# Personal Information & Privacy Policy of
Uni-Ubi

Update date: October 18 , 2024

Effective date: October 21 , 2024

# Preface

Hangzhou UniUbi AI Co., Ltd. and its affiliates (hereinafter referred to as "we" or "UniUbi") respect and are committed to protecting personal information and privacy. Therefore, we have formulated this Personal Information and Privacy Protection Policy (hereinafter referred to as "this Policy"), which introduces our basic information, data protection principles and other overall information related to personal information processing.

This policy is intended to serve as an overall overview of our personal information and privacy protection, in order to declare our unified requirements and standards in the field of personal information processing. To avoid ambiguity, this policy does not fully include all information about our processing of personal information for specific purposes in specific product or service scenarios; for specific personal information processing practices in specific product or service scenarios, please also read the privacy policy or similar legal text applicable to such scenarios, provided by our customers (hereinafter referred to as "customers") or we separately to individual end users (hereinafter referred to as "users" or "you"). In addition, this policy applies only to UniUbi and is completely independent of the privacy policy or similar legal text that our customers or any third party may or need to display or provide to you.

This policy is intended to help customers and users understand the following:

Important Notes
Our personal information and privacy protection principles
How we collect and use your personal information
How we share, transfer and publicly disclose your personal information
How we store and protect your personal information
How we transfer your personal information globally
Your rights regarding your personal information
How we handle children’s personal information
How this Policy is Updated
How to contact us

In this policy, "personal information" refers to various information recorded electronically or otherwise that can identify or relate to a specific natural person, or reflect the activities of a specific natural person, alone or in combination with other information. Unless otherwise specified, other relevant definitions and terms under this policy have the same meanings as in laws, regulations, normative documents, and national standards such as the Personal Information Protection Law, the Data Security Law, the Cybersecurity Law, and the Information Security Technology - Personal Information Security Specification.

# text

# 1. Important Notes

When you use any platform or software service of UniUbi (including but not limited to UniUbi's official website, various application software, open platform, code and related technical services) or other UniUbi related terminal devices, it means that you agree to the terms of this policy.

You know and agree that in order to implement the necessary business processes, you need to provide relevant personal information, and we will also collect some necessary information. If you do not agree to provide this part of the necessary information, we will not be able to provide you with services. In order to achieve the purpose of the service, the aforementioned information (including videos, images and personal identity information that may contain personal sensitive information) may be independently stored on the server side of UniUbi's specific products due to the needs of specific business scenarios. You agree that we can access and analyze the information you provide to assist in maintaining the personal and property safety of your application scenarios, provide you with more objective data analysis results with reference value for your management or business decisions, and continuously improve the core functions of this service. Without your authorization, we will not disclose, modify or illegally use the above information.

You confirm that you have the right to provide us with relevant information and promise that the information you provide to us is true and legal. If you are not the owner of the relevant information, you should confirm that you have obtained the explicit consent of the relevant rights holder before providing us with the information, and there are no such rights disputes or potential disputes between you and the relevant rights holder. For us, your provision of information is deemed to have obtained the full legal authorization and explicit consent of the relevant rights holder.

If the relevant rights holder raises an objection to us in accordance with the law, we will take necessary measures such as deletion, blocking, disconnection, interruption or termination of service in accordance with the law. Our taking of the aforementioned measures in accordance with the law does not constitute a breach of contract with you, and we do not bear any liability for breach of contract. We will notify you in a timely manner after taking necessary measures. You shall be responsible for communicating and resolving the objection with the rights holder who raised the objection and bear all responsibilities. At the same time, we respect the communication solution reached between you and the relevant parties and can continue to provide you with services in accordance with the solution.

You understand and agree that, as a neutral service and technology provider, we do not assume any other liability beyond that required by law.

# 2. Our Personal Information and Privacy Protection Principles

In our practice of handling personal information, we always adhere to the following principles:

Legal and legitimate

We guarantee to comply with the provisions of the Personal Information Protection Law, Data Security Law, Cybersecurity Law, Civil Code and other applicable laws and regulations and relevant normative documents, and will not use personal information to engage in any illegal activities; We respect and promise to protect the relevant rights of personal information subjects in accordance with applicable laws and regulations.

Safe and controllable

We will take appropriate technical and management measures to protect personal information from risks such as loss, unauthorized access, damage, alteration or public disclosure;

We have set up a dedicated management department and management personnel to design and implement a strict authority control system to strictly control the number and scope of personnel who can access personal information and reduce the risk of data leakage;

Based on the data classification and grading system, we have taken appropriate measures to ensure the accuracy, completeness, availability and timeliness of personal information.

Transparency is necessary

We promise to process only personal information strictly necessary for specific purposes in the implementation of business functions;

We promise to retain personal information only for the period necessary to achieve the purpose of processing, unless the retention period needs to be extended in accordance with mandatory laws, regulations or regulatory requirements;

We promise to strictly process data in a manner that minimizes the impact on the rights of personal information subjects.

Accountability and Correction

We promise to use appropriate and feasible technical and management measures to ensure that the processing of personal information is auditable, accountable, and correctable;

We have established a reasonable and effective employee information security rules system internally, and have also set up relevant regulations on information security rewards and punishments to ensure the implementation of relevant responsibilities.

“Default Compliance” in Product Design

We promise to coordinate and integrate multiple considerations such as product design, technical security, and legal compliance, and promote product research and development and design with the concept of default compliance in all aspects of product and/or service development to ensure that the "design privacy" principle is followed in product design.

# 3. How we collect and use your personal information

Collection and use of necessary personal information

We will follow the principles of legitimacy, legality and necessity, and for the following purposes described in this policy, collect and use your personal information that you actively provide during the use of our products and/or services, or that we directly collect from you when you use our products and/or services, as well as your personal information provided to us by third-party partners authorized by you. If we want to use your personal information for other purposes not specified in this policy, or use the collected information for other purposes based on specific purposes, we will inform you in a reasonable manner and obtain your consent again. In order to provide you with the extended business functions of our products and/or services, you can choose to authorize us to collect and use your information. If you refuse to provide it, you will not be able to use the relevant extended business functions normally or achieve the functional effects we intend to achieve, but it will not affect your normal use of the basic business functions of our products and/or services. When you use our products and/or services, we need/may need to collect and use your personal information in the following scenarios:

1.1 Information browsing

When you visit our official website, in order to better provide you with products or services, continuously improve our products and services, and optimize and enrich your user experience, our website server will automatically record the browser you use, the name of your Internet Service Provider, the URL you visit when you visit our website, the web pages you visit, and the date and duration of your visit.

1.2 Business Cooperation

1.2.1 Channel Cooperation

If you wish to become a channel partner of UniUbi , you can fill in the basic information of you and your company on the channel cooperation page (including your name, mobile phone number, email address, your position in the company, the name of your company, the location of your company, the company's establishment time, the number of employees in the company, the company type, the company's business, the industry you intend to cooperate with, the area you intend to cooperate with and your specific business needs). We will contact you in a timely manner after receiving your information to further communicate on cooperation matters.

1.2.2 Supplier Cooperation

If you wish to become a supplier of UniUbi , you can fill in the supplier self-recommendation form, which includes contact information (sales manager, phone/fax, email address, you can choose to fill in the information of the company manager, quality manager, and technical manager), company information (company name, company address, registered capital, establishment time, nature of the company, total number of employees and personnel composition, annual turnover, you can choose to fill in the company tax number, bank account, account number, company website), product information and business license, product catalog, certification certificate and other relevant information.

1.2.3 Business Consulting

If you want to learn more about our products or services, you can fill in the basic information of you and your company (including your name, mobile phone number, email address, company name, intended city, initial requirements) on the customization requirements page. We will contact you in time after receiving your information to further discuss cooperation matters.

Please note that since the information you submit involves information about your company and other contact information of your company, please ensure that you have obtained full authorization from your company and relevant contacts before submitting the relevant company information and company contact information.

1.3 Function Trial

If you try the "face recognition" function displayed on the UniUbi official website (such as face detection, face comparison, and ID card comparison), you can upload pictures containing facial information on the trial page. Please note that facial pictures are sensitive personal information. Please do not upload pictures of people other than the trial user or pictures of others without the explicit authorization and consent of the information subject. We will delete the personal information including facial information you submitted in a timely manner after your trial ends, or anonymize the personal information.

2、Product or service integration into developer product

When you, as a developer, integrate UniUbi 's products or services into your products , you understand and agree that, based on providing products or services to you and/or your end users , you need to process the personal information of the end users of your integrated products through UniUbi . Please confirm that you have disclosed and explained to the end users and have obtained sufficient and necessary authorization, consent and permission from the end users to allow UniUbi 's products or services to collect, store, process, use and share the necessary personal information of the end users. If your product is designed and developed for children under the age of fourteen, you should have taken necessary technical measures to ensure that you have obtained the authorization, consent and permission of their guardians. For details, please refer to the " UniUbi Open Platform Privacy Protection Policy ".

Special statement about cookies

Cookies are small files that are transmitted and stored on your device by websites, applications or services. To personalize your online experience and make your visit easier, UniUbi Smart 's websites, online services, applications, emails and advertisements may use cookies and other similar technologies, such as pixel tags and web beacons. We use cookies like most websites on the Internet, and we cannot access cookies that are not set by UniUbi Smart . The time that cookies are stored on your hardware device depends on your device settings.

If your browser has enabled cookie settings and preferences such as Do Not Track, all UniUbi websites will respect your choice. Managing cookies and cookie preferences must be done in your browser's options/preferences.

(I) Sharing

We may share your personal information in the following circumstances.

Obtain your explicit consent or authorization for sharing.
Based on statutory circumstances, such as according to the provisions of laws and regulations, administrative, judicial and other competent authorities shall make requests and issue relevant procedures in accordance with the law.
Sharing with affiliated companies: In order to provide you with consistent services, we may share necessary personal information with our affiliated companies.

Please be aware that we will only share your personal information for legal, legitimate, necessary, specific and clear purposes. For companies, organizations and individuals with whom we share personal information for the sole purpose of achieving the purposes stated in this Privacy Policy, we will sign strict information protection and confidentiality agreements with them and require them to abide by the agreements and take relevant security measures to protect your personal information.

(II) Transfer

When selling, transferring or merging part of our business or assets , if it involves the transfer of personal information, we will require the company or organization that receives your personal information to continue to be bound by this Privacy Policy and to continue to process and protect your personal information in accordance with the same standards described in this policy. Otherwise, we will require the company or organization to re-solicit your authorization and consent .

(III) Disclosure

We may only disclose your personal information in the following circumstances and only if we take security measures that meet industry standards:

Disclose the personal information you specify in accordance with your needs and in the manner you explicitly agree to;
According to the provisions of laws and regulations, we may disclose personal information based on the corresponding type of personal information and disclosure method when administrative, judicial and other competent authorities make requests in accordance with the law. Under the premise of complying with the provisions of laws and regulations, when we receive the above-mentioned request for disclosure of information, we will require the production of corresponding legal documents, such as subpoenas or investigation letters.

# 5. How we store and protect your personal information

(I) Storage of Personal Information

Storage period: Unless otherwise provided by laws and regulations or agreed upon by both parties, we will only retain your relevant personal information for the shortest period necessary to achieve the purpose . We mainly refer to the following standards to determine the storage period of personal information and the longer one shall prevail:

(1) Ensure the safety and quality of the services we provide to you;

(2) Whether you agree to a longer retention period;

(3) Whether there are other special agreements or legal provisions regarding the retention period.

After the storage period expires, your personal information will be deleted or anonymized.

Storage location: Personal information we collect within the territory of the People's Republic of China will be stored within China. If we need to transfer your personal information overseas, we will complete the corresponding procedures in accordance with the requirements of relevant laws and regulations. We will also require the data recipient to process personal information in accordance with this Privacy Policy and other relevant security and confidentiality measures to provide your personal information with protection standards no less than those stipulated by Chinese data protection laws and regulations.
Termination of operation: If termination of operation occurs, we will notify you at least 30 days in advance and delete or anonymize your personal information after termination of operation.

(II) Personal Information Protection Measures

We have completed the cybersecurity level protection filing for our business systems in accordance with Chinese laws and regulations, and have adopted security measures that meet industry standards (including but not limited to encryption, desensitization, and permission management) to protect the personal information you provide. We have obtained ISO 27001 certification. However, please note that although we have taken reasonable technical and management measures to protect your personal information, no website, Internet transmission, computer system, or wireless connection is absolutely secure.

Once a personal information security incident unfortunately occurs, we will immediately set up a special emergency response team and launch an emergency response plan to prevent the security incident from expanding, and promptly inform you of the following related matters in accordance with the provisions of laws and regulations: the basic situation of the security incident and the possible impact, the disposal measures we have taken or will take, your suggestions for self-prevention and risk reduction, and your remedial measures. We will promptly inform you of the relevant situation of the incident by email, letter, phone, push notification, etc. When it is difficult to inform the personal information subject one by one, we will take reasonable and effective ways to issue an announcement. At the same time, we will also proactively report the disposal of personal information security incidents in accordance with the requirements of the regulatory authorities.

# 6. How we transfer your personal information globally

Due to the requirements of Chinese laws and regulations, in principle, all personal information we collect and generate in China will be stored in China.

If it is necessary to provide your personal information outside the People's Republic of China, we will inform you in advance of the name or name of the overseas recipient, contact information, processing purpose, processing method, type of personal information, and the way and procedure for you to exercise the rights stipulated in this Law to the overseas recipient, and obtain your separate consent. At the same time, we will also conduct relevant security assessments before your personal information is transferred across borders in accordance with the requirements of laws and regulations.

# 7. Your rights regarding your personal information

We highly respect your rights to personal information under the law. Please note that in specific product or service scenarios, we recommend that you make a request directly to the personal information controller in the specific business scenario (usually our customers or developers), who will forward it to us as appropriate. For security reasons, we may need to verify your identity before processing your request.

If you really need it, you can also contact us by sending an email to service@uni-ubi.com. To ensure that your request is clear and specific, please provide the following in the aforementioned email:

Your name and contact details;
Your detailed request, comments and/or corresponding links.

In principle, we do not charge any fees for your reasonable requests. However, for repeated requests that exceed reasonable limits, we will charge certain costs within legal limits or may reject them.

Generally speaking, we will respond as soon as possible within the time limit prescribed by laws and regulations, except in the following circumstances:

Related to the performance of obligations prescribed by laws and regulations;
Directly related to national security and national defense security;
Directly related to public safety, public health, and major public interests;
Directly related to criminal investigation, prosecution, trial and execution of judgment;
There is sufficient evidence that you may have subjective malice or abuse of rights;
To protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to obtain their authorization and consent;
Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
Involving trade secrets.

Please note that all personal information you provide when using our products and/or services will continue to be authorized for us to use during your use of our products and/or services, unless you withdraw your consent.

We protect your right to know and right to choose during the installation or use process in accordance with the law, and do our best to protect your right to authorize, delete and withdraw consent to personal information, so as to fully protect your privacy and information security. You can change the scope of your authorization for us to collect personal information or withdraw your consent by deleting information, turning off device functions, system settings, etc. You can also withdraw all authorizations for us to continue to collect and process your personal information by canceling your account.

Please understand that each business function requires some basic personal information to be completed. Once you withdraw your consent or authorization, we will no longer be able to provide you with the services corresponding to the withdrawal of consent or authorization, and will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the processing of personal information previously carried out based on your authorization.

# 8. How we handle children’s personal information

Please note that all of our products, websites and services are mainly for corporate customers, and we usually do not actively collect or process children's personal information. If any customer or user wishes or intends to provide us with or request us to process children's personal information, please strictly follow the requirements of relevant laws and regulations to ensure that the prior express consent of the child's guardian has been obtained. In the case of collecting children's personal information with the consent of their parents or guardians, we will only use or disclose this information when permitted by law, with the explicit consent of their parents or guardians, or when necessary to protect children. For the avoidance of doubt, we will regard anyone under the age of 14 as a child.

You can obtain more detailed information in the "Rules for Processing Personal Information of Minors" we provide.

# 9. How this Policy is Updated

We reserve the right to update or modify this policy from time to time. However, we will not reduce your rights under this policy without your explicit consent. You can view the latest version of this policy through this page.

For major changes, we will provide more prominent notices (including for some services, we will send notices via email to explain the specific changes). The aforementioned "major changes" include but are not limited to:

Significant changes to our service model. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;
We have undergone significant changes in our ownership structure, organizational structure and other aspects. Such as changes in owners caused by business adjustments, bankruptcy mergers, etc.;
The main recipients of personal information sharing, transfer or public disclosure change;
There are significant changes in your rights to participate in the processing of personal information and how to exercise them;
When our responsible department for handling personal information security, contact information and complaint channels change;
When the personal information security impact assessment report indicates that there is a high risk.

# 10. How to contact us

If you have any questions or concerns about how we use your personal information or this Privacy Policy, especially if you believe that our processing of personal information has harmed your legal rights and interests, you can contact us in the following ways and we will respond to your request within 15 working days from the date of receipt of your feedback:

You can contact us through the online customer service on the Uni- ubi website or our customer service hotline (4000686857)/customer service email (service@uni-ubi.com) .

# Personal Information & Privacy Policy of Uni-Ubi