Global Personal Data Protection Statement

Meitrack Group and its global affiliates (collectively referred to as the “Meitrack”, “we”, “us”, and “our”) respect your privacy. Therefore, we have developed a Global Personal Data Protection Statement (hereinafter referred to as “this Statement”) that covers how we collect, use, disclose, protect, store and transfer your personal data. Please take a moment to read this Statement carefully and familiarize yourself with its content. If you have any questions, you are welcome to contact us.

This Statement explains how Meitrack processes your personal data, but does not cover all processing scenarios as you will be informed in specific processing activity. The products or services discussed, mentioned, or introduced in this statement vary depending on your product or geographic location. The privacy notice or supplementary statement released by Meitrack for a specific product or service will explain how Meitrack processes your personal data. Therefore, before using a specific product or service, it is recommended that you read this Statement as well as the privacy notice or supplementary statement released by Meitrack for the product or service to understand how it processes your personal data.

This Statement applies only to Meitrack software platform products, including devices, accessories, computer applications, software, websites, and services that are displayed or mentioned in this Statement.

1. Definitions

“Personal Data” means any data, recorded electronically or otherwise, about a natural person who can be identified from that data or from that data in combination with other information.

“Meitrack Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with Meitrack. “Control”, for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity.

“Services” means any of the following services provided by Meitrack: (a) Meitrack-branded product offerings made available via the Internet on http://meiligao.org, (b) consulting or training services provided by Meitrack either remotely via the Internet or in person, and (c) any support services provided by Meitrack, including access to Meitrack’s help desk.

2. Purpose of Meitrack’s Processing of Personal Data

Before using Meitrack products or services, you may need to provide personal data. You do not have to provide your personal data to Meitrack, but in some cases, if the data requested by us is not provided, we may be unable to provide related products or services to you. Meitrack will collect and use your personal data for the purposes stated in this Statement.

3. Duration

The processing of personal data will be carried out by Meitrack while the Customer’s Platform Account is in existence or as needed for the performance of the obligations and rights between Meitrack and the Customer unless otherwise agreed upon in writing.

4. Type of Personal Data Processed

The Customer may submit personal data to Meitrack, the extent of which is determined and controlled by the Customer in its sole discretion, and which may include, but is not limited to the following categories of personal data:

(a) Account Information. This type of information includes your name, email address, mobile phone number, order information, shipping address, and payment mode. The Customer is responsible for maintaining the secrecy of the password and information of the Customer’s Platform Account at all times.

(b) Device Information. Meitrack will collect data about your device and how you and your device exchange information with Meitrack products and services. This type of information includes the device and application information, log information, location information, and information you store on your device or servers.

(c) Additional Profile Information. The Customer may choose to provide additional information as part of its profile.

(d) Other Information. The Customer may choose to provide information when the Customer fills in a form, conducts a search, and updates or adds information to its Platform Account. Meitrack may also collect information about you, your device, and the use of services in other ways.

5. How Meitrack Uses Your Personal Data

5.1 Register and activate Meitrack products that you have purchased.

5.2 Register a Meitrack account so that you can enjoy a wider range of functions and mobile services.

5.3 Deliver, activate, or verify the products and services you have requested, or make changes and provide technical support and after-sales services for the products and services based on your requirements.

5.4 Send you operating system or application updates and installation notifications.

5.5 Provide personalized user experience and content.

5.6 Carry out internal auditing, data analysis, and research; analyze business operation efficiency and measure market shares; and improve Meitrack’s products and services.

5.7 Synchronize, share, and store the data you have uploaded or downloaded, as well as the data needed for the uploading and downloading operations.

5.8 Other purposes within specific services or with your consent.

6. Meitrack Agrees and/or Warrants

6.1 Meitrack agrees and/or warrants to process the personal data only on behalf of the Customer and in compliance with its instructions and this Statement.

6.2 Meitrack agrees and/or warrants that all personal data processed on behalf of the Customer remains the property of the Customer and/or the relevant data subjects.

6.3 Meitrack agrees and/or warrants that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by this Statement, Meitrack will promptly notify the change to the Customer, in which case the Customer is entitled to suspend the transfer of data and/or terminate the Services.

6.4 Meitrack agrees and/or warrants that Meitrack has implemented the technical and organizational security measures before processing the personal data transferred.

6.5 Meitrack agrees and/or warrants that Meitrack will not disclose the personal data to third parties without your consent, unless so permitted by laws and regulations, legal process or enforceable government.

7. The Customer Agrees and/or Warrants

7.1 The Customer agrees and/or warrants that the processing of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the Data Protection Law.

7.2 The Customer agrees and/or warrants that it has instructed and throughout the duration of the personal data-processing services will instruct Meitrack to process the personal data transferred only on the Customer’s behalf and in accordance with this Statement.

7.3 The Customer agrees and/or warrants that it will read this Statement and product documentation carefully and determine whether to provide the personal data to Meitrack. Once the data is provided, it agrees that it will instruct Meitrack to process the personal data in accordance with this Statement and product documentation.

7.4 The Customer agrees and/or warrants to access and use the Services only for legal, authorized, and acceptable purposes.

7.5 The Customer will not use (or assist others in using) the Services in ways that: (a) violate, misappropriate, or infringe the rights of Meitrack, its users, or others; (b) are illegal, obscene, defamatory, threatening, intimidating, harassing, hateful, racially, or ethnically offensive, or instigate or encourage conduct that would be illegal, or otherwise inappropriate; (c) involve publishing falsehoods, misrepresentations, or misleading statements; (d) impersonate someone; (e) involve sending illegal or impermissible communications such as bulk messaging, auto-messaging, auto-dialing, and the like; (f) do not (or help others) distribute, license, transfer, display, perform, access, use, copy, adapt, modify, and prepare derivative works; (g) do not exploit the Software Platform in impermissible or unauthorized manners, or in ways that burden, impair, or harm Meitrack, the Software Platform, systems, other users, or others; or (h) do not reverse engineer, alter, modify, create derivative works from, decompile, or extract code from the Software Platform; do not send, store, or transmit viruses or other harmful computer codes through or onto the Software Platform; do not interfere with or disrupt the integrity or performance of the Software Platform; do not collect the information of or about other users in any impermissible or unauthorized manner; do not sell, resell, rent, or charge for the Software Platform; do not distribute or make the Software Platform available over a network where it could be used by multiple devices at the same time.

7.6 The Customer agrees and/or warrants that the Customer is responsible for keeping the Customer’s Platform Account safe and secure, and the Customer will notify Meitrack promptly of any unauthorized use or security breach of the Customer’s Account or the Software Platform.

7.7 The Customer agrees and/or warrants that Meitrack grants the Customer a limited, revocable, non-exclusive, non-sublicensable, and non-transferable license to use the Software PlatformPlatform.

8. Technical and Organizational Measures

8.1 Meitrack shall take the appropriate technical and organizational measures to adequately protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.

8.2 The technical and organizational measures are subject to technical progress and further development. In this respect Meitrack may implement alternative adequate measure, however, the security level of the defined measures must never be reduced. Major changes must be documented.

8.3 We will take the following technical and organizational measures:

(a) Meitrack servers are located at the secure data center.

(b) The servers are protected from various kinds of vulnerabilities, including 360 Total Security and Huorong Security.

(c) The software has been regularly updated to keep the private data security level high.

(d) Our company exploits modern data encryption methods, such as end-to-end.

(e) All the employees have been trained how to spot potential data threats and take security measures.

(f) Online personal data can be stored for three months. After this period, the data will be automatically deleted. However, you can authorize Meitrack to set the storage period of personal data.

(g) The Customer can browse its personal data (name, email, account ID, etc.) in the profile settings at any time.

(h) If the Customer decides to correct or delete (partially or completely) its private data from the platform, please contact Meitrack. After Meitrack verifies its identity, data will be cleared within one business day.

(i) Your own Privacy Policy and Terms of Service will be displayed on the login page after you fill in one of the Admin panel fields.

9. How Meitrack Processes Your Personal Data

9.1 Entrusting Third Parties. Meitrack has the right to entrust third parties with the processing of your personal data on behalf of Meitrack, but the third parties can use your information only for the purpose of providing services to you on behalf of Meitrack. Meitrack will sign stringent non-disclosure agreements (NDAs) or data processing clauses with the third parties, requiring them to comply with this Statement and take appropriate confidentiality and security measures when processing personal data.

9.2 Sharing. Sharing refers to the process in which Meitrack shares any personal data with another data controller, and the parties have independent control over your personal data. Meitrack will not share any personal data with third parties unless one of the following circumstances applies: (a) After obtaining your consent, Meitrack may share the information that you have authorized with specified third parties. (b) Meitrack may share your information as required by laws and regulations, for resolving legal disputes, or as required by administrative or judiciary authorities pursuant to law. (c) To provide better service to you, Meitrack may share your information with business partners, such as the order information, account information, device information, and location information, but your information will be shared only for legitimate, appropriate, necessary, specific, and explicit purposes.

9.3 Transfer. A transfer refers to the process of transferring personal data from Meitrack to another data controller. Meitrack will not transfer your personal data to any company, organization or individual unless one of the following circumstances applies: (a) After obtaining your consent, Meitrack may transfer your personal data to specified third parties. (b) When the transfer of your personal data is involved due to mergers, acquisitions, or liquidation, new companies or organizations that hold your personal data will continue to abide by this Statement.

9.4 Public disclosure. (a) After obtaining your consent, Meitrack may disclose your personal data to third parties. (b) Meitrack may disclose your personal data to third parties as required by laws and regulations, for resolving legal disputes, or as required by administrative or judiciary authorities pursuant to law.

10. Notification of Data Breaches

10.1 In the event that Meitrack is aware of any breach of security that results in the accidental, unauthorized or unlawful destruction or unauthorized disclosure of or access to personal data, Meitrack shall, to the best of its ability, notify the Customer thereof with undue delay, and the Customer has the right to request the retention or deletion of the personal data. Meitrack will ensure that the furnished information is complete, correct and accurate.

10.2 If required by laws and/or regulations, Meitrack shall cooperate in notifying the relevant authorities and/or data subjects. The Customer remains the responsible party for any statutory obligations in respect thereof.

11. Governing Law and Jurisdiction

This Statement shall be governed by and construed in accordance with the laws of People’s Republic of China.

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