection experience, or providing a specific service), we may store your personal information outside the aforementioned areas under the premise of complying with laws and regulations (the specific name, contact information and processing purpose of the overseas recipient can be inquired and obtained through the contact information disclosed in these Rules), when we transmit relevant personal information collected in China to overseas companies, we will comply with laws and regulations and stipulations of relevant regulatory authorities, and require overseas companies to keep your personal information confidential by signing agreements, on-site verification and other effective measures. We will follow necessary procedures in accordance with the law and take the necessary measures to ensure that the receiving party meets the protection standards prescribed by applicable laws and regulations. We ensure that when your personal information is transferred to other territories, it remains under our control and does not diminish the protection of your personal information under applicable laws. If explicitly required by applicable laws, we will conduct regular security assessments for cross-border transmission of personal information and decide whether to continue cross-border transmission of your personal information based on the assessment results.


How we share, transfer and publicize your personal information?


1. Share

We will treat your personal information with a high degree of diligence and will not share your personal information with any company, organization or individual other than Vorwerk Group and its partners.


Vorwerk Group and its partners sharing information with us

1. Companies under Vorwerk Group and its related companies.Based on your explicit prior authorization or consent, we may provide the information to companies under Vorwerk Group and its related companies click to view detailed information of related companies to get their support, including product, service and technical support, or provide you with updates of products or services, recommend products, conduct market investigation and data analysis, etc.

2. Cooperation partners in advertisement and data analysis. Without your authorization, we will not share your personal information with non-partners that provide advertising and analytics services. However, we may share the user portraits formed by using your information (such as analyzing customer consumption behavior) with partners providing advertising and analysis services, so as to help them improve the accuracy and effective reach rate of advertising and service information without identifying your personally identifiable information.

3. Cooperation partners of technical services. Based on your authorization and settings, your location information and device information will be collected and provided to the technical service providers, and in special circumstances, it will include your separately filled-in personal information, to obtain their support, such support includes providing technical infrastructure services, providing functional services within or after products linking, analyzing the use of our online services, measuring the effectiveness of advertising and services, providing customer service, and conducting investigation and analysis.

4. Third-party SDKs. In order to ensure the normal and stable operation of Cookidoo platform or realize relevant functions, we have adopted and embedded various third-party software development kits (SDKS) on the website and APP. The third party SDK’s we access are listed in the following table. You can view the data usage and protection rules of the third parties through relevant links.

SDK Name Types of Personal Information Collected Purpose and scenario project Third party name Third party link for personal information processing rules
Ali Cloud message service Phone number Send message verification codes to users Ali Cloud Computing Co., Ltd. http://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud2019021 41711_54837.html?spm=5176.8195934.J_9220772140.78.64ba4378sup16F
Google Firebase Collect statistics on the user's usage time, device platform (IOS or Android) and its version number Ensure and improve APP stability by APP crash reporting and tracking user behavior (such as pressing certain buttons, etc.) Google LLC https://policie s.google.cn/pri vacy?hl=zh-CN
Google Analytics Browser Cookies, user behavior data, and Google generated clientIDs and corresponding user agent information Browser-based user behavior analysis service and website traffic analysis report Google LLC https://policie s.google.cn/pri vacy?hl=zh-CN
Algolia Browser Cookies and the user's search history record Menu and content search Algolia Inc https://www.alg olia.com/polici es/privacy/
Instana User ID, IP address, browser type and version, and operating system type and version, to display relevant setting information Application performance monitoring platform for tracking internal call of API and their performance Instana Inc https://www.ins tana.com/privac y-policy/
Onetrust Browser Cookies Cookies user authorization management Onetrust LLC https://www.onetrust.com/privacy-notice/
Tencent Automotive Service Personal Wechat login information Use Wechat to direct login Cookidoo Shenzhen Tencent Computer System Co., Ltd. https://privacy.tencent.com/po licy/tencent- privacypolicy

Before sharing information, we will sign strict data security and confidentiality agreements with third parties sharing personal information and require them to take relevant confidentiality and security measures in accordance with our instructions and these Rules to process the aforesaid information. You can obtain the name of the receiving party as the third party that independently controls personal information, its contact information, processing purpose, processing method, and type of personal information via the contact information published at the bottom of these Rules.

2. Transfer

We will not transfer your personal information to any company, organization or individual, except for the following circumstances:

1. After obtaining your express consent;

2. In the case of merger, acquisition, separation, reorganization or bankruptcy liquidation, if any transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue to be bound by these Rules; otherwise, we will require the company or organization to seek authorization from you again.

3. Public Disclosure

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

1. After obtaining your express consent;

2. We may publicly disclose your personal information when compulsorily required by law, legal procedures, litigation or government authorities.

4. Exceptions that the sharing, transfer and public disclosure of personal information is subject to prior authorization and consent

Vorwerk does not need your authorization to share, transfer or publicly disclose personal information under the following circumstances:

  1. Those related to Vorwerk’s performance of obligations specified by laws and regulations;
  2. Those related to national security and national defense security;
  3. Those related to public security, public health or major public interests;
  4. Those relating to criminal investigation, prosecution, trial and execution of judgments;
  5. Those for the protection of the life, property and other important legal rights and interests of information owner or other individuals, while difficult to get your consent in person;
  6. The collected information is disclosed to the public by you;
  7. Information collected from legally publicly disclosed information, such as legal news reports and government information disclosure channels;
  8. Other circumstances prescribed by laws and regulations.


How we protect your personal information

We will take appropriate security measures and technical measures complying with standards of the industry to protect your personal information, including but not limited to the development of a strict internal information management procedures, data encryption, setting job responsibility, control of access rights, and security measures to prevent its loss, illegal use, unauthorized access or disclosure, tampering or destruction.

We only allow those who need to know the information to access or use it after taking reasonable steps to verify their identity. In the meantime, we will strictly require them to fulfill their confidentiality and security obligations. If they fail to fulfill these obligations, they will be held legally responsible or be terminated from labor and cooperation relationship with us. In order to protect the security of your information, if your personal information is wrong, we will access, correct or delete the information at your request after strictly verifying and proving the identity of the applicant (unless we must retain such personal information for legitimate reasons).

If a security incident affects the security of your personal information, we will notify you through your reserved email, phone, system push and other ways, and inform you of the suggestions to reduce or prevent related risks.

If necessary, we will notify the competent authorities in accordance with applicable laws and regulations. In the meantime, we will promptly deal with security risks such as system loopholes, network attacks, virus attacks and network intrusions. In the event of incidents that endanger network security, we will take timely remedial measures in accordance with the network security incident emergency plan, and report to the relevant competent authorities according to stipulations.


When you use the Cookidoo platform, we may use cookies and other similar techniques to record information, including, but not limited to, your IP address, device identifier, hardware model, operating system version, location and logs related to our services. These technologies help us better understand user behavior, tell us which parts of our site you have viewed and which transactions you are processing, and measure and improve the effectiveness of advertising and web search.

Please understand that many cookies on our platform play a vital role: for example, when you log into your Cookidoo account, cookies record your account information, saving you from steps such as re-entering registration information, or helping you determine the security of your account. Other cookies help us understand how you use our platform so that we can improve our online work. To do this, we use relevant analytics tools to analyze the loading time of our platform, how our visitors used it, and what messages our visitors viewed the most. They also help us identify the parts of our platform that aren't working as expected, prompting us to take remedial measures and make them better for you to use.

All the most popular web browsers allow you to manage cookies. You can choose to accept or reject all cookies, or reject specific categories of cookies.You can choose to accept or reject all cookies, or reject specific categories of cookies. If you turn off cookies, you may still be able to use part of the content of our platform, but some useful parts will not be available, and may result in our inability to provide products or services in whole or in part, or affect your access to information related to products or services.


How you should manage your personal information

We respect your concerns about your personal information and do our best to protect your rights to your personal information so that you are fully capable of protecting your privacy and security. Your rights include:

1. Access and update your personal information

You may log onto Cookidoo platform to access and correct your personal information. We may require you to make identity verification when you accessing or correcting the above information to ensure the security of your information.

2. Delete personal information

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

  1. If we handle personal information in violation of any laws and regulations;
  2. If we collect and use your personal information without obtaining your consent;
  3. If our processing of personal information violates our agreement with you;
  4. If we terminate our services and operations.

When deleting the aforesaid information, we may ask you to make identity verification, to protect your information security. When you delete information from our services, we may not delete the corresponding information from the backup system immediately, but will delete such information when the backup is updated.

3. Withdraw your consent

For the collection and use of additional personal information collected, you may withdraw your authorization through the corresponding setting function or grant or withdraw your consent at any time via the contact information publicized at the bottom of these rules. After you withdraw your consent, we will no longer process your relevant personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out based on your authorization.

4. Cancel an account

When you need to cancel your account, you can contact our service center via the contact information publicized at the bottom of these rules. After you cancel your account, all your information in the account will be cleared, and we will not collect, use or share any personal information related to the account. However, we still need to reserve the previous information according to the regulatory requirements, and the competent authority has the right to inquire in accordance with the law within the period of preservation.

5. Exercise other rights on personal information

5.1 In accordance with the relevant stipulations of the Personal Information Protection Law, you are also entitled to the following rights on personal information under statutory conditions:

1) Copy and transfer your personal information;

2) Require us to explain the personal information processing rules;

5.2 Where a natural person deceases, his or her close relatives may, for their own lawful and legitimate interests, exercise the rights of checking, copying, correcting and deleting the personal information of the deceased as stipulated in the Personal Information Protection Law, unless otherwise arranged by the deceased before his or her decease.

5.3 If you and your close relatives want to exercise the aforementioned rights, they can contact us via the contact information at the bottom of these rules. To further verify the facts and circumstances, we may require you and your close relatives to provide further information, proof or explanatory materials according to law, and we will provide you and your close relatives with corresponding services according to law after verification. Except as otherwise stipulated by laws and regulations and these Rules.


Special agreement on personal information of minors

Our website, applications and related products and services do not target minors under the age of 18, and we will not knowingly collect any personal information of minors. If you are a minor, especially a child under 14 years of age, please do not attempt to register on the Cookidoo platform or otherwise provide us with any of your personal information in any other form. If we find that personal information of a minor has been inadvertently obtained, we will delete such information as soon as possible.


Disclaimer

When you start or continue to use our products or services in an appropriate manner for more than 15 days and you do not contact us in an appropriate manner to express contrary opinions, we will consider that you fully understand and agree to these Rules.

Please understand that the Internet is not an absolutely secure environment. It is not possible to determine whether Emails, instant messaging, social software, trading platforms and other communication methods with other users are fully encrypted. Please pay attention to the protection of your personal information when interacting with them in use.

Please understand that due to the rapid development of computer and Internet technology and synchronization speed limitation, a variety of malicious or non-malicious attack means may exist or appear. Although we are making consistent efforts to improve and strengthen security measures to protect your personal information from accidents or sabotage, we cannot always guarantee the absolute security of your personal information.

Please understand that we have no control over the system, communication network or hardware equipment you use in using the products or services. Please understand and pay attention to the protection of your personal information security.

If your use of our services or other behavior intentionally or unintentionally threatens our ability to provide the services or other systems, we have the right to take all reasonable steps to protect the services and our systems, which may include suspending your access to the services. Repeated breaches of these restrictions may result in termination of your account.

Please note that our websites, products, applications software and services may contain links to third party websites, products and services. Any personal information collected by a third party that may involve you must comply with the third party's regulations on personal information. We hope that you understand the personal information processing rules of these third parties. We will use commercially reasonable efforts to request these third parties to take protection measures for your personal information, but we cannot guarantee that these parties will take protection measures as we require, nor will we assume any responsibility for the actions or consequences of these parties. If you find that these third-party web pages or application programs developed by third-party are risky, you are advised to terminate relevant operations to protect your legitimate rights and interests.

For example, all enterprises may face the same problems, considering the characteristics of information technology and network space itself, in some special cases (such as hacker attacks, telecommunications failures, etc.), although we have taken necessary measures as stipulated by laws and regulations, there is still the risk of personal information disclosure. Unless otherwise specified in these rules, in order to protect your personal and property safety, we especially remind you not to provide your account password, verification code, communication content and other information to us or any third party that provides services for you in our name via the public network.


Notification of version updates and changes

We will review and update our personal information processing rules regularly, and indicate the most recent update date below. If we change our personal information processing rules, we will publicize the changes below. We may inform you of these changes via the contact information you leave. If necessary, we will confirm with you whether you are satisfied with the changes. However, please be aware that if you refuse to agree to the changed rules for use and personal information processing rules, you may be unable or unable to continue to fully use our services and functions or achieve the service effect we intend to achieve.

We are determined to honour our commitments. Without your permission, we will never change our rules or practices in a way that weakens the protection of existing personal information.

The latest review and update date of the Personal Information Processing Rules is 12th ,August, 2022


How to contact us

If you have any objections, comments, suggestions, concerns, complaints or reports regarding any aspect of those rules or our collection and processing of your personal information, please contact us in the following ways:

Contact department: [call center]

Contact call: [400-820-7711 (8:00-20:00 Monday to Sunday, except for national holidays)]

Contact E-mail of Service Center: [[email protected]]

Contact E-mail of person in charge of personal information protection: [[email protected]]


If you are not satisfied with our response, you may contact the relevant industry association responsible for personal information protection related complaints, competent authorities, or file a lawsuit with the people's court with jurisdiction power in accordance with the applicable law.