# Privacy Policy Version release date: April 14, 2024 Version effective date: April 14, 2024 Introduction About us Noun interpretation How do we collect and use your personal information How do we use cookies and similar technologies How do we share, transmit and disclose your personal information How do we store and protect your personal information Your rights to manage personal information How do we handle personal information of minors Personal information protection of deceased users How to update this policy How to contact us Dispute Resolution ## 1.Introduction Welcome to use our products and services! The topic of personal information protection has the highest priority at InnoPaaS. Therefore, we will strictly comply with laws and regulations, and take corresponding safety protection measures to safeguard your personal information. Based on this, the service provider of InnoPaaS (or "we") has formulated this personal information protection policy (hereinafter referred to as "this policy") to help you fully understand how we collect, store, use, process, transmit, provide, disclose, delete and protect your personal information when you are using our products and services, and how you can manage your personal information. We aim to help you better make appropriate choices. Please carefully read and understand this policy before you use our products and services, especially the terms marked in bold/bold underline. Please ensure that your use are based on full comprehension and agreement. Once you use or continue to use our products and services, it means your agreement that we can use and process your relevant information in accordance with this policy. We have tried our best to concisely and popularly explain the professional vocabulary involved in this policy for your understanding. If you have any questions, comments or suggestions with this policy, you can contact us through the contact information provided in this policy. We may revise this policy from time to time according to laws and regulations or business adjustment. When this policy is changed, we will show you the changed content in the form of prompt in a prominent position, or push notices and messages after the version is updated. Please understand that only after you confirm and agree to the changed policy will we collect, use, process and store your personal information according to the changed version. You are entitled to refuse the changed version, which may prevent you from using or continuing to use our relevant services and functions completely, or reduce the original quality and effectiveness of services. ## 2. About us The product operations and services of InnoPaaS is provided by TRANSLAND INFORMATION GROUP LIMITED (hereinafter referred to as “InnoPaaS”) and all of its affiliates. Affiliates include any company or institution which is or will be controlled by or under common control with InnoPaaS and the legal successors of such company or institution. “Control” refers to the ability to directly or indirectly influence the management of the company mentioned, whether through ownership, voting shares, contracts or other means determined by the people's court. The basic information of our operating entity is as follows: TRANSLAND INFORMATION GROUP LIMITED, registered office:FLAT/RM A 12/F ZJ 300 LOCKHART ROAD WAN CHAI,Hong Kong. Generally, we collect your personal information in the following scenarios: Account registration and login To create a InnoPaaS account, you need to provide us with your email address, name and company name. If you refuse to provide the above information, you will not be able to register your InnoPaaS account and can only use the browsing service. Once you confirm and continue to use this product, we will consider that you agree to our collection of the above-mentioned relevant personal information. You can use your password to log in to InnoPaaS. When logging in, you need to provide us with your email address and password. We promise that the above information is collected to provide you with account login services, protect your account security and prevent security risks. ## 3.Account recharge We provide you with online recharge function by accessing the third party payment institutions. When you recharge online through the third party payment institutions, we will receive information about your recharge amount. When you recharge offline by bank transfer, you need to provide your recharge amount, account number, bank of deposit, account name and payment voucher. We promise that the above information collection is only for recharge and reconciliation. We cannot obtain your personal property information only based on this information. If you refuse to provide it, you may not be able to recharge your account, so that you cannot or cannot continue to use our products, please consider carefully before choosing whether to provide them. ## 4.System settings In order to use the business alarm service provided by us, you need to provide your name, mobile phone number, email address and company name when setting the system. If you refuse to provide, you may not be able to use the service. Please consider carefully before choosing whether to provide them. Your personal information collected indirectly from a third party You understand that we cannot obtain the personal information you provide to an external third party or your personal information collected by an external third party, and we will not use unconventional methods (such as malicious interference with the other party's data) to obtain your personal information by software programs without authorization. If InnoPaaS does need to collect (share, etc.) your personal information indirectly from a third party due to the needs of business development, and we directly or jointly provide you with products or services, we (or the third party) will express to you the source, type, purpose, method, business function and scope of authorization and consent of your personal information shared before collection (if the use method and scope exceed the scope of your original authorization in the third party, we will obtain your authorization again) . When some of our products or services are provided or jointly provided by third-party authorized partners, we may indirectly collect some of your information from some business partners and the information about you provided by other parties when using our products and / or services in order to conduct business necessary and reasonably. ## 5. How do we use cookies and similar technologies When you use InnoPaaS, we will not access other similar technologies except cookies in order to verify your identity. If you refuse to use or delete cookies, you may not be able or continue to use our products. ## 6. How do we share, transmit and disclose your personal information ### 6.1 Share We attach importance to the protection of your personal information. Your personal information is an important basis and part of our products and services for you. We collect and use your personal information only within the purpose and scope of this policy or in accordance with the requirements of laws and regulations, and keep it strictly confidential. In order to provide you with more perfect and high-quality products and services, some of our services will be provided by affiliated companies or partners. We may share some of your personal information with partners or affiliated companies to provide better services and functions. We will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and will only share the personal information necessary to provide services. If you refuse our partners or affiliated companies to collect personal information necessary for providing services when providing services, you may not be able to use relevant services in our products. We will not share your personal information with any company, organization or individual other than InnoPaaS. and its affiliates and partners necessary to complete business functions, except for the following cases: Sharing with your explicit and separate consent in advance: after obtaining your explicit and separate consent, we will share your personal information with other parties. We may share your personal information in accordance with laws and regulations, or in accordance with the mandatory requirements of the competent government departments and judicial decisions. Within the scope required or permitted by law, it is necessary to provide your personal information to a third party in order to protect the interests, property or safety of users or the public. If there is sharing of personal information in actual operation, we will inform you of the recipient's name, contact information, processing purpose, processing method and type of personal information, and obtain your separate consent. The receiving party shall process personal information within the scope of the above processing purpose, processing method and type of personal information. If the receiving party changes the original processing purpose and processing method, we will obtain your consent again according to law. The subjects that may share personal information in actual operation include: Sharing with our affiliates: your personal information may be shared with our affiliates. We will only share necessary personal information and are bound by the purposes stated in this policy. If the affiliated company wants to change the purpose of processing personal information, it will ask for your separate consent again. Our affiliates include any company or institution controlled, controlled or under common control with InnoPaaS now or in the future, as well as the legal successors of the above companies or institutions. “Control” refers to the ability to directly or indirectly influence the management of the mentioned company, whether through ownership, voting shares, contracts or other ways recognized by the people's court. Sharing with authorized partners: we may share some of your personal information with partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and will only share the personal information necessary to provide services. Our partners are not authorized to use the shared personal information for any other purpose. Authorized partners who may share personal information include SMS provider. At present, our SMS suppliers include China's third-party suppliers, China's three major operators (China Telecom, China Mobile and China Unicom) and international suppliers. In order to send the specified number and SMS content to the operator of the destination country, who will finally send the SMS, we must provide your phone number and SMS content to the SMS supplier. When your business needs to send global SMS, your phone number and SMS content will be cross-border transmitted, and the recipient of the information is the operator in the destination country. In order to ensure your information security, we will conduct cross-border data transmission through a dedicated interface. ### 6.2 Transmit We will not transmit your personal information to any company, organization or individual, except in the following cases: Transmit with explicit individual consent: after obtaining your individual consent, we will transmit your personal information to other parties; If it is necessary to transmit personal information due to combination, division, dissolution or declaration of bankruptcy, among others, we will inform you of the name or contact information of the receiving party. The receiving party shall continue to perform its obligations under this agreement. If the receiving party changes the original processing purpose and processing method, it shall obtain your consent again. ### 6.3 Disclose We will not publicly disclose your personal information. If it is necessary to publicly disclose your personal information, we will inform you of the purpose and type of the publicly disclosed information before public disclosure (if your personal sensitive information is involved, we will also inform you of the content of the sensitive information involved), and then publicly disclose it with your separate consent. Unless otherwise provided by laws and regulations or otherwise agreed in this policy. For your personal information publicly disclosed, we will carefully review its legitimacy, rationality and legitimacy as soon as we receive the application for public disclosure, and take the strictest personal information security protection measures and means to protect it during and after public disclosure. Exception of share, transmission, disclosure of your personal information Please be aware that, in accordance with the provisions of laws and regulations, sharing, transmitting, and disclosing your personal information does not require your prior authorization under the following circumstances: Directly related to national security and national defense security; Directly related to public safety, public health, and major public interests; Directly related to criminal investigation, prosecution, trial, and execution of judgments; or in accordance with the requirements of laws and regulations, administrative agencies, public prosecutors, and other competent agencies; In order to protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to obtain your own consent; Personal information is disclosed to the public by you yourself or collected from legally disclosed channels (such as legal news reports, government information disclosure, etc.); Necessary for signing and fulfilling relevant agreements or other written documents with you; Other circumstances stipulated by laws and regulations. ## 7. How do we store and protect your personal information ### 7.1 How do we store your personal information Information storage location. We will store the user's personal information collected in China in accordance with laws and regulations. If it is necessary to conduct cross-border data transmission, we will clearly inform you separately (including the purpose, receiver, use mode and scope, use content, security measures, security risks, etc.) and obtain your separate consent. The information storage period. We promise that the storage period of your personal information is the shortest period necessary to realize the purpose of the personal information handling. For example, when you use our registration and login functions, we need to collect your password, name, e-mail and phone number, and we need to keep your password, name, e-mail and phone number after you provide it and during your use of the function, so as to provide you with the function normally and ensure your account and system security. In addition, we may save your relevant information to the necessary period specified by relevant laws (for example, the e-commerce law stipulates that the storage time of commodity and service information and transaction information shall not be less than three years from the date of completion of the transaction). After the storage period is exceeded, we will delete your personal information or anonymize it according to the requirements of applicable laws. Storage of Information Deletion. After you cancel your account, we will delete or anonymize your personal information. After you or we assist you in deleting relevant information, we may not be able to delete the corresponding information from the backup system immediately due to applicable laws and regulations and security technology restrictions. We will safely store your personal information and restrict any further processing until the backup can be deleted or anonymous. ### 7.2 How do we protect your personal information We will establish an information security system and take technical measures and other necessary measures to protect your personal information security in strict accordance with the relevant requirements of laws and regulations such as the personal information protection law, the network security law and the data security law. Our technologies and measures to protect your personal information. We attach great importance to personal information security and take all reasonable and feasible measures to protect your personal information: ## 8.Technical measures for data security We adopt a variety of complex data desensitization technologies and SSL transport layer security protocol to enhance the security of personal information in use. At the same time, we adopt BCrypt to encrypt your login password. We have established strict data access control and multiple identity authentication technology to protect personal information and avoid illegal use of data. We use code security check and data access log analysis technology to conduct personal information security audit. ## 9.Other safety measures We promote and protect your personal information security by adopting sensitive information protection measures on the operation page. The Internet is not an absolutely safe environment. We suggest you pay attention to protecting the security of your personal information. Please protect your personal information properly and provide it to others only when necessary. Please understand: the Internet environment is not 100% secure. We will try our best to ensure or guarantee the security of any information you send us. However, due to technical limitations and possible malicious means, even if we try our best to strengthen security measures, it is impossible to ensure the 100% security of information at the beginning. After an unfortunate personal information security incident, we will timely inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce risks, and the remedial measures for you in accordance with the requirements of laws and regulations. We will timely inform you of the relevant information of the event by mail, letter, telephone, push notice, etc. when it is difficult to inform the personal information subject one by one, we will take a reasonable and effective way to make an announcement. At the same time, we will actively report the disposal of personal information security incidents in accordance with the requirements of regulatory authorities. ## 10. Your rights to manage your personal information We understand your concern about personal information and try our best to ensure your right to access, correct, delete and withdraw your authorization, so that you have sufficient ability to protect your privacy and security. Your rights include: ### 10.1 You are entitled to access to your personal information You can consult the relevant personal information you have provided to us according to the relevant instructions (or settings) of the products and services we provide, include: Account information: you can log in to your account settings at any time through relevant product pages to access the personal data information in your account, including your personal name, phone number, e-mail and company name. Financial information: you can view your consumption records and invoice records through the payment page. Other information: if you encounter operational problems during your visit and need to obtain other personal information that cannot be known above, you can contact us through the way provided in this policy. ### 10.2 Correct / modify your personal information When you find that the personal information you provide us has registration errors, incompleteness or updates, you can correct / modify your personal information in our products and services. ### 10.3 You are entitled to delete your personal information You can apply to us for deleting your personal information through the contact information publicized in this policy. Once you delete, we will delete or anonymize such information, unless otherwise specified by laws and regulations. You can directly ask us to delete your personal information in case of the following circumstances, unless it has been anonymized or otherwise stipulated by laws and regulations: If our handling of personal information violates laws and regulations; If we collect and use your personal information without your consent; If our handling of personal information violates the agreement with you; If you no longer use our products or services, or you cancel your account; If we no longer provide you with products or services. After you delete the information from our service, we may not delete the corresponding information in the backup system immediately, but we will delete the information when the backup is updated. After you cancel your account, we will stop providing you with products or services and delete your personal information according to your requirements, unless otherwise stipulated by laws and regulations. ### 10.4 You are entitled to rescind authorization You can apply to us to withdraw the authorization about your personal information through the contact information publicized in this policy. After you withdraw your personal information authorization, you may not be able or unable to fully use our relevant services and functions, or you may not be able to achieve the service effect we intend to achieve. ### 10.5 You are entitled to cancel your account You can apply to us for account cancellation through the contact information publicized in this policy. After you cancel your account, you will no longer be able to log in and use our products and services with this account; And all rights and interests such as the rights and interests generated but not consumed during the use of our products and services and the expected future interests of the account will be cleared; The contents, information, data, records, etc. under the account will be deleted or anonymized (unless otherwise stipulated by laws and regulations or required by the regulatory authorities, for example, according to the network security law of the people's Republic of China, your network operation log will be kept for at least six months); After the account is cancelled, it cannot be recovered. ### 10.6 You are entitled to obtain a copy of your personal information You can apply to us for a copy of your personal information through the contact information publicized in this policy. On the premise of compliance with relevant laws and regulations and technical feasibility, we will provide you with a copy of your personal information according to your requirements. ### 10.7 You are entitled to request the transfer of personal information to your designated personal information processor You can apply to us for transferring your personal information to your designated personal information processor through the contact information publicized in this policy. We will transfer your personal information to your designated personal information processor according to your requirements on the premise that it meets the conditions specified by the national network information department and is technically feasible. ## 11. How do we handle personal information of minors Our products are only for natural persons with full capacity for civil rights and capacity suitable for their civil acts, legal persons or other organizations. Our products do not involve the processing of minors' personal information. ## 12. Personal information protection of deceased users After the death of our user, for their own legitimate and legitimate interests, their close relatives can exercise the right to consult, copy, correct and delete the relevant personal information of the deceased user through the contact information publicized in this policy, unless otherwise arranged by the deceased user before death. You understand and confirm that in order to fully protect the personal information rights and interests of the deceased user, the close relatives of the deceased user who apply to exercise this right need to submit the identity documents of the deceased user, death certificates, identity documents of the applicant, and proof of kinship between the applicant and the deceased user according to our designated process or customer service prompt, and provide the types and purposes of the rights to be exercised. 13\. How to update this policy In order to provide you with better service, we will update the terms of this policy according to the update of products and relevant requirements of laws and regulations. Such updates form a part of this policy. Without your express consent, we will not reduce your rights under this policy. Before the updated policy comes into effect, we will notify you by reminding you in a prominent position or sending you a push message or by other means. If such update results in a substantial reduction or significant change in your rights under the policy, we will ask for your separate consent again. Major changes include but are not limited to: Major changes have taken place in our service model. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc; Significant changes have taken place in our ownership structure and organizational structure. Such as owner change caused by business adjustment, bankruptcy, M & A, etc; The main objects of personal information sharing, transfer or public disclosure have changed; Significant changes have taken place in your right to participate in personal information processing and the way in which you exercise it; The responsible department, contact information and complaint channels responsible for handling personal information security have changed; When the personal information security impact assessment report indicates that there is a high risk. ## 14. How to contact us If you have any questions, comments or suggestions on this policy, you can contact us through any of the following ways: You can communicate with us online through Intercom. In addition, you understand that we will not be able to respond to your request under the following circumstances related to personal information: Related to national security and national defense security; Related to public safety, public health and major public interests; Related to criminal investigation, prosecution and trial; There is sufficient evidence to show that you have subjective malice or abuse of rights; Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations; Involving trade secrets; Other circumstances stipulated by laws and regulations. ## 15.Dispute Resolution The interpretation of this policy and dispute resolution shall be governed by and construed in accordance with laws of the People’s Republic of China and Any dispute arising under or concerning this Agreement may be litigated only in the Shanghai International Economic and Trade Arbitration Commission and the prevailing Party shall be entitled to its reasonable attorneys’ fees, expenses and costs incurred in connection therewith in addition to such other relief as may be granted.