Issue Date: 2023/1/14

Effective Date:2023/1/14

Summary

Ugreen Group Limited (hereinafter referred to as "we") understands the importance of your personal information, and this summary is intended to show you indirectly and clearly how we handle and protect your personal information. If you need further information, please read the full UGREEN Privacy Policy.

1. How we collect and use your personal information
2. Account Data: When you register or login to our account, you need to provide us with at least an cell phone number(Users in Chin) oran E-mail address( Users not in China).We will desensitize your cell phone number or your the E-mail address. If you refuse to provide your cell phone number or E-mail address, you will not be able to complete registration, log in to and use UGREEN normally; on the other hand, you can create an account and use UGREEN by using a quick login with a third party login. You can also choose to provide us with your nickname, gender, motto, and custom avatar information to enrich your account information.
3. Third party login account data: If you choose to authorize the use of third party account login (QQ/Wechat/ Facebook/ Apple ID) for quick login, we will obtain your shared account information (avatar, nickname) from the third party. We will use your personal information in accordance with the agreement with the third party and the terms of the third party's published privacy policy regarding the sharing of personal information and in compliance with relevant regulations. If you refuse to provide authorization, you will not be able to use your third party account to log into UGREEN.
4. UGREEN app connects to UGREEN smart device data: When you use UGREEN software to connect to UGREEN smart devices, we will collect your location information, Wi-Fi list information, Bluetooth information with your permission to help you realize the connection between your phone and the device, and the control of your phone to the device. Once connected, you can monitor your device's operating status and control it remotely via UGREEN. This is the core function of UGREEN, if you choose not to provide the above information, you will not be able to use this core function.
5. Feedback: When you provide feedback to us through the "Help Center - Feedback", you need to provide your feedback content (required), optional pictures, videos, contact information (WeChat/QQ/cell phone number/ E-mail address). If you do not provide feedback content, you will not be able to submit feedback; After we receive your feedback, we will reply to you through the contact information you provide. If you refuse to provide contact information, we will not be able to respond to you, and can not deal with your problems and device failure for you. If you do not provide pictures, videos, you may not be able to well illustrate the problem of your feedback.
6. Information on permissions requested for use in providing services.

In order to provide services to you, we will ask you to obtain the following permissions: access camera album permissions, network permissions, storage permissions, Bluetooth permissions, geolocation permissions, system settings permissions, and update and install applications permissions. If you do not agree to grant the above permissions, you will not be able to use the functions associated with the permissions, but it will not affect your use of other functions. Special Note: We only get the permission to read and do not collect or use the content of your local files, nor do we make any modification or editing to the above content.

1. How we share your personal information

Please be aware that some parts of the products/services we provide to you cannot be done alone, so we may share or entrust some of your personal information with third parties such as our partners, and we will take the necessary technical and administrative measures to protect the security of your personal information as much as possible. For a list of the personal information we share, please click on "List of Third Party Information Sharing" to review.

III. How you manage your personal information

You can click "Settings-Personal Center-Account Security" in the upper left corner of UGREEN app to manage your personal information, including inquiry, correction, withdrawal, deletion of your personal information, and cancellation of your account.

If you encounter problems in managing your personal information, you may contact us. However, please also understand that we may not be able to fully comply with your request due to compliance with legal and regulatory obligations or the necessity of the services we provide.

1. Our protection of personal information of minors

Minors under the age of 16 (or the age of majority according to the user's local laws) ("Minors") should obtain the prior express consent of their parents or legal guardians before using our products and/or services. If you are a minor, you should read this Privacy Policy Summary and the UGREEN Privacy Policy together under the supervision and guidance of a guardian before using our products and/or services, and you should use our products and/or services with the express consent and guidance of your guardian. Without such consent and acknowledgement, we do not knowingly collect any personal information from minors.

If you are the guardian of a minor and you have questions about the personal information of a minor in your custody, you may contact us through the contact information listed in Section 5 of this Privacy Policy Summary.

1. Contact us

You can contact us in any of the following ways.

We have established a dedicated personal information protection team and person in charge. If you have any questions, comments or suggestions regarding this policy or our services, you can contact us at:

1. 1. you can contact us through the "Feedback" on the UGREEN app, the approach: Settings - Help Center - Feedback.
2. 2. Send an email to the person in charge of personal information protection: cnfw@ugreen.com (contact email).
3. 3. Send the letter as follows：

Address: Block 7, YuAn Zone, Longcheng Industrial Park, No.39, Longguan West Road, Dalang Street, Longhua, Shenzhen, China

Tel: 0755-28066995

Postcode: 518000

UGREEN Privacy Policy

Introduction

UGREEN is a product and service provided by Ugreen Group Limited (hereinafter referred to as "UGREEN" or "we", with registered office at Block 7, YuAn Zone, Longcheng Industrial Park, No.39, Longguan West Road, Dalang Street, Longhua, Shenzhen, China). It is our obligation to protect your personal information and we will provide adequate protection for your personal information in accordance with legal and regulatory requirements. To this end, we have developed the UGREEN Privacy Policy ("Policy") to help you understand how we handle your personal information and your rights during your use of UGREEN hardware, firmware and application(app).

Application name: UGREEN

*The basic function of this app is "monitoring and remote control of the operation status of the device after connecting to the UGREEN smart device with the UGREEN app." This app requires an email address to log in, and after logging in and associating the device, you can use its functional services.

Before you interact with our UGREEN products, please make sure you read this Privacy Policy (especially those marked in bold) carefully and understand the purposes and security measures we use to process your personal information, including how we collect, use, store, share and transfer your personal information. In this policy, you can use our tips to enforce your rights related to your personal information, such as the right of inquiry, the right of deletion, etc.

At the same time, you have the right to refuse to agree to this policy, but please know that if you choose to refuse, you may not be able to fully use the relevant services and functions of UGREEN, or to achieve the results of our intended services. Your consent to this Privacy Policy means that you understand the functions provided by the application and the necessary personal information required for the operation of the functions, and give the corresponding authorization to collect and use, but it does not mean that you have separately agreed to open additional functions, processing of non-essential personal information, the opening of the relevant additional functions, processing of non-essential personal information and handling of sensitive personal information, we will seek your consent separately according to your actual use. During the reading process, if you have any questions, comments, suggestions or complaints, please contact us through the contact information in Article 9 of this policy.

This policy describes.

1. How we collect and use your personal information
2. How we share, transfer and publicly disclose your personal information

III. How you can exercise your rights

1. Safety and security measures
2. Data Retention Period
3. Protection of personal information of minors

VII. How your personal information is transferred globally

VIII. Statement on policy changes

1. Contact us

I. How we collect and use your personal information

1. Definition

Personal information: all kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding information after anonymization.

Smart device: It is a non-standard computing device produced or manufactured by hardware manufacturers that can transmit information through wireless networks, such as UGREEN smart devices.

Application: means a mobile application provided by Ugreen Group Limited that helps the end user (you) remotely control smart devices and connect to the Internet of Things (IoT) platform of the provider Aliyun Computing Co., Ltd..

2. The types of personal information we collect and the purposes for which it is used

In the course of your use of the UGREEN Services, UGREEN collects information that you voluntarily provide when using the Services or as a result of your use of the Services in order to provide you with the Services, to optimize our Services, and to protect your account security in the following ways.

（1） Information you voluntarily provide to us, purpose of use

• Account Data: When you register or log in to our account, you will need to provide us with at least your cell phone number( User in China) or an E-mail address (Users not in China). We will desensitize your cell phone number or your E-mail address. If you refuse to provide your E-mail address or your cell phone number, you will not be able to complete the registration, login and use UGREEN normally;on the other hand, you can create an account and use UGREEN by using a quick login with a third party login. You can also choose to provide us with your nickname, gender, motto, and custom avatar information in order to enrich your account information.
• Third party login account data: If you choose to authorize the use of third-party account login(QQ/ Wechat/ Facebook/ Apple ID), we will obtain your account information (avatar, nickname) from the third party. We will use your personal information in accordance with the agreement with the third party and the terms of the third party's published privacy policy regarding the sharing of personal information and in compliance with relevant regulations. If you refuse to provide authorization, you will not be able to use your third-party account to log into UGREEN.
• UGREEN app connects to UGREEN smart device data: When you use UGREEN software to connect to UGREEN smart device, we will collect yourlocation information, Wi-Fi list information , Bluetooth information with your permission to help you connect your phone to your device and control your phone to your device. Once connected, you can monitor your device's operating status and control it remotely through UGREEN. This is the core business function of UGREEN, if you choose not to provide the above information, you might not be able to use this core function.
• Feedback: When you feedback to us through the "Help Center - Feedback", you need to provide your feedback content (required), optional pictures, videos, contact information (QQ/ Wechat/cell phone number/ E-mail address). If you do not provide feedback content, you will not be able to submit feedback; if we receive your feedback, we will reply to you through the contact information you provide. If you refuse to provide contact information, we will not be able to respond to you, and can not deal with your questions and device failure for you. If you do not provide pictures, videos, you may not be able to well illustrate the problem of your feedback.
• Invoked mobile device permissions (Checklist of System Rights Management)

Permission Type	Usage scenario or purpose	Turning on permissions ask(Yes/No)	Is it possible to turn off permissions (Yes/No)	Impact of closure	Mobile OS
Camera	Need to get your camera permission: using the camera within the App, avatar upload/replacement, question feedback	Yes	Yes	Avatar upload/replacement, camera not available when question feedback	Android iOS
Albums	Retrieve your selected pictures/videos from your phone album for picture upload/replacement to avatar and question feedback	Yes	Yes	Unable to read the picture/video information in your phone album to upload to the avatar and problem feedback	Android iOS
Network (Traffic/Wi-Fi)	Mobile traffic/Wi-Fi to connect App and UGREEN smart devices	Yes	Yes	Unable to connect App and UGREEN smart devices	Android iOS
Bluetooth	The phone searches for a nearby UGREEN smart device via Bluetooth and pairs with the device to connect	Yes	Yes	Unable to search and connect to UGREEN smart devices	Android iOS
Storage Space	App reads picture/video information from phone storage space; App writes picture/video information to phone storage space	Yes	Yes	Unable to store, select photo/video information	Android iOS
Location	Works with Bluetooth and Wi-Fi to get a list of Bluetooth devices and Wi-Fi names, as well as for determining the server's region	Yes	Yes	Unable to get the list of Bluetooth devices and Wi-Fi names, unable to correctly determine the user's region to assign to the corresponding server	Android iOS
System Setup	Set Bluetooth and Wi-Fi on status	Yes	Yes	Unable to turn on Bluetooth and Wi-Fi, thus making it impossible to connect to UGREEN smart devices	Android iOS
Update and install applications	Update APP application	Yes	Yes	Unable to update the app, resulting in known app issues that cannot be fixed	Android iOS

Please note that by turning on any of the permissions, you authorize us to collect and use the relevant personal information to provide you with the corresponding services, and by turning off any of the permissions, you cancel your authorization, and we will no longer collect and use the relevant personal information based on the corresponding permissions, nor will we be able to provide you with the services corresponding to the permissions. However, your decision to close the permission will not affect the collection and use of information based on your authorization.

For an itemized list of the relevant business functions that may open your mobile device access rights, please refer to the Checklist of System Rights Management.

（2） Information we collect automatically, purpose of use

• Mobile device information: Inorder to bind UGREEN smart devices and ensure the stability and security of the software system, we will get your phone model, brand, OS version, ROM version and screen resolution. If you refuse to provide it, we will not be able to connect your cell phone to the device and send the device information to your phone.
• Log information: When you use our application, system and exception logs are uploaded, including your IP address, the language used, the version of the operating system, and the date or time of access.

（3） Information about UGREEN smart devices

• Basic information of UGREEN smart devices: When you use UGREEN to connect UGREEN smart devices, we collect basic information about the devices, including device name, device ID, online status, activation time, firmware version and upgrade information, and system language, for the app to connect to the devices, display device usage information, and update and upgrade thedevice firmware. In order to implement pushing device usage information to users, we need to collect device identifiers (IMEI, IDFA, Android ID, MAC, OAID, Advertising ID, Serial Number, IMSI, UAID, ICCID), device platform, and device vendor information. If not collected, users will not be able to receive device usage information.
• Information reported by UGREEN smart devices:We collect information reported by smart devices when you use UGREEN software to connect to the smart devices we serve.
• Device identifier information:UGREEN software is developed based on DCloud uni-app (5+ App/Wap2App), which needs to collect your device identifier (IMEI/android ID/DEVICE_ID/IDFA, SIM card IMSI information, OAID) during application operation to provide statistical analysis service. And UGREEN software improves performance and user experience through application launching data and abnormal error log analysis to provide better service for users.

Please note that separate device information and service log information cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information will be treated as personal information during the period of combined use, and we will anonymize and de-identify such information unless we obtain your authorization or unless otherwise required by law or regulation.

Please refer to the Checklist of Personal Information Collection for an itemized list of the information UGREEN collects and uses about you.

3. Legal basis for processing personal information

The purposes for which we process your information are as follows:

• Services for you: We process your account and profile data, permission information, log information, location information and information related to your smart device, andthe legal basis for such processing is our agreement with you.
• Improving our services: We process your device information, usage data, location information and smart device-related information to ensure the functionality and security of our products, to develop and improve our products and services, to analyze the efficiency of our operations, and to prevent and track fraud or misuse. The legal basis for such processing is the performance of our agreement with you in accordance with our terms of use.
• Non-marketing communications: We process your personal information for the purpose of sending you important information related to services, changes to terms/conditions and policies, and/or other administrative information. At the same time, we may also send you notifications related to the services you use, such as alert services. You can manage whether you request to receive such communications by going to UGREEN's "Message Center - Settings" and when you choose to turn off push notifications, we will not continue to send you such information. The legal basis for such processing is our agreement with you.

4. Exception for prior authorized consent

Please note that your prior authorized consent is not required for the collection and use of personal information in the following cases：

• directly related to national security and national defense security；
• directly related to public safety, public health, and significant public interest；
• directly related to crime investigation, prosecution, trial, and sentence enforcement；
• For the purpose of safeguarding your or other individuals' significant legal rights and interests, such as life and property, but where it is difficult to obtain my consent；
• The personal information collected is disclosed by you to the public at your own discretion；
• Where personal information is collected from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure and other sources；
• necessary to enter into and perform the contract at your request；
• Necessary for maintaining the safe and stable operation of the product or service provided, such as detecting and disposing of malfunctions of the product or service；
• Necessary for the conduct of legitimate journalism；
• Where it is necessary to conduct statistical or academic research in the public interest and where it provides the results of academic research or descriptions to the public by de-identifying the personal information contained in the results；
• Other circumstances specified in laws and regulations.

II. How we share, transfer, and publicly disclose your personal information

1. Who do we share your personal data with?

We will not share your personal information with any company, organization or individual outside of Ugreen Group Limited except as follows：

(1) Sharing with explicit consent: We may share your personal information with other parties after obtaining your explicit consent.

(2) Fulfillment of legal obligations: We may share your personal information to the public in accordance with laws and regulations, or in accordance with mandatory requirements of government authorities.

(3) Sharing with our affiliates: As permitted by law, we may share your information with our affiliates for the purpose of providing you with UGREEN products and services. We will only share personal information that is necessary and is subject to the purposes stated in this Privacy Policy. Affiliates who wish to change the purposes for which personal information is processed will again seek your authorized consent.

(4) Sharing with Authorized Partners: Certain of our services will be provided by authorized partners only to fulfill the purposes stated in this policy. We may share some of your personal information with our partners in order to provide better customer service and experience. We will only share your personal information for purposes that are legal, legitimate, necessary, specific, and explicit, and only as much personal information as is necessary to provide the services. Our partners do not have the right to use the personal information shared for any other purpose. Typically, our partners are:

①Third party service providers: Provide us with application development.

②Third party SDK service provider : In order to ensure the stable operation and function of the application, so that you can use and enjoy more services and functions, we will embed the third party's SDK in the application. This privacy policy only applies to the information we collect from you, not to the products or services provided to you by the third party alone, and we are not responsible for how the third party's products or services collect, use, or process your personal information. We are not responsible for how third party products or services collect, use, or process your personal information. When you use the products or services provided by the third party alone, the third party may collect your personal information; when you use the third party products or services, please also carefully read and fully understand the privacy policy of the products or services provided by the third party; please refer to the valid version provided by the third party when you use the third party products or services. In order to provide you with more services, ensure the stability and quality of services or upgrade the relevant functions, we may need to adjust the third-party SDK/API that we access, and we will update the directory of the third-parties that UGREEN app accesses in a timely manner to explain to you the latest situation involving the third-party SDK so that you can check the third-party data usage rules.

Please refer to the List of Third-Party Information Sharing for the third-party SDKs embedded in the platform and the information to be collected by or shared with the third-party SDKs.

2. Transfer

We will not transfer your personal information to any company, organization or individual unless we have your express consent or, in the event of a merger, acquisition or bankruptcy liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this privacy policy, or we will require that company or organization to seek your authorized consent again.

3. Public Disclosure

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

(1) after obtaining your express consent;

(2) disclosure based on law: We may publicly disclose your personal information if compelled to do so by law, legal process, litigation, or governmental authority.

4. Exception for prior authorized consent

Prior authorized consent of the subject of personal information is not required for the sharing, transfer, or public disclosure of personal information in the following cases:

(1) directly related to national security and national defense security;

(2) directly related to public safety, public health, and significant public interest

(3) directly related to crime investigation, prosecution, trial, and sentence enforcement;

(4) for the purpose of safeguarding the significant legitimate rights and interests of the subject of personal information or other individuals, such as life and property, but where it is difficult to obtain the consent of the individual;

(5) Personal information disclosed to the public by the subject of the personal information itself;

(6) Those that collect personal information from legitimate public disclosures, such as legitimate news reports, government information disclosure and other channels.

III. How you can exercise your rights

1. Rights related to personal data

In accordance with the relevant laws, regulations and standards of, we protect your right to exercise the following rights with respect to your personal information.

(1) Inquiries about your personal information

Approach: Personal Center - Account & Security

For information that cannot be accessed through the above means, you may contact us at any time through the contact information in Article 9 of this policy, and we will respond to your request for access within 15 business days of verifying your identity information.

(2) Correction of your personal account information

Approach: Personal Center-Account & Security (you can edit your avatar, nickname, gender, modify your personality signature, change your password and gesture password)

For information that cannot be corrected through the above means, you may contact us at any time through the contact information in Section 9 of this policy and we will respond to your request for correction within 15 business days of verifying your identifying information.

(3) Change the scope of your authorized consent or withdraw your authorization

The approach to change the authorization scope of related functions: Personal Center - Privacy Permissions Settings.

When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization. If you encounter operational problems during this process, you may contact us at any time via the contact information in Article 9 of this policy.

(4) Deletion of your personal information

You can delete it yourself by going to: Personal Center - Account & Security.

If we have processed your personal information in violation of laws and regulations, or we collected or used your personal information without your consent, or you no longer use our products or services canceled account, you need to delete personal information, you can submit a request to delete your personal information to us through the contact information in Article 9 of this policy, we will respond to your deletion request within 15 business days. When your information is executed deleted, we will no longer use the data, but may not be able to delete it immediately in order to accommodate the necessary relevant legal policy requirements or to protect the integrity of the data necessary for the normal operation of the service, store or backup it for the necessary period of time, but delete it in a timely manner after that period of time.

(5) Cancellation of your account

You can cancel your account at any time. Once you cancel your UGREEN software account, you will not be able to use the services of UGREEN remote monitoring and operating smart devices, and we will delete or anonymize your personal information as required by applicable laws, and the relevant data will not be recoverable, so please proceed with caution!

Cancellation approach: Personal Center-Account & Security-Cancel Account

If you are authorized to log in to the UGREEN software platform through a third party account (QQ/ Wechat/ Facebook/ Apple ID), you will need to apply to the third party to cancel your account. However, you can also contact us through the contact information in Article 9 of this policy and we will respond to your cancellation request by deleting the personal information under the account associated with your registered cell phone number within 15 business days after verifying your identity information.

(6) Access to copies of personal information by subjects of personal information

You have the right to obtain a copy of your personal information by sending a request to cnfw@ugreen.com.

When an individual user logs out, the system may delete personal information and we will not be able to provide a complete copy of personal information.

(7) Constraint information system automatic decision making

In some business functions, we may make decisions based solely on non-human automated decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legal rights, you have the right to an explanation. If these decisions significantly affect your legal rights, you have the right to seek an explanation from us and we will provide appropriate remedies.

(8) Processing restrictions

In some cases, you have the right to ask us to stop processing your personal information and only store such information. However, we may process your personal information if we have a legitimate reason to do so (for example, to defend a legitimate claim or to protect others).

If we agree to stop processing personal information, then we will take reasonable steps to do so. Please inform any third party to whom we have disclosed the relevant personal information so that they may also cease processing it.

You may request that we stop processing the personal information we hold about you and only store it if.

• You believe that personal information is inaccurate and that the data whose accuracy is in doubt may lead to a loss of the data subject's own interests.
• The processing of data by us, and the purposes for which the data are processed, is deemed unlawful by official authorities such as the courts (you want us to retain personal information in storage form only); or
• We no longer need the personal data for the purposes of the data processing activities, but at this time you have a legal claim, and in order to bring, exercise or defend that legal claim, you have the right to exercise the right to restrict processing against the data controller in order to ensure that the data subject's legal claim can be successfully pursued.

(9) Respond to your request above

For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before we process your request. We will respond within 15 business days. (However, this may be extended for an additional two months in certain circumstances, such as when the request involves a large amount of information or a complex situation)

In principle, we do not charge a fee for your reasonable requests. We may refuse requests that are unwarrantedly repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical (for example, involving the backup of information stored on tapes).

If you are a user located in one of the following countries: Australia, Japan, the United Arab Emirates, the Kingdom of Saudi Arabia, the United Kingdom or the State of California in the United States, the terms set forth under your jurisdiction at Supplementary Terms apply to you in addition to the terms set forth in our Privacy Policy.

2. In the following cases, we will not be able to respond to your requests for correction or deletion of information in accordance with the requirements of laws and regulations:

(1) directly related to national security and national defense security;

(2) directly related to public safety, public health, and significant public interest;

(3) directly related to the investigation, prosecution, trial, and enforcement of sentences for crimes;

(4) Where we have sufficient evidence of subjective malice or abuse of your rights (e.g. where your request would endanger public safety and the legitimate rights and interests of others, or where your request is beyond what can be covered by ordinary technical means and commercial costs);

(5) When responding to a request from a subject of personal information will result in serious damage to the legitimate rights and interests of you or other individuals or organizations;

(6) involving trade secrets.

IV. Safety and security measures

1. In terms of data security collection, we confirm the legality, legitimacy and necessity of data collection through personal information security impact assessment, identify and inform you in a clear and accurate manner to obtain consent, and at the same time make log records of your authorized consent collection; adopt technical measures to identify the source party collecting or generating data to ensure the accuracy and resistance to denial of data sources.
2. In terms of data security transmission, personal information is transmitted using secure channels and is securely encrypted and desensitized by suitable encryption algorithms to ensure the confidentiality and integrity of personal information during data transmission.
3. In terms of data security storage, a data classification and grading management system is adopted, and different information storage strategies are adopted in response to the results of data classification and grading; sensitive personal information needs to be stored encrypted to ensure that data security usage norms can be implemented; authority control is strengthened for databases storing personal information; regular backup and restoration of personal information is performed to ensure the integrity of personal information in the process of storage and usage.
4. In terms of data security destruction, the minimum available period of personal information storage is set according to the requirements of laws and regulations and the actual needs of the business, and the expired data is processed through security deletion technology to ensure that the destroyed data cannot be recovered, and the technical means include but are not limited to complete data erasure program, disk destruction, physical destruction, etc.
5. In the unfortunate event of a personal information leakage security incident, we will, in accordance with the requirements of laws and regulations, promptly 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 the risk, and the remedial measures for you. We will promptly inform you of the event-related situation in one or more ways, such as email, telephone, SMS, push notifications, letters, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to issue announcements. At the same time, we will also take the initiative to report the disposition of personal information security incidents in accordance with the requirements of the regulatory authorities.
6. The Internet is not an absolutely secure environment, and even if we do our best to strengthen security measures, we cannot always guarantee the absolute security of information. Please understand that your use of our products and services may be subject to malicious attacks that result in security problems beyond our control, etc.
7. Your cooperation

Although we have taken reasonable and effective measures as described above and have complied with the standards required by relevant laws and regulations, we still cannot guarantee the security of your personal information when communicating through unsecured means. Therefore, you should take active measures to ensure the security of your personal information, such as: setting complex passwords, changing your account password regularly, and not disclosing your account password information to others to help us keep your account and personal information secure. If you discover that your personal information has been compromised, especially your account or password, please contact us immediately using the contact information provided at the end of this Privacy Policy so that we can take appropriate measures to protect the security of your information.

V. Data retention period

During your use of the Service, we will continue to store your personal information for you. If you need to delete your personal information, you can contact us through the contact information in Article 9 of this policy. In addition, we will delete or anonymize your personal information after the above retention period, except as expressly provided by law or regulation. If we are unable to destroy the data for technical reasons, we will take appropriate measures to prevent further use of your personal data.

VI. Protection of personal information of minors

Ltd. attaches great importance to the protection of children's (or minors') personal information. If you are under the age of 16 (or the age of majority according to the user's local laws ), you must obtain the prior written consent of your parents or legal guardians before using our services. Ltd. protects the personal information of children in accordance with the relevant laws and regulations of each region, country or area. Please note that if we discover that we have collected personal information from a child without the prior consent of a verifiable parent or legal guardian, we will attempt to delete the relevant personal information as soon as possible. If a guardian has reason to believe that we have collected personal information from a minor without the guardian's consent, please contact us through the contact information in Article 9 of this Policy and we will delete the relevant data as soon as possible upon your request.

VII. How your personal information is transferred globally

In 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. Because we provide our products or services through resources and servers located around the world, this means that your personal information may be transferred to, or accessed from, jurisdictions outside the country where you use the product or service, with your expressly authorized consent. Such jurisdictions may have different data protection laws or even no such laws. In such cases, we will ensure that your personal information is adequately protected to the same extent as it is in the People's Republic of China. For example, we may request your consent for cross-border transfers of personal information or implement security measures such as data de-identification prior to cross-border data transfers. Data transfers to users in the EU will be in accordance with the European Commission's model contract for the transfer of personal data to third countries.

VIII. Statement on Policy Changes

We may make changes to this policy from time to time. We will not reduce your rights under this policy without your express consent. We will post any changes to this policy on this page. For material changes, we will notify you by pop-up information, email, etc., and ask for your consent again.

Material changes referred to this policy include, but are not limited to:

1. significant changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used;
2. significant changes in our ownership structure, organizational structure, etc. such as changes in ownership due to business restructuring, bankruptcy and mergers, etc.;
3. changes in the primary recipients of personal information sharing, transfer or public disclosure;
4. significant changes in your rights to participate in the processing of personal information and in the manner in which it takes place;
5. in the event of a change in the department responsible for handling the security of personal information, our contact information and complaint channels;
6. when the personal information security impact assessment report indicates a high risk.

By continuing to use the Service after we update this Policy, you agree to the contents of this Policy (including the updated version) and consent to our collection, use, retention, disclosure, and transfer of information about you in accordance with this Policy.

IX. Contact Us

1. We have established a dedicated personal information protection team and person in charge. If you have any questions, comments or suggestions regarding this policy or our services, you can contact us:

(1) You can contact us through the "Feedback" on the UGREEN app, approach: Settings - Help Center - Feedback.

(2) Send an e-mail to the person in charge of personal information protection: Name of the person in charge (legal representative) : ; cnfw@ugreen.com (contact e-mail).

(3) Send your letter as follows：

Address: Block 7, YuAn Zone, Longcheng Industrial Park, No.39, Longguan West Road, Dalang Street, Longhua, Shenzhen, China

Tel: 0755-28066995

Zip code: 518000

(4) We can be contacted by telephone ：

Tel: 0755-28066995

2. In order to ensure that we handle your problem efficiently and provide you with timely feedback, we need you to submit proof of identity, valid contact information, written request and relevant evidence, and we will process your request within 15 business days after verifying your identity.
3. If you are not satisfied with our response, especially if you believe that our personal information processing practices have harmed your legitimate rights and interests, you may first negotiate with us, and if you are not satisfied with the results of the negotiation, you may also seek a solution by filing a lawsuit with a court of competent jurisdiction in Longhua District, Shenzhen. Please note that if you are a resident of EEA, UK, you have the right to lodge a complaint with the data protection authority of your country.