Dear User,

We have updated the Bangmaoda Basic Function Privacy Policy to further improve the following content:

1. Clearly distinguished between the basic business functions and extended business functions of Bangmaoda, and specified whether the personal information involved in each function is necessary or non-necessary;
2. Supplemented the requirements for our response time limit when you submit applications for personal information inquiry, correction, deletion, account cancellation, etc., which are processed manually;
3. Added a chapter on “Explanation of Third-Party Services and Associated Launch”, disclosing scenarios involving invoking third-party applications (e.g., WeChat) to provide services, including function names, invocation methods, types of information involved, purposes of use, as well as the corresponding third-party operators and links to their privacy policies.

This Bangmaoda Basic Function Privacy Policy (hereinafter referred to as “this Privacy Policy”) applies to all online shopping basic business functions and other extended function products and services provided by Shenzhen Bangmaoda Technology Group Co., Ltd. (hereinafter referred to as “we”, “us” or “Bangmaoda”) to users (hereinafter referred to as “you”) based on the operated internet platforms. It includes the Bangmaoda Ordering Platform website (enpcb.ycbmd.com) and its associated business websites, the Bangmaoda Order Assistant App, the “Bangmaoda Order Assistant” PC client software, the WeChat Mini Program “Bangmaoda Order Assistant | PCB Prototyping & SMT Patch”, the WeChat Official Account “Bangmaoda”, as well as all existing or future internet products and/or services of various types.

The scope of products and services provided by Bangmaoda is extensive, so this Privacy Policy may not fully cover all possible scenarios of personal information collection and processing under all products and services. The content of personal information collection for specific products and/or services may be elaborated in separate privacy policies or statements issued by Bangmaoda upon the release of such specific products and/or services. In case of any inconsistency between this Privacy Policy and the privacy policy or statement of a specific product and/or service, the privacy policy or statement of the specific product and/or service shall prevail. For content not covered by the privacy policy and user service agreement of a specific product and/or service, this Privacy Policy shall prevail. Please read carefully and confirm that you fully understand this Privacy Policy and the privacy policy of the specific product and/or service (if any) before use to make an appropriate choice. If you have any questions about this Privacy Policy, you may contact us through the contact information provided in the “How to Contact Us” section of this Privacy Policy.

Our product type is online shopping, and our basic business functions include: account registration and login, commodity/service information display, order placement and order management, payment, prepayment, order/commodity delivery, and security protection. In the course of your use of the above basic business functions, we will collect and use the following necessary personal information related to you: registered user’s mobile phone number, consignee information (consignee name and contact number, delivery address), order placer’s name and contact number, technical contact person’s name and contact number, order information (order number, purchase details, order time, order amount), and payment information (payment amount, payment time). You must authorize us to collect and use the necessary personal information; if you fail to provide the corresponding information, you will not be able to use our products and/or services normally.

Your agreement to this Privacy Policy only means that you have understood all the online shopping basic business functions we provide and the necessary personal information required for their operation, and have granted us the corresponding authorization for collection and use. In addition to the basic business functions, we also provide you with various other extended functions, for which relevant personal information is also required. If you refuse to provide such information, you will not be able to use the corresponding extended functions, but you can still use the basic business functions.

Preface

This Privacy Policy uses bold and underlined text to prominently indicate clauses that have or may have a significant bearing on your rights and interests, sensitive personal information that we may collect, and clauses that may have the effect of exempting or limiting our liabilities for us. Please read and pay special attention to these clauses.

This Privacy Policy will help you understand the following content:

I. Definitions

II. How We Collect and Use Your Personal Information

III. How We Use Cookies and Similar Technologies

IV. How We Share, Transfer and Publicly Disclose Your Personal Information

V. How We Protect Your Personal Information

VI. How We Store Your Personal Information

VII. Your Rights

VIII. Other Third Parties and Their Services

IX. Protection of Minors

X. Notices and Revisions

XI. How to Contact Us

I. Definitions

Third Party: Refers to suppliers with whom we cooperate for the needs of personal information collection, data storage, system maintenance, business support, etc., or individuals, companies, enterprises or other organizations with whom we establish cooperative or investment relations for other matters.

Personal Information: Refers to various types of information recorded by electronic or other means that can identify the identity of a natural person alone or in combination with other information, excluding information after anonymization processing.

Sensitive Personal Information: Refers to personal information that may endanger personal and property security if disclosed, illegally provided or abused, and is extremely likely to cause damage to personal reputation, physical and mental health or discriminatory treatment. For the relevant sensitive personal information listed in this Privacy Policy, we will prompt you to pay attention to it in a prominent manner (bold and underlined text) in this Privacy Policy for your alertness during reading.

Children: Refers to minors under the age of fourteen (inclusive).

Deletion of Personal Information: Refers to the act of removing personal information from the systems involved in the provision of products and/or services to keep it in an unretrievable and inaccessible state.

Anonymization: Refers to the processing of personal information to make it impossible to identify a specific individual and irretrievable.

II. How We Collect and Use Your Personal Information

(I) Basic Business Functions

1. Account Registration and LoginWe provide services to you based on your Bangmaoda account. You may register and log in to your account using your mobile phone number, SMS verification code and login password. The mobile phone number you submit is used for your account registration, login and password retrieval, and also serves as one of the designated contact methods between you and us for account management-related operations. Please understand that this is a mandatory requirement to comply with the real-name network registration system.

You may authorize us to obtain your WeChat account for account registration and quick login. We will invoke and launch the WeChat client and collect your WeChat nickname, WeChat OpenID and UnionID to create or bind an account for you (see Explanation of Third-Party Services and Associated Launch). After successful account registration, you will obtain an exclusive customer ID, and you may choose to log in to your account using your customer ID and login password. If you have previously registered an account using your email address, or set an email address after successful account registration, you may also log in to your account using your email address and login password, or retrieve your login password by receiving an SMS verification code via your email address. If you fail to provide such information, you may not be able to register and log in, nor use our products and/or services.

In addition, you may use the Bangmaoda Order Assistant App to scan a QR code for quick login to the PC-side ordering platform, during which we do not collect or store your personal information.

After completing account registration, providing additional information will help us provide you with better services and experience, including contact person, contact number, QQ number and bound email address. Failure to provide such information will not affect your use of the basic functions of our products and/or services.

You acknowledge and agree that we are committed to providing you with a one-stop service for the entire electronic and mechanical industry chain. For the convenience of your use of other products and/or services provided by us, your email address will be simultaneously applicable to all products and/or services under Bangmaoda when you send information to us.

2. Commodity/Service Information DisplayTo provide you with display services for commodities and/or services in your shopping cart or orders, we will collect your browsing information, search history, shopping cart addition information and order information.
3. Order Placement and Order ManagementWhen you prepare to price and place an order or settle the commodities in your shopping cart, we will automatically generate an order for the commodities you purchase. You are required to fill in at least the consignee information (consignee name and contact number, delivery address), order placer’s name and contact number, and technical contact person’s name and contact number in the order. At the same time, the order will specify the order information (order number, purchase details, order time, order amount).

We will use the above information to implement identity verification, confirm transactions, process payment and settlement, deliver commodities, facilitate order inquiries, provide customer service consultation and after-sales services. We will also use the above information to determine whether there are abnormalities in your transactions to protect the security of your transactions.

Please note that if you order commodities and/or services for others through our products and/or services, you need to provide the aforementioned information of the actual purchaser. Before providing us with the aforementioned information of the actual purchaser, you must ensure that you have obtained their authorization and consent.

4. Order/Commodity DeliveryAfter you place an order and complete the payment online, or redeem physical commodities with points, the third-party logistics service providers cooperating with us will complete the delivery of your orders/commodities. We will collect your order information and consignee information and provide them to the above third-party logistics service providers to ensure the safe delivery of your orders/commodities.
5. Security Protection ServicesTo safeguard the order and security of e-commerce transactions, more accurately identify violations of laws and regulations, protect the personal and property safety of you, third parties or the public from infringement, and better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks and network intrusions, we may use or integrate your device information, service log information and information we obtain from third parties through legal authorization to comprehensively judge your operational risks and promptly prevent security incidents.(1) Device InformationTo ensure the stability and security of the system when you use our products and/or services, troubleshoot potential risks, prevent the illegal acquisition of your personal information, and more accurately prevent fraud and protect account security, we will collect your device information when you use this platform, including your unique device identifiers (IMEI, IMSI, IDFA, AAID, OAID, Android ID, VAID, boot_id, MAC address), basic device information (device manufacturer, device model, system version, screen size, device type, browser information), storage and system information (SD card root directory, process information (lower versions)), and network and location information (GPS location, WiFi information (SSID, BSSID), IP address, mobile network operator, network type), and correlate such device information.

Our products are developed based on DCloud uni-app (5+App/Wap2App). During the operation of the application, it is necessary to collect your unique device identifiers (IMEI, IMSI, IDFA, OAID, Android ID, DEVICE_ID) to provide statistical analysis services, and improve performance and user experience through the analysis of application startup data and abnormal error logs. We promise not to disclose, store or use such information for any other purposes.

(2) Service Log Information

To provide you with secure services, identify violations of laws and regulations, and detect and prevent security incidents, we will automatically collect detailed information about your use of products and/or services and save it as network logs when you use this platform, including your IP address, browser type, telecom operator, network environment, language used, access date and time, browsing history, notification opening records and stay duration, and save such information in accordance with relevant legal requirements.

Please note that standalone device information and log information are information that cannot identify the identity of a specific natural person. If we combine such non-personal information with other information to identify the identity of a specific natural person, or use it in combination with personal information, such non-personal information will be deemed as personal information during the combined use period. Unless authorized by you or otherwise stipulated by laws and regulations, we will process such personal information through desensitization, de-identification/anonymization and other methods.

6. Exemption from Obtaining Consent for the Collection and Use of Personal Information in Accordance with the LawYou acknowledge and agree that in the following circumstances, we may collect and use your personal information without obtaining your authorization or consent in accordance with relevant laws and regulations:(1) It is necessary for the conclusion and performance of a contract to which you are a party, or for the implementation of human resource management in accordance with legally formulated labor rules and regulations and legally signed collective contracts;(2) It is necessary for the performance of statutory duties or obligations;(3) It is necessary for responding to sudden public health incidents, or for protecting the life, health and property safety of natural persons in emergency situations;(4) It is necessary for the implementation of news reporting, public opinion supervision and other acts for the public interest, within a reasonable scope;(5) Processing your voluntarily disclosed or other legally disclosed personal information within a reasonable scope in accordance with relevant laws and regulations, unless it has a significant impact on your personal rights and interests or you explicitly refuse;(6) Other circumstances stipulated by laws and administrative regulations.

(II) Other Extended Functions

In addition to the basic functions, we also provide you with other extended functions. The provision of such functions also requires you to provide relevant personal information, and you may choose to separately agree or disagree to our collection and use of the personal information involved in this part. If you refuse to provide such information, you will not be able to use the corresponding extended functions, but you can still use the basic business functions.

1. Customer Service and After-Sales ServiceWhen you contact us or submit feedback, complaints and dispute resolution applications, we need you to provide your feedback content (pictures and text descriptions proactively provided by you to prove relevant facts), mobile phone number, email address, order information, as well as other documents you submit (if any), service records, communications and call records formed thereon to verify your identity, provide feedback to you and resolve your problems reasonably and as soon as possible. If you fail to provide such information, you will not be able to use this function, but it will not affect your use of other products and/or services provided by us.

To provide you with instant customer service, our exclusive customer service function will invoke and launch your WeChat client. Your conversation content will be processed by WeChat and subject to its privacy policy, and we will not save the relevant content (see Explanation of Third-Party Services and Associated Launch).

2. ClipboardTo improve your operational efficiency, we will apply for access to your clipboard when you copy and paste information in the Bangmaoda Order Assistant App. We only identify the clipboard content locally and will not save your clipboard information to our servers. If you refuse to authorize the clipboard permission, you will not be able to use this function, but it will not affect your use of other products and/or services provided by us.
3. Marketing ServicesWe will use your mobile phone number to send you our marketing information (service notifications, update content and event previews). We will include an unsubscribe option in the marketing information; if you do not want to receive our marketing information, you may unsubscribe at any time in accordance with the prompts in the marketing information, or contact us through the contact information provided in this Privacy Policy.

Please note that we do not have any content related to automated decision-making, and will not recommend customized content for you or impose unreasonable differential treatment on you based on your usage habits or preference information.

4. Sensor InformationTo provide you with a better page display function and protect the security of your account and operations, we need to collect your acceleration sensor information and share it with Chromium to identify whether it is a normal user behavior.
5. Additional Services Based on System PermissionsTo enhance your online shopping experience using the Bangmaoda Order Assistant App, we may apply for and use your system permissions to collect and use the required personal information. We will request you to authorize the corresponding permissions required for the functions according to the functional scenarios you wish to use, including the camera and phone permissions. If you disagree to enable the relevant permissions, you will not be able to use the corresponding functions, but it will not affect your use of other products and/or services provided by us.

You may independently decide to enable or disable these permissions at any time in your mobile phone system settings. Your decision to disable the permissions will not affect the collection and use of information based on your prior authorization. For an explanation of the permissions we need to apply for and use and the corresponding usage scenarios: enter the App homepage > click [My] > click [Settings] in the upper right corner > click [Application Permission Description] to view the Explanation of Application Permission Application and Usage Status.

(III) Other Personal Information Usage Rules

When we intend to use your personal information for other purposes not stated in this Privacy Policy, or use information collected for specific purposes for other purposes, we will seek your express consent in advance. For functions and scenarios not clearly specified in this Privacy Policy, we will display the corresponding personal information collection and usage rules to you and obtain your express consent when you actually use such functions or scenarios.

III. How We Use Cookies and Similar Technologies

In the course of your use of our services, we and our third-party partners will automatically collect certain types of usage information when you use our services, read our emails or contact us in other ways. We usually collect such information through various tracking technologies, including Cookies, web beacons, embedded scripts, location identification technologies, file information and similar technologies (collectively referred to as “Tracking Technologies”).

The purpose of us sending Cookies to you is to determine the identity and login status of registered users, simplify your repeated login steps and protect account or data security; at the same time, we may collect data obtained through Cookies and similar technologies to analyze users’ service usage, improve service quality and optimize user experience.

We will not use Cookies and similar technologies for any purposes other than those stated in this Privacy Policy. You may manage or delete Cookies according to your own preferences. Most web browsers automatically accept Cookies, but you can usually clear all Cookies saved on your computer as needed, or manage site-specific Cookies in the settings function bar of the browser. However, if you do so, you may need to manually change your user settings every time you access the Bangmaoda website, and all the information you previously recorded will be deleted, which may also have a certain impact on the security of the services you use.

We may collect information about your device and its software, such as your IP address, browser type, internet service provider, platform type, device type, operating system, and date and time stamps (a unique identifier that allows us to identify your browser, mobile device or account). When you access our website from a mobile device, we may collect a unique identification number related to your device or our mobile application.

We may collect analytical data or use third-party analytical tools to help us measure website traffic and usage trends, thereby understanding user demographic information. We may also adopt technologies such as application statistical modeling tools to enable us to identify and contact you across multiple devices.

IV. How We Share, Transfer and Publicly Disclose Your Personal Information

(I) Sharing

We will not share your personal information with any companies, organizations or individuals other than Bangmaoda, except in the following cases:

1. Obtaining your explicit consent or authorization in advance;
2. Providing it in accordance with laws and regulations, administrative provisions and mandatory requirements of government competent departments and judicial departments;
3. Handling disputes or controversies between you and others at your request;
4. Providing it in accordance with the agreements signed with you (including electronically signed online agreements and the corresponding platform rules) or other legal document agreements;
5. Using it based on the social public interests and sudden public health incidents in compliance with laws and regulations;
6. Sharing with our affiliated companies: Our affiliated company Yancheng Bangmaoda Technology Co., Ltd. or other affiliated companies will jointly process your personal information with us to the extent necessary for providing you with relevant services, including your email address information; we have clearly agreed on the rights and obligations of each party with our affiliated companies through agreements to ensure the full protection of your personal information. In the event of a personal information security incident (or potential incident) by any party, the other party will be notified as soon as possible and corresponding measures will be taken to reduce the impact of the incident and prevent the expansion of losses;
7. Sharing with third-party business partners: We will only share the minimum necessary personal information with business partners within the necessary scope, and we will adopt strict supervision measures to conduct strict security monitoring on the application programming interfaces (APIs), software development kits (SDKs) and information systems through which business partners obtain relevant personal information. Our business partners include the following types:(1) Suppliers/Service Providers: For the sole purpose of fulfilling the purposes stated in this Privacy Policy, certain of our services will be provided by third-party business partners, including payment services and after-sales services. To ensure the smooth completion of the services provided to you, we may share the necessary personal information (mobile phone number, consignee information, payment information) for providing services to you with the above partners;(2) Other Business Partners: Partners entrusted by us to provide other business support (including technical infrastructure services, analyzing the use of our services, measuring the effectiveness of services); partners entrusted by us to conduct promotion and advertising (we will only provide them with information such as the coverage, effectiveness and statistics of the promotion, and will not provide personal information that can identify your identity);(3) Based on your separate consent: We will share with other third parties upon obtaining your separate consent again (including but not limited to signing other agreements);(4) Based on social public interests in compliance with laws and regulations.

We will only share your personal information for legal, legitimate, necessary, specific and clear purposes. For all companies, organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

For information on the entrusted processing and sharing of your personal information by Bangmaoda with third parties, see the List of Personal Information Shared by Bangmaoda with Third Parties.

(II) Transfer

We will not transfer your personal information to any companies, organizations or individuals, except in the following cases:

1. Obtaining your explicit consent or authorization in advance;
2. In the event of merger, division, dissolution, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy; otherwise, we will require the company or organization to seek authorization and consent from you again.

(III) Public Disclosure

We will only publicly disclose your personal information in the following cases:

1. Obtaining your explicit consent or authorization in advance;
2. Disclosure based on law: We may disclose your personal information to the above regulatory authorities in the case of laws, legal procedures, litigation or mandatory requirements of government competent departments;
3. If we determine that you have violated laws and regulations or seriously violated the Bangmaoda platform agreements and rules, or to protect the personal and property safety of other users or the public from infringement, we may disclose your personal information, including relevant violations and the measures we have taken against you.

In accordance with legal provisions, the sharing and transfer of anonymized personal information, with the assurance that the data recipient cannot restore and re-identify the personal information subject, does not constitute an external sharing, transfer or public disclosure of personal information, and the storage and processing of such data will not require separate notification to and consent from you.

Please note that the information you voluntarily post or even publicly share when using products and/or services may involve your or others’ personal information or even sensitive personal information. Please be more cautious when considering posting or even publicly sharing relevant information when using our products and/or services.

V. How We Protect Your Personal Information

1. Data Security Technical MeasuresTo protect the security of your information, we will take various reasonable physical, electronic and managerial security measures to protect your information from disclosure, damage or loss, including but not limited to SSL, encrypted information storage, access control of data centers, dedicated network channels and proxies. We also adopt strict management measures for employees who may have access to your information, including but not limited to implementing different permission controls according to job positions, signing confidentiality agreements with them, and monitoring relevant operation activities. We will provide corresponding security measures to protect your information in accordance with the existing technology and provide reasonable security guarantees. We will make every effort at all times to prevent your information from being disclosed, damaged or lost.
2. Security CertificationWe are committed to providing all-round protection for the security of your information. At present, the core portal website of Bangmaoda has passed the Level 3 Protection Certification for Information Systems issued by the Ministry of Public Security. In addition, Bangmaoda designs information security policies and procedures with reference to international standards, and regularly verifies the effectiveness of security measures through third-party audits. We have obtained the dual certification of the international standard ISO/IEC 27001:2022 Information Security Management System and ISO/IEC 27701:2019 Privacy Information Management System to ensure the security of your personal information. However, please understand that the internet is not an absolutely secure environment. We strongly recommend that you assist us in protecting the security of your account by using secure methods and complex passwords. If you find that your personal information has been leaked, especially your account or password, please contact us immediately through the contact information provided in this Privacy Policy so that we can take corresponding measures.
3. Guarantees in Cooperation Agreements with Third PartiesBefore we share your personal information with other third parties, we will strictly require the third parties to assume obligations and responsibilities for information protection. To this end, we will require third parties to sign data processing agreements or include clauses and agreements on data protection and personal information processing in the cooperation agreements signed by both parties before cooperation. The agreements strictly stipulate the third parties’ confidentiality obligations for users’ personal information, including that the storage, use and circulation of information shall all meet our control requirements and be subject to our review, supervision and audit. In the event of any violation, we will require the other party to bear corresponding legal liabilities.
4. Personal Information Security IncidentsIn the unfortunate event of a personal information security incident, we will inform you in a timely manner in accordance with the requirements of laws and regulations of: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant circumstances of the incident via email, letter, phone call, push notification and other methods. If it is difficult to inform each personal information subject one by one, we will adopt reasonable and effective methods to issue an announcement. At the same time, we will also report the disposal of the personal information security incident to the regulatory authorities in accordance with their requirements.

VI. How We Store Your Personal Information

1. Storage LocationIn principle, personal information collected and generated by us in the People’s Republic of China will be stored in the People’s Republic of China, except in the following cases: clearly stipulated by laws and regulations; obtaining your authorized consent separately. In the above cases, we will require the data recipient to process personal information in accordance with this Privacy Policy as well as the security and confidentiality measures stipulated by laws, regulations and other relevant provisions.
2. Storage PeriodWe promise to retain your personal information only for the necessary and minimum period required to achieve the purposes stated in this Privacy Policy, unless there are mandatory retention requirements by law (for example, the E-Commerce Law of the People’s Republic of China requires that commodity and service information and transaction information be kept for not less than three years from the date of completion of the transaction; other circumstances that require a reasonable extension of the period for financial, audit and dispute resolution purposes). After your personal information exceeds the retention period, we will delete your personal information or conduct anonymization processing on it in accordance with the requirements of applicable laws.

Please note that our judgment of the minimum retention period is mainly based on the following criteria: (1) maintaining corresponding transaction and business records to respond to your possible inquiries or complaints; (2) ensuring the safety and quality of the services we provide to you; (3) whether you agree to a longer retention period.

3. Cessation of Operation of Products and/or ServicesIn the event of cessation of operation of products and/or services, unless otherwise stipulated by laws, regulations or normative documents, we will inform you of such circumstances, immediately stop collecting your personal information, and at the same time delete the collected personal information or conduct anonymization processing on it. If neither anonymization nor deletion is feasible (for example, your personal information has been stored in backups), we will securely store your personal information, isolate it from other data processing areas and restrict any further processing of it.

VII. Your Rights

1. Obtain a Copy of Personal InformationYou have the right to obtain a copy of your personal information, which you may request us to provide by contacting us through the methods specified in the “How to Contact Us” section of this Privacy Policy. Where technically feasible (e.g., matching data interfaces), we may also transmit a copy of your personal information directly to a third party designated by you at your request. Unless otherwise stipulated by laws and regulations, we will accept and process your request within 15 working days.
2. Transfer of Personal InformationWith the continuous development of our business, we may undergo mergers, acquisitions and asset transfers, and your personal information may be transferred as a result. In the event of the aforementioned changes, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy; otherwise, we will require the company or organization to seek authorization and consent from you again.

If you take the initiative to submit an application for the transfer of personal information, you may contact us through the methods specified in the “How to Contact Us” section of this Privacy Policy. Unless otherwise stipulated by laws and regulations, we will accept and process your request within 15 working days.

3. Respond to Your Above Right RequestsIf you are unable to exercise your rights through the methods or paths listed in this Privacy Policy, you may contact us through the methods specified in the “How to Contact Us” section of this Privacy Policy. To ensure security, we may require you to submit a written request or prove your identity in other ways when you exercise the above rights. Unless otherwise stipulated by laws and regulations, we will accept and process your request within 15 working days.

We will not charge fees for your reasonable requests in principle, but we may charge a certain cost fee for multiple repeated requests that exceed a reasonable limit. We may refuse requests that are groundlessly repeated, require excessive technical means (e.g., the need to develop new systems or fundamentally change current practices), pose risks to the legitimate rights and interests of others, or are highly impractical (e.g., involving information stored on backup tapes).

4. Exceptions to Responding to Your Right RequestsNotwithstanding the above provisions, in accordance with the requirements of laws and regulations, we may not be able to respond to your requests in the following cases:(1) Related to our performance of obligations stipulated by laws and regulations;(2) Directly related to national security and national defense security;(3) Directly related to public security, public health and major public interests;(4) Directly related to criminal investigation, prosecution, trial and execution of judgments;(5) We have sufficient evidence to show that you have subjective malice or abuse of rights;(6) It is for the protection of the major legitimate rights and interests of you or other individuals but it is difficult to obtain the consent of the person concerned;(7) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;(8) Involving trade secrets.

VIII. Other Third Parties and Their Services

Our services may contain links to and from third parties directly related to our business partners, advertisers and social media websites. In addition, our users may post links to third-party websites. If you follow a link to any website, please note that these third parties and their services have their own privacy policies. We strongly recommend that you read their privacy policies, terms and conditions of use to understand how they collect, use and share personal information, and please be cautious when providing your personal information.

IX. Protection of Minors

We do not provide services to children under the age of fourteen (inclusive).

Our services are targeted at adults who have reached the age of eighteen and have full capacity for civil rights and civil conduct. For individuals who have reached the age of sixteen but not eighteen, even if they take their own labor income as the main source of living and have full capacity for civil rights and civil conduct, they are not within the scope of our services.

If we discover or are informed that we have collected the personal information of minors without first obtaining the verifiable consent of their parents or legal guardians, we will take appropriate measures such as deletion of the relevant personal information in a timely manner.

X. Notices and Revisions

We may revise or update this Privacy Policy from time to time to reflect changes in our business development and compliance requirements. However, we will not reduce your rights under this Privacy Policy without your explicit consent. We will issue the updated version on the website and mobile terminal, and remind you of the updated content through website announcements, push notifications, in-site messages, red dot prompts or other appropriate methods before it takes effect. Please visit in a timely manner to understand the latest Privacy Policy.

For material changes, we will inform you of the specific changes to the Privacy Policy through a pop-up window and re-obtain your authorized consent.

Material changes referred to in this Privacy Policy include but are not limited to:

1. Major changes in the product and/or service model, such as the purpose of personal information processing, the type of personal information processed, the method of using personal information, etc.;
2. Major changes in our ownership structure, organizational structure, etc., such as changes in ownership caused by business adjustments, bankruptcy and mergers and acquisitions, etc.;
3. Major changes in the main objects of personal information sharing, transfer or public disclosure;
4. Major changes in your rights to participate in personal information processing and their exercise methods;
5. Changes in the responsible department, contact information and complaint channel for personal information security processing by us;
6. High risks indicated in the personal information security impact assessment report.

XI. How to Contact Us

If you have any questions, opinions or suggestions about this Privacy Policy, your personal information, or complaints and reports, you may contact us through the following method:

Personal Information Protection Officer Email: xiaxiaocun@shbmds.com