Privacy Policy

Marshub Co., Ltd. (hereinafter "we", "us" or "our") recognises the importance of your personal information. In accordance with the Personal Information Protection Law of the People's Republic of China, the Cybersecurity Law of the People's Republic of China, the Data Security Law of the People's Republic of China and other applicable laws and regulations, we process your personal information in accordance with the principles of lawfulness, legitimacy, necessity and good faith, and we take reasonable security measures to protect the security of your personal information. This Policy explains who we are, what personal information we collect, why we collect it, how we use and retain it, whether it is transferred overseas, and what rights you have and how to exercise them. Please read this Policy in full before using our products and services. The provisions of this Policy that concern your material rights and interests are highlighted in bold.

1. Scope

   1. This Policy applies to the products and services we provide to you through the following channels:
      1. the MarsHub websites: marshub.cn, marshub.com and their subdomains;
      2. the MarsTranslation linguist community: marstranslation.com and app.marstranslation.com;
      3. mobile applications, clients, mini-programs and API interfaces;
      4. marketing campaigns, offline events, tendering and business negotiations;
      5. customer support, complaint handling and recruitment.
   2. This Policy does not apply to services independently operated by third parties. Third-party services are governed by their own privacy policies, and we recommend that you read them carefully before use.
   3. Where a product has a separate privacy notice, that notice applies together with this Policy; in the event of any inconsistency, the product's separate privacy notice prevails.

2. Personal Information Processor

   Processor name: Shenzhen MarsHub Technology Co., Ltd.

3. Definitions

   1. Personal information: any information relating to an identified or identifiable natural person recorded electronically or by other means, excluding information after anonymisation.
   2. Sensitive personal information: personal information which, once leaked or illegally used, may easily lead to the infringement of a natural person's human dignity or endanger the safety of his or her person or property, including biometric information, religious belief, specific identity, medical and health information, financial accounts, whereabouts and similar information, as well as the personal information of minors under the age of fourteen.
   3. Personal information processing: includes the collection, storage, use, adaptation, transmission, provision, disclosure and deletion of personal information.
   4. Anonymisation: the process by which personal information is processed so that it is impossible to identify a specific natural person and impossible to restore.
   5. De-identification: the process by which personal information is processed so that it is impossible to identify a specific natural person without the aid of additional information.

4. What Personal Information We Collect

   1. We follow the principle of minimum necessity and collect only the personal information necessary to achieve the specific processing purposes. The details are as follows:

      Scenario	Personal information collected
      Account registration and login	Name, email address, password (stored in encrypted form), mobile number, name of your organisation, job title, country or region
      Enterprise user administrators and sub-accounts	Administrator's name, job title, work email address, mobile number, records of sub-account use
      Product use and file processing	Documents, texts, images, audio and video that you upload, and any personal information that they may contain
      Billing and payment	Order information, billing address, invoice title and tax number, transaction reference numbers returned by the payment channel (we do not store full bank card numbers or payment passwords)
      Contracts and business dealings	Contact name, job title, work email address, telephone, organisation name, records of contract execution and performance
      Website enquiry forms and consultations	Name, contact details, email address, product of interest, description of requirements
      Customer service and tickets	Communication records, ticket content, and account information collected where necessary to verify identity
      Devices and logs	IP address, browser type and version, operating system, device identifiers, access time, pages visited, referring links, operation logs, error logs
      Cookies and similar technologies	See Section 8
      Linguists and freelancers	Name, contact details, identity document information, evidence of language proficiency and qualifications, bank account, tax information, CV and portfolio
      Recruitment and job applications	CV, contact details, education and work history, interview assessments, background check information (with your consent)
      Marketing events	Name, organisation, job title, contact details, attendance records, preferences

   2. We will not collect personal information unrelated to the services provided. If you refuse to provide certain necessary information, we may be unable to provide you with the corresponding functionality or to conclude a contract.
   3. We will not collect your religious belief, genetic, fingerprint, facial or other biometric information, nor will we collect your medical and health information, unless you voluntarily upload such information and it is necessary to complete a translation project.
   4. Personal information contained in the content you upload: where you use functions such as document translation, video localisation, subtitle generation and voice synthesis, the materials you upload may contain the personal information of others. In such case, you are the processor of that personal information, and we act only as an entrusted processor on your behalf, processing it in accordance with your instructions and assuming liability in accordance with Article 9.1. You should ensure that you have obtained the necessary lawful basis and authorisations.

5. Sensitive Personal Information

   1. We process sensitive personal information only where there is a specific purpose and sufficient necessity and where strict protective measures are adopted. We will inform you of the necessity of the processing and of its impact on your personal rights and interests, and will obtain your separate consent.
   2. The sensitive personal information we may process, and the relevant scenarios, are as follows:

      Type	Scenario
      Identity document information	Linguist contracting, real-name verification, issuance of invoices, statutory withholding and remittance of taxes
      Financial account information	Payment to linguists and suppliers
      Whereabouts	Not actively collected; where contained in materials you upload, you are responsible as the processor and we process it in accordance with the rules on entrusted processing
      Information of minors under the age of fourteen	Not actively collected; where content you upload contains such information, you must obtain the separate consent of the guardian

   3. We will not process your biometric information (facial, fingerprint, voiceprint) for the purpose of identification. Where you use voice synthesis or dubbing services involving the voice of another person, you should obtain the separate consent of that natural person.

6. How We Collect Personal Information

   1. Provided directly by you: information provided when registering, completing forms, uploading files, placing orders and making payments, participating in events, contacting us, applying for a job, or applying to become a linguist.
   2. Collected automatically by us: when you visit this Platform, the server automatically records your IP address, browser and device information, access logs and operation logs. Such information is used to safeguard service security, troubleshoot faults and conduct statistical analysis.
   3. Obtained from third parties:
      1. where you log in through a third-party account (such as enterprise SSO or a social media account), the necessary information provided by that third party in accordance with its own policies (such as account identifier, nickname and email address);
      2. transaction status and reference numbers returned by the payment channel;
      3. your name, work email address and department provided by the administrator of your Enterprise User when opening a sub-account for you;
      4. background check agencies that have obtained your authorisation in accordance with law (recruitment scenarios only).
   4. Obtained from public sources: limited to professional information that you have made public (such as a public professional social media profile), and used only for business contact and market analysis.

7. Processing Purposes and Legal Bases

   1. We process your personal information only within the following purposes, and determine the lawful basis in accordance with Article 13 of the Personal Information Protection Law:

      Processing purpose	Legal basis (PIPL Article 13)
      Registering accounts, logging in, identity verification, provision of translation and localisation services, delivery of outputs	Necessary for concluding or performing a contract to which you are a party
      Billing, invoicing, receipt of payment, withholding and remittance of taxes, retention of accounting vouchers	Necessary for performing statutory obligations (Tax Collection and Administration Law, Accounting Law, etc.)
      Safeguarding network and information security, preventing fraud and abuse, log auditing, troubleshooting	Necessary for performing statutory obligations; and necessary for responding to public health emergencies or for protecting the life, health and property safety of natural persons in emergencies (Article 13(4))
      Responding to your enquiries, handling complaints and tickets, after-sales support	Necessary for concluding or performing a contract
      Sending you notices directly related to services already purchased (such as service changes, renewal reminders and security alerts)	Necessary for performing a contract
      Sending you product or marketing information	Your consent (withdrawable at any time)
      Statistical analysis and marketing cookies	Your consent (withdrawable at any time)
      Cross-border transfer (see Section 10)	Your separate consent, together with completion of the statutory overseas transfer procedures
      Recruitment and hiring, employee management	Necessary for concluding or performing a labour contract; performance of statutory obligations
      Processing linguists' identity documents, bank accounts and tax information	Necessary for concluding or performing a contract; performance of statutory obligations
      Responding to litigation, arbitration and regulatory investigations	Necessary for performing statutory obligations; necessary for safeguarding our lawful rights and interests

   2. We will not use your personal information for purposes not specified in this Policy. If we need to use it for other purposes, we will inform you again and obtain your consent (unless otherwise provided by laws).

8. Cookies and Similar Technologies

   1. We use technologies such as cookies, pixel tags, software development kits (SDKs) and local storage to maintain login status, remember language preferences, compile visitor statistics and evaluate marketing effectiveness.
   2. Cookie categories:

      Type	Purpose	Example
      Strictly necessary cookies	Maintaining sessions, login status, security protection and load balancing	Session identifier
      Preference cookies	Remembering language, region and interface settings	Language preference
      Statistical analysis cookies	Counting visits, page paths and conversion funnels	Site analysis tools
      Marketing cookies	Advertising delivery and effectiveness measurement (including Meta Pixel)	Facebook Pixel

   3. Where we collect device information or usage behaviour through third-party SDKs, we will also comply with the privacy policies of those third parties.

9. Entrusted Processing, Sharing, Transfer and Public Disclosure

   1. Entrusted processing: we may entrust technical service providers such as cloud service, SMS and email push, payment, customer service system, data statistics and translation engine providers to process personal information. We will enter into data processing agreements with them specifying the processing purposes, duration, processing methods, categories of information, protection measures and the rights and obligations of both parties, and we will supervise their processing activities. Entrusted parties may not process beyond the agreed scope and may not sub-entrust (except with our consent).
   2. Sharing: we will not sell your personal information to any third party. We share it only in the following circumstances:
      1. with your separate consent;
      2. where necessary to perform a service you have requested (such as allocating a project to a linguist designated by you);
      3. as mandatorily required by laws and regulations or by regulatory authorities or judicial authorities;
      4. where necessary to protect the life, health or property safety of you or others and it is difficult to obtain the consent of the individual concerned.
   3. Personal information contained in the content you upload is processed only in accordance with your instructions and is not regarded as an act of sharing on our part. As the processor, you should independently perform the obligations of notification and of obtaining consent.
   4. Transfer: where we transfer personal information as a result of merger, division, reorganisation, asset transfer or sale of business, we will inform you of the name and contact details of the recipient and require the recipient to continue to perform the obligations under this Policy; where the recipient changes the original processing purposes or methods, we will obtain your consent again.
   5. Public disclosure: we will not publicly disclose your personal information unless we have obtained your separate consent or are mandatorily required by laws and regulations. Information that has been anonymised and cannot be restored does not constitute personal information, and we may use it in accordance with law.

10. Retention Period

    1. We retain your personal information only for the shortest period necessary to achieve the processing purposes, unless otherwise provided by laws and regulations.
    2. Where the retention period is exceeded, we will delete the personal information or anonymise it. Where deletion is difficult to effect immediately for technical reasons, we will cease all processing other than storage and necessary security protection.
    3. We may extend the retention period before the expiry of a retention period prescribed by laws and regulations, or while litigation, arbitration or a regulatory investigation is ongoing.

11. Security Protection Measures and Security Incident Handling

    1. We have obtained ISO/IEC 27001 certification for our information security management system, and we continue to operate and improve in accordance with the requirements of that system.
    2. In the event that personal information is, or may be, leaked, tampered with or lost, we will immediately activate our emergency response plan, take remedial measures, report to the authorities performing personal information protection duties as required by law, and at the same time notify you as an affected individual. The notification shall include: the basic circumstances of the incident, the possible impact, the handling measures we have taken, recommendations for your own prevention, and our contact details.
    3. If you discover a security risk in relation to personal information, please inform us immediately.
    4. Please understand that the internet environment is not absolutely secure. Please keep your account and password safe, do not tick "remember password" on public devices, and do not submit sensitive personal information to us through unofficial channels.

12. Automated Decision-Making and Artificial Intelligence

    1. We will not conduct automated decision-making based on your personal information that has a material impact on your rights and interests. If we carry out such decision-making in the future, we will ensure the transparency of the decision-making and the fairness and equity of the results, will not implement unreasonable differential treatment, and will provide you with a convenient means of refusal.
    2. Where we push information to you or conduct commercial marketing through automated decision-making, we will at the same time provide an option that is not targeted at your personal characteristics, or provide a convenient means of refusal.
    3. Our machine translation and generative functions may involve automated processing such as quality scoring, language identification and terminology extraction. Such processing is used only to improve translation results and product quality, and does not produce legal or similarly significant effects on your personal rights and interests.
    4. We will not, without informing you, use the content you upload to train general-purpose models for unspecified third parties. If this becomes necessary in the future, we will separately inform you of the processing purposes, the scope of information and the opt-out method, and will obtain your separate consent.

13. Updates to This Policy

    1. We may update this Policy due to changes in laws and regulations, business adjustments or service upgrades. The updated Policy will be published on this Platform.
    2. For material changes (including substantive changes to the processing purposes, processing methods, categories of personal information, recipients of sharing or overseas transfer, or the manner in which you exercise your rights), we will notify you through prominent means such as in-site announcements, pop-up windows, in-site messages or emails 【7】 days before they take effect; where necessary, we will obtain your consent again.