Shenzhen Winline Technology Co., Ltd. and its affiliated companies (hereinafter collectively referred to as “we“) attach great importance to the privacy and personal information protection of users (hereinafter also referred to as “you“). We hope to explain to you through this Privacy Policy the business scenarios of the Winline Technology Official Website (hereinafter referred to as “this Platform”) that we legally own and operate, the types of personal information that need to be processed, the ways and protective measures we provide for you to access, update, and delete such information, as well as the rules we must comply with when sharing, transferring, or publicly disclosing your personal information. At the same time, we will also inform you of what rights you enjoy. Please read carefully and fully understand this Privacy Policy. We have indicated the key content in bold and underline, please pay special attention. Accepting or agreeing to this Privacy Policy means that you:

● Confirm that you have reached the legal age required to accept this Privacy Policy (18 years old or above);

● Represent yourself or the individual you legally represent to agree to accept this Privacy Policy;

● Explicitly acknowledge that your use of this Platform’s services is subject to this Privacy Policy.

Please note that if the information you provide contains personal information of other parties, you must ensure that you have obtained legal authorization before providing such personal information to us.

If you have any questions, comments, or suggestions, please contact us through the following contact information:

Phone: [*]

Contact Address: [*]

Table of Contents

I. How We Collect and Use Your Personal Information

II. How We Use Cookies and Similar Technologies

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

IV. How We Store and Protect Your Personal Information

V. How You Manage Your Personal Information

VI. Protection of Minors’ Personal Information

VII. Updates and Notifications of This Privacy Policy

VIII. How to Contact Us

I. How We Collect and Use Your Personal Information

1.1 Methods of Personal Information Collection

We will obtain your personal information through the following channels:

(1) Information you directly provide: We will collect and store the information you provide to us when using this Platform, including the information you fill in on various online pages of this Platform.

(2) Information we actively collect: When you use this Platform, we will collect information based on the normal operation of the Platform or the performance of legal obligations, such as network logs containing your IP address information.

1.2 Scenarios for Collecting and Using Your Personal Information

We will follow the principles of legitimacy, lawfulness, and necessity, and collect and use your personal information for the purposes described in this Privacy Policy. The specific circumstances are as follows:

(1) Leaving a message to us. You may contact us through the “Service and Support” section of this Platform. To communicate with you and respond to your needs, we will collect your name, email address, country, WhatsApp&phone number, and message content that you actively provide.

(2) Performing statutory obligations regarding cybersecurity. To fulfill obligations under laws and regulations such as the Cybersecurity Law, we need to retain network logs, which will contain your IP address information.

1.3 Exceptions to Consent Requirements

Please note that in the following circumstances, our collection and use of personal information do not require your authorization and consent:

(1) Necessary for the conclusion and performance of a contract to which the individual is a party, or necessary for human resource management conducted in accordance with legally formulated labor rules and regulations and legally signed collective contracts;

(2) Necessary for the performance of statutory duties or statutory obligations;

(3) Necessary for responding to public health emergencies, or for protecting the life, health, and property safety of natural persons in emergency situations;

(4) Processing personal information within a reasonable scope for news reporting, public opinion supervision, and other behaviors conducted for public interests;

(5) Processing personal information that has been voluntarily disclosed by the individual or otherwise lawfully disclosed within a reasonable scope in accordance with legal provisions;

(6) Other circumstances prescribed by laws and regulations.

Please note that information that cannot identify your identity or establish a direct connection with you, either alone or in combination with other information, does not constitute personal information. If we combine information that alone cannot be associated with any specific individual with other information to identify a natural person’s identity, or combine it with personal information for use, such information will be treated as personal information during the period of combined use.

1.4 Device Permission Invocation

During your use of this Platform, we will not apply for any of your device permissions.

II. How We Use Cookies and Similar Technologies

To ensure the normal and efficient operation of the website and to provide you with a more convenient access experience, we will store small data files called Cookies on your device terminal/system. The main function of Cookies is to facilitate your use of website products and services, and to help the website count the number of visitors, etc. We will not use Cookies for any purpose other than those described in this Privacy Policy. You may manage or delete Cookies according to your own preferences. You may clear all Cookies saved on your mobile device, and you have the right to accept or reject Cookies. Most browsers automatically accept Cookies, but you can usually modify your browser settings to reject Cookies according to your needs; in addition, you may also clear all Cookies saved within the software. However, you may therefore be unable to fully experience some of our convenient and secure service functions.

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

(1) Sharing

In principle, we will not share or disclose your personal information to third parties. Unless in circumstances with a legal basis, such as obtaining your separate consent, being necessary for providing services, or being necessary for performing statutory obligations, we will share, disclose, or transfer your personal information to third parties. In addition, as required by law, judicial authorities, or government authorities, we may provide your personal information.

(2) Transfer

With the development of our business, we may conduct mergers, acquisitions, reorganizations, asset transfers, or similar transactions. If personal information transfer is involved, we will require the company or organization that receives your personal information to continue to be bound by this Privacy Policy; otherwise, we will require that company or organization to seek your authorization and consent again.

Except for the above circumstances, we will not transfer your personal information without your explicit consent.

(3) Public Disclosure

We will only publicly disclose your personal information under the following circumstances and on the premise of adopting security protection measures that meet industry standards:

①　Disclosing the personal information you specify in a manner of disclosure that you explicitly agree to, according to your needs;

②　Under circumstances where we must provide your personal information as required by laws and regulations, mandatory administrative law enforcement, or judicial requirements, we may publicly disclose your personal information according to the type of personal information and the method of disclosure required. On the premise of complying with laws and regulations, when we receive requests for the disclosure of the above information, we will require that corresponding legal documents be issued, such as subpoenas or investigation letters.

(4) Exceptions to Prior Authorization and Consent When Sharing, Transferring, or Publicly Disclosing Personal Information

In the following circumstances, sharing, transferring, or publicly disclosing your personal information does not require your prior authorization and consent:

①　Related to national security and national defense security;

②　Necessary for public security, public health, and major public interests;

③　Necessary for criminal investigation, prosecution, trial, and judgment enforcement;

④　Necessary for protecting major legitimate rights and interests such as the life and property of you or other individuals, but where it is difficult to obtain the consent of the individual;

⑤　Other circumstances necessary for safeguarding public interests, such as your credit evaluation information that must be disclosed/shared;

⑥　Personal information that you have voluntarily disclosed to the public;

⑦　Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure, and other channels. However, this excludes cases where you explicitly refuse or where processing such information infringes upon your major interests;

⑧　Other circumstances where authorization is not required in accordance with the law.

According to legal provisions, for sharing, transferring, or publicly disclosing personal information that has been de-identified, and ensuring that the data recipient cannot restore and re-identify the personal information subject, our processing of such data will not require additional notification to you or your consent.

IV. How We Store and Protect Your Personal Information

(1) Storage of Personal Information

Personal information collected and generated within the territory of the People’s Republic of China will be stored within the territory of China, and will not be transmitted overseas.

We will only retain your personal information for the period necessary to achieve the purposes described in this Policy, unless laws and regulations have mandatory retention requirements, such as the Cybersecurity Law of the People’s Republic of China requiring network logs to be retained for six months. We determine the storage period of personal information mainly based on the following standards, whichever is longer: completing services related to you and maintaining corresponding service records to respond to possible inquiries or complaints from you; ensuring the security and quality of the services we provide to you; whether you agree to a longer retention period; whether there are other special agreements or legal and regulatory provisions regarding the retention period. After the retention period expires, we will delete your personal information or anonymize it in accordance with applicable legal requirements.

(2) Protection Measures for Personal Information

①　Data security measures: To ensure the security of your information, we strive to adopt various physical, electronic, and managerial security measures that meet industry standards to protect your personal information, and establish a data classification and grading system and data security management system to regulate the storage and use of personal information. We use confidentiality agreements with information access personnel and technical security measures to prevent your personal information from being accessed, publicly disclosed, used, modified, damaged, or lost without authorization. For example, using encryption technology to ensure the confidentiality of data; using trusted protection mechanisms to prevent data from being maliciously attacked; deploying access control mechanisms to ensure that only authorized personnel can access personal information; and holding security and privacy protection training courses to enhance employees’ awareness of the importance of protecting personal information.

②　Please be aware and understand that the Internet is not an absolutely secure environment. If you find that your personal information has been disclosed, please immediately contact us using the contact information provided in this Privacy Policy so that we can take corresponding measures.

③　Security incidents: In the unfortunate event of a personal information security incident, we will immediately establish a special emergency response team and activate the emergency plan to prevent the security incident from expanding. In accordance with the requirements of laws and regulations, we will promptly inform you of: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, remedial measures for you, etc. We will promptly inform you of the relevant situation of the incident by email, letter, phone, push notification, or other means. When it is difficult to inform each personal information subject one by one, we will adopt reasonable and effective methods to issue announcements. At the same time, we will also proactively report the handling of personal information security incidents as required by regulatory authorities.

V. How You Manage Your Personal Information

We attach great importance to your management of personal information, and we will, in accordance with applicable laws and regulations ensure the exercise of your personal information rights.

If you need to exercise the rights to access, copy, correct, supplement, or delete your personal information, or withdraw your authorization and consent, or exercise other personal information subject rights granted to you by applicable laws and regulations, you may contact us through the contact information in Article 8 of this Policy. We will respond to your request within 15 days after completing your identity verification.

Please understand that after you withdraw your consent or authorization, we will no longer be able to provide you with the services corresponding to the withdrawn consent or authorization, nor will we process your corresponding personal information. However, your decision to withdraw consent or authorization will not affect the personal information processing previously carried out based on your authorization.

For your reasonable requests, we do not charge fees in principle, but for requests that are repeated multiple times or exceed reasonable limits, we may charge a certain cost fee depending on the circumstances. For requests that are unreasonably repetitive, require excessive technical means (for example, requiring the development of a new system or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on backup tapes), we may refuse them.

VI. Protection of Minors’ Personal Information

We attach great importance to the protection of minors’ personal information. Our online websites and services are intended for adults. If you are a minor under the age of 18, please do not use this Platform’s services on your own and provide any information to us.

If we find that we have collected personal information of minors without prior obtaining verifiable consent from parents or legal guardians, we will seek to take appropriate measures to process the relevant data as soon as possible.

VII. Updates and Notifications of This Privacy Policy

Our Privacy Policy may be changed. Without your explicit consent, we will not reduce the rights you should enjoy under this Privacy Policy. When there are changes to our basic information, the purposes, methods, types, and retention periods of your personal information processing, the ways you manage your personal information, or our contact information, we will update them in a timely manner and present the revised content to you in the form of push notifications, pop-ups, or other appropriate forms that meet legal requirements when you log in and when versions are updated.

Under the aforementioned circumstances, if you continue to use our services, it means that you agree to accept and be bound by the revised Policy.

VIII. How to Contact Us

You may contact us through the following methods, and we will respond to your request within 15 days;

Phone: [*]

Contact Address: [*]