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Privacy Policy
Privacy Policy
How Shanghai Hongying Intelligence Collects and Uses Your Personal Information How Shanghai Hongying Intelligence Uses Cookies and Similar Technologies How Shanghai Hongying Intelligence discloses your personal information Your rights in relation to personal information processing activities How Shanghai Hongying Intelligence Protects and Retains Your Personal Information How Shanghai Hongying Intelligence handles children's personal information Third-party providers and their services How this policy will be updated How to contact Shanghai Hongying Intelligent Technology Co.
HYTOP Smart Control Co., Ltd. and its global affiliates (hereinafter referred to as "HYTOP Smart", "we", and "our") are aware of the importance of privacy to you and will respect your privacy. Before submitting personal information to HYTOP Smart, please read and understand this Privacy Policy (hereinafter referred to as "this Policy"). This Policy applies to HYTOP Smart websites, products, and services that display this Privacy Policy or link to this Privacy Policy. In particular, this website is operated by HYTOP Smart, which is the personal information processor of the personal information collected by this website.

This Policy explains how HYTOP Smart processes your personal information. However, this Policy may not cover all possible data processing scenarios. Information about the collection of product- or service-specific data may be outlined by HYTOP Smart in specific privacy notices or supplemental statements issued with particular products or services, or provided in notices at the time of data collection.

Our purpose in formulating this Policy is to help you understand the following:
1. How Shanghai Hongying Intelligence Collects and Uses Your Personal Information
2. How Shanghai Hongying Intelligence Uses Cookies and Similar Technologies
3. How Shanghai Hongying Intelligence discloses your personal information
4. Your rights in relation to personal information processing activities
5. How Shanghai Hongying Intelligence Protects and Retains Your Personal Information
6. How Shanghai Hongying Intelligence handles children's personal information
7. Third-party providers and their services
8. How this policy will be updated
9. How to contact Shanghai Hongying Intelligent Technology Co.
1. How Shanghai Hongying Intelligence Collects and Uses Your Personal Information

### 1.1 How Shanghai HYTOP Smart Collects Your Personal Information

Personal information refers to various information recorded electronically or by other means related to identified or identifiable natural persons, excluding information processed anonymously. When you use Shanghai HYTOP Smart products and services or interact with us, we may collect your personal information. Depending on the different products and services you use and your interactions with us, the specific types of data collected will also vary. You are not required to provide personal information to Shanghai HYTOP Smart, but in some cases, if you choose not to provide it, Shanghai HYTOP Smart may not be able to provide you with related products or services or respond to or resolve issues you encounter. Shanghai HYTOP Smart will only collect and use your personal information for the purposes stated in this statement. The personal information we may collect includes:

#### 1.1.1 Information Provided by You to Shanghai HYTOP Smart
- **Personal contact information:** When you contact us, provide us with feedback, suggestions, or inquiries, participate in our online or offline activities, subscribe to marketing materials, etc., you may leave your contact information, including your name, company name, position, email address, phone number, etc.

#### 1.1.2 Information Obtained During Your Interaction with Us or When Using Our Products and Services
- **Device and network information:** We will collect relevant information about your device when you use Shanghai HYTOP Smart products and services, such as device type, device name or model, device identifier, operating system type and version, browser type and version, screen resolution, language settings, IP address, network service provider, etc., as well as other technical information specific to the product.
- **Interaction record information:** This type of information will be directly submitted to us by you when you use our website, products or services, and interact with us. For example, information requests you provide to us, including query information you enter or questions or information you provide to obtain customer support. Your online or offline communication records through online or offline activities, phone calls, emails, etc.
- **Log information:** When you use Shanghai HYTOP Smart's products and services or view content provided by Shanghai HYTOP Smart, Shanghai HYTOP Smart will automatically collect and store necessary log information, such as the time of each service access, the page path accessed, client IP address, event information (such as errors, crashes, restarts, upgrades), etc.

#### 1.1.3 Information from Third-party Sources and Publicly Available Information
Where permitted by law, we may also obtain data from public and commercial third parties or publicly available sources, for example, we support our services by purchasing statistical data from other companies.

Shanghai HYTOP Smart may also collect and use non-identifiable data. Non-identifiable data refers to data that cannot be used to identify individuals. For example, Shanghai HYTOP Smart will collect aggregated statistical data, such as website traffic. Shanghai HYTOP Smart collects this data to understand how users use its website, products, and services. Through this, Shanghai HYTOP Smart can improve its services to better meet customer needs. Shanghai HYTOP Smart may independently decide to collect, use, process, transfer, or disclose non-identifiable data for other purposes. We will do our best to separate your personal information from non-identifiable data and use these two types of data separately. If personal information is mixed with non-identifiable data, it will still be treated as personal information processing.

### 1.2 How Shanghai HYTOP Smart Uses Your Personal Information
We may use your personal information for the following purposes:
1. Respond to your interaction requests. When you visit our website, participate in online or offline activities, request changes, or request the information you requested (such as marketing materials, white papers, subscribe to electronic magazines), and contact us about any issues or product information (such as providing technical support, giving us feedback, suggestions, inquiries, etc.).
2. Recommend relevant content, products, or services to you. With your consent, we will send you information about products and services that may interest you; invite you to participate in Shanghai HYTOP Smart activities (including promotional activities), market research, or satisfaction surveys; or provide you with personalized content and services when you visit online platforms such as websites and apps. If you do not wish to receive such information, you can unsubscribe at any time according to the SMS prompt or other methods we provide.
3. Other situations:
   - Investigate errors when you choose to send error details to us.
   - Protect the security of our products, services, and customers or users, and implement and improve our loss prevention and anti-fraud programs.
   - Comply with and enforce applicable legal requirements, relevant industry standards, or our policies.

2. How Shanghai Hongying Intelligence Uses Cookies and Similar Technologies

2.1 Cookies
To ensure that our websites work properly, we sometimes store small data files on your computer or mobile device called cookies, which are plain text files that are stored on your computer or mobile device by a web server.The contents of a cookie can only be retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile application. cookies usually contain an identifier, the name of the site, and some numbers and characters. Cookies enable websites to store data such as user preferences or items in a shopping basket.

Shanghai Hongying Intelligence enables cookies for the same reason that most websites or internet service providers enable cookies, to improve the user experience. With the help of cookies, websites are able to remember a user's single visit (using session cookies) or multiple visits (using persistent cookies). Cookies enable websites to save settings such as the language of the computer or mobile device, font size and other browsing preferences. This means that users do not have to reconfigure their preferences each time they visit. If a website does not use cookies, it will treat a user as a new visitor every time they open a web page. For example, if you log in to a website and then go to another page, the website will not recognise you and you will be logged out again. Shanghai Hongying Intelligence will not use cookies for any purpose other than those described in this policy. You can manage or delete cookies according to your own preferences, please see AboutCookies.org for more information. You can clear all cookies stored on your computer, and most web browsers have the ability to block cookies. However, if you do this, you will need to change your user settings yourself each time you visit our site. For more information on how to change your browser settings, please visit the links below:
Internet Explorer Google Chrome Mozilla Firefox Safari Opera

2.2 Web beacons and pixel tags
In addition to cookies, we may use other similar technologies such as web beacons and pixel tags on our website. For example, emails sent to you by Shanghai Hongying Intelligence may contain click-through URLs that link to content on Shanghai Hongying Intelligence's websites, and if you click on the link, Shanghai Hongying Intelligence will track the click to help us understand your product and service preferences and improve customer service. A web beacon is usually a transparent image embedded on a website or in an email. Pixel tags in emails allow us to know if an email has been opened. If you do not want your activity to be tracked in this way, you can unsubscribe from Shanghai Hongying Intelligence's mailing list at any time.

Your use of our website means that you agree to the use of cookies, web beacons and pixel tags as described above.

3. How Shanghai Hongying Intelligence discloses your personal information

Generally, Shanghai Hongying Intelligence will not disclose your personal information to the public, except for the following scenarios:
(1) Where certain services are provided by an authorised partner of Shanghai Hongying Intelligence, Shanghai Hongying Intelligence will share your personal information with that partner as described in this policy. For example, if the partner is commissioned to handle hotlines, send emails, provide technical support, etc. on behalf of Shanghai Hongying Intelligence, we will require the partner to use your personal information only for the purpose of providing services to you on behalf of Shanghai Hongying Intelligence;
(2) We may disclose personal information amongst Shanghai Hongying Intelligence's affiliates. We will only disclose your information within Shanghai Hongying Intelligence's affiliates for a specific, explicit and lawful purpose, and will only disclose information that is necessary to provide the service.
(3) Shanghai Hongying Intelligence may also disclose your personal information to relevant law enforcement or other governmental authorities when required to do so by applicable law or in response to legal process. In some jurisdictions, if Shanghai Hongying Intelligence is involved in a reorganisation, merger or bankruptcy and liquidation proceeding, your personal information may also be disclosed to the counterparty.
(4) Shanghai Hongying Intelligence may also disclose your data where there is a legitimate need to do so, for example, in order to perform a contract and where we believe that disclosure is necessary and appropriate to prevent bodily harm or property damage or to investigate possible or actual unlawful acts.

4. Your rights in relation to personal information processing activities

You should ensure that all personal information submitted is accurate. Shanghai Hongying Intelligence endeavours to maintain the accuracy and integrity of personal information and to update such data in a timely manner.

Where required by applicable law, you may (1) have the right to inspect and copy the specific personal information we hold about you; (2) require us to update or correct your inaccurate personal information; (3) refuse or restrict our use of your personal information; (4) require us to delete your personal information; and (5) require us to provide explanatory notes on the rules for handling personal information. If you would like to exercise the relevant rights, please click here to give us online feedback. For security purposes, you may be required to provide a written request. We may refuse to process a request if we have a reasonable basis to believe that the request is fraudulent, unenforceable, or damaging to the privacy rights of others.

You also have the right to withdraw your consent at any time, where required by applicable law, when Shanghai Hongying Intelligence processes your personal information based on your consent. However, revocation of consent will not affect the legality and validity of our processing of your personal information based on your consent prior to such revocation, nor will it affect our processing of your personal information based on any other appropriate basis of legitimacy.

5. How Shanghai Hongying Intelligence Protects and Retains Your Personal Information

Shanghai Hongying Intelligence values the security of personal information. We employ appropriate physical, managerial and technical safeguards to protect your personal information from unauthorised access, disclosure, use, modification, damage or loss. For example, we use encryption technology to ensure the confidentiality of data; we use protection mechanisms to prevent malicious attacks on data; we deploy access control mechanisms to ensure that only authorised personnel have access to personal information; and we organise training courses on security and privacy protection to enhance staff awareness of the importance of protecting personal information. While we endeavour to protect your personal information, please be aware that no security measure is foolproof.

We will retain your personal information for as long as necessary to fulfil the purposes described in this policy, unless an extension of the retention period is required or permitted by law. Because the data storage period may vary based on different scenarios and different products and services, the criteria we use to determine the retention period include: the period of time for which the personal information is required to fulfil the business purpose, including providing products and services, maintaining corresponding transaction and business records, controlling and improving the performance and quality of the products and services, guaranteeing the security of the system, products and services, responding to possible user enquiries or complaints, locating problems, etc.; whether the user is aware of any problems; and whether the user is aware of any problems or issues. complaints, locating problems, etc.; whether the user agrees to a longer retention period; whether there are special requirements for data retention in laws, contracts, etc., etc.

6. How Shanghai Hongying Intelligence handles children's personal information

Our products, websites and services are primarily intended for adults. Children (minors under the age of 14) may not create their own user accounts without parental or guardian consent. In the event that personal information about a child is collected with parental consent, we will only use or disclose this data as permitted by law, with the express consent of the parent or guardian, or as necessary to protect the child. If SHANGHAI HONGYING INTELLIGENCE discovers that it has collected personal information from a child without first obtaining verifiable parental consent, it will endeavour to delete the data as soon as possible.

7. Third-party providers and their services

To ensure a smooth browsing experience, you may receive content or web links from third parties external to Shanghai Hongying Intelligence and its partners (hereinafter referred to as ‘Third Parties’). Shanghai Hongying Intelligence has no control over such Third Parties. It is your choice whether or not to access the links, content, products and services provided by Third Parties.

Shanghai Hongying Intelligence has no control over the privacy and data protection policies of Third Parties and such Third Parties are not bound by this Policy. Please refer to the privacy policies of such third parties before submitting personal information to them.

8. How this policy will be updated

Shanghai Hongying Intelligence reserves the right to update or modify this policy from time to time. If our Privacy Policy changes, we will post the latest version of the Privacy Policy here. If we make material changes to our Privacy Policy, we may also send you notice of the changes through various channels, such as posting a notice on our website or sending you a separate notice.

9. How to contact Shanghai Hongying Intelligent Technology Co.

If you have any privacy complaints or questions to contact Shanghai Hongying Intelligent Data Protection Officer, please click here. Normally, we will reply within fifteen working days. If you are not satisfied with our response, especially if our personal information processing behaviour has harmed your legitimate rights and interests, you can also file a complaint or report to the regulatory authorities such as Netcom, Telecom, Public Security and Industry and Commerce.

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