Last modified: September 2023

CHINT Group Limited ("CHINT Group" or "we") fully recognizes the importance of your personal information and is committed to protecting the security and reliability of your personal data. This Privacy Policy (hereinafter referred to as "this policy") applies to CHINT Group products and services that display or link to this privacy policy.Through this policy, we will explain the purposes, methods, and scope of how our products and services collect and use your personal information, your rights regarding your personal information, and the security measures we take to protect your information.

This policy details how we collect, use, store, share, and transfer your personal information, as well as how we provide you with access to, update, delete, and protect your personal information. However, this policy may not cover all possible data processing scenarios.Information about the collection of specific product or service data may be detailed in a specific privacy notice or supplementary statement issued by CHINT Group for a particular product or service, or in a notice provided at the time of data collection.

Before using our products or services, please read this policy carefully to understand our practices regarding the protection of customer personal information.

This privacy policy helps you understand the following aspects:

1. The personal information we process 

2. The purposes and basis for processing personal information 

3. How we store your personal information

4. How we delegate processing, share, transfer, and publicly disclose your personal information

5. How we protect your personal information

6. Your rights regarding your personal information

7. How we protect the personal information of minors

8. How we use cookies and similar technologies

9. Third-party service providers and their services

10. How your personal information is transferred across borders

11. How this policy is updated

12. How to contact us

I. The personal information we process

Personal information refers to various pieces of information related to an identified or identifiable natural person, recorded electronically or otherwise, excluding anonymized information. Personal information is collected directly or indirectly when you use our products, services, or website, or interact with us.In accordance with legal and regulatory requirements, we follow the principles of legality, legitimacy, necessity, and integrity. We only collect personal information necessary for the functionality of our products and use the collected information solely for explicit purposes.The main types of personal information we process include:

1. Information you actively provide when using our products or services:

(1) Information such as nicknames, mobile numbers, and email addresses that you actively fill in or upload when registering or using our products or services

;

(2) Information such as your name, phone number, email, product details, and fault descriptions submitted when you use our customer service or after-sales service

;

Some specific services may require you to provide specific personal information to carry out related functions. If you

choose not to provide such information, it will not affect the use of other functions in our products or services.

2. Information collected during your use of our products or services

: To ensure the security of our products, services, and user accounts, to provide better products and services, and to improve user experience, we collect certain information about your device and how you and your device interact with our products and services during your use (including use through an enterprise/institution account). This includes:

(1) Device Information: Such as device attribute information (e.g., your hardware model, operating system version, device settings, unique device identifiers, International Mobile Equipment Identity (IMEI), network device hardware address (MAC), advertising identifiers (IDFA)); device location information (obtained through GPS, Bluetooth, or WiFi signals); device connection information (type of browser, telecommunications operator, language used); and device status information (e.g., sensor data from the device, a list of installed applications). We may associate the information collected from your various devices to provide you with consistent services across these devices.We may link your device information or phone number with your service account.

(2) Log Information and Activity Records: This section includes data on how you interact with our products or services, such as your account login activities (including password changes, updates to linked phone numbers and email addresses, and filing complaints). It also covers the search terms you input, software event logs (like restarts, upgrades, errors, and crashes), IP address, URLs visited, browser type and language settings, and information regarding the downloading, installation, or use of our mobile apps and software. Additionally, it includes details on your communications through messaging software, as well as the dates, times, duration, and browsing activities associated with service access.

(3) Subscription and Personalized Services: Upon your explicit consent to subscribe to our services, we collect relevant information to provide personalized products or services. This includes sending advertisements, promotional messages, brand information, or surveys via email, SMS, phone calls, or other methods. If you do not wish to receive such information, you can unsubscribe by contacting us at services@chint.com, and we will promptly cease sending personalized information to you.

(4) Collection of Additional Information: To help you better use our products or services, with your explicit consent, we may collect additional relevant information. For example, when you activate certain personalized products or services, we also use the information collection features of our products or website to record some personal information when you access related CHINT Group products or services, in order to provide these personalized products or services. If you do not provide this type of information, you may not be able to properly use our related personalized products or services.

3. Information from third parties

In accordance with legal permissions and based on your authorization, to provide you with optimized services and meet your personalized needs, we may receive your personal information or other information from our affiliates or partners (such as third-party media agencies, market research firms, and advertising service providers).

To provide our recruitment services, you may need to upload your resume to the third-party MOKA recruitment platform, and we will receive your resume information from this third-party platform.

II. The purposes and basis for processing personal information

1. CHINT Group processes your personal information for specific purposes and only processes personal information that is specifically related to achieving these purposes. Based on our relationship with you and the products and services we provide, we may use your personal information for the following purposes:

(1) To provide you with products and services;

(2) To meet your personalized needs;

(3) To invite you to participate in surveys about our services;

(4) To improve our services for a better user experience;

(5) For other purposes with your consent.

According to relevant laws and regulations, we may collect and process your personal information without seeking your consent in the following circumstances:

(1) Necessary for us to fulfill legal obligations or statutory duties;

(2) Necessary for the establishment or fulfillment of a contract in which you are a party;

(3) Necessary to respond to public health emergencies or to protect the life, health, and property of natural persons in emergency situations;

(4) Legally processing your publicly disclosed or otherwise legally disclosed personal information within a reasonable scope;

(5) Other circumstances as stipulated by laws and regulations.

III. How we store your personal information

The retention period for the personal information we collect is the minimum necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required by law. Once the above retention period has expired, we will delete or anonymize your personal information.

If we discontinue some or all of our products or services for special reasons, we will promptly inform you and cease the collection and processing of personal information related to those products or services. We will also delete or anonymize any personal information we hold that is related to the discontinued product or service, unless otherwise stipulated by law.

IV. How we delegate processing, share, transfer, and publicly disclose your personal information

1. Delegated Processing

Certain specific modules or functions within this business service are provided by external vendors. For example, we hire service providers to assist us with customer support.

For companies, organizations, and individuals to whom we delegate the processing of personal information, we sign strict confidentiality agreements with them. We require them to process personal information in accordance with our instructions, this privacy policy, and any other relevant confidentiality and security measures.

2. Sharing

If necessary for business purposes, we may share your personal information within CHINT Group to provide you with timely services. We will not share your personal information with any companies, organizations, or individuals outside of CHINT Group and its affiliated companies, unless we have your explicit consent. However, there are exceptions:

(1) Necessary for us to fulfill legal obligations or statutory duties;

(2) Necessary for the establishment or fulfillment of a contract in which you are a party;

(3) Necessary to respond to public health emergencies or to protect the life, health, and property of individuals in emergency situations.

We may share the minimum necessary information with authorized business partners to provide you with services. We require them to strictly adhere to our data privacy protection measures and requirements to safeguard your privacy. If an authorized partner uses your information for purposes not commissioned by us, they will seek your consent separately.

3. Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following cases:

(1) Transfer upon obtaining explicit consent: After obtaining your explicit consent, we may transfer your personal information to others;

(2)  In the case of mergers, acquisitions, or bankruptcy liquidation involving the transfer of personal information, we will require the new entity that holds your personal information to continue to be bound by this privacy policy, or we will require the company or organization to seek your authorization again.

4. Public Disclosure

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

(1) After obtaining your explicit consent;

(2) Based on legal disclosure: We may publicly disclose your personal information in accordance with laws, legal procedures, litigation, or mandatory requirements from governmental authorities.

V. How we protect your personal information

a. How we protect your personal information

We have implemented reasonable and feasible technical and organizational measures to protect the information collected in relation to the services. We have employed security measures that meet industry standards to protect your personal information provided, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data.

We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We will retain your personal information only for the duration necessary to fulfill the purposes described in this policy unless an extension of the retention period is required or permitted by law.

2. Notification and Response to Personal Information Security Incidents

Please note that while we have taken reasonable measures to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure. In the event of a personal information security breach, we will notify you in accordance with applicable laws and regulations. You will receive prompt information about: the nature and possible consequences of the breach, the measures we have implemented or plan to implement in response, recommendations for actions you can take to mitigate risks, and the remedies available to you.We will promptly inform you of the incident details through emails, letters, phone calls, or push notifications.If it is difficult to inform individuals one by one, we will issue announcements in a reasonable and effective manner.At the same time, we will report the handling of personal information security incidents as required by regulatory authorities.

3. The internet environment is not 100% secure, but we strive to ensure or guarantee the security of any information you send to us. If our physical, technical, or administrative protective facilities are compromised, resulting in unauthorized access, public disclosure, alteration, or destruction of information that damages your legal rights, we will bear the corresponding legal responsibility.

4. In the unfortunate event of a personal information security breach, we will notify you in accordance with applicable laws and regulations. You will receive prompt information about: the nature and possible consequences of the breach, the measures we have implemented or plan to implement in response, recommendations for actions you can take to mitigate risks, and the remedies available to you. We will notify you of the incident details promptly via email, letter, telephone, or push notifications. If it is difficult to inform each individual directly, we will announce it in a reasonable and effective manner.

We will also proactively report the handling of the personal information security incident as required by regulatory authorities.

VI. Your Rights Regarding Your Personal Information

We respect your rights concerning your personal information. The following lists the rights you are legally entitled to, which may vary by country or region:

(1) Right to be informed. You have the right to know how your personal information is processed and to access the personal information we hold about you;

(2) Right to refuse. You have the right to refuse or restrict the processing of your personal information in certain situations.Please note that even if you request to refuse or restrict our processing of your personal information, we may still be obligated to continue processing it as required by law, thereby denying your request;

(3) Right to rectification. You have the right to correct incomplete or inaccurate information we hold about you;

(4) Right to access and copy. You have the right to access and copy your personal information;

(5) Right to deletion. You have the right to delete your personal information.Please note that even if you request the deletion of your personal information, we are obliged to retain certain information if required by law;

(6) Right to account cancellation. We provide an account cancellation service. You can choose to email us to cancel your account (services@chint.com).After you choose to cancel your account, we will delete or anonymize all your related personal information in a timely manner as required by law and regulations, except where other legal regulations stipulate otherwise.After cancellation, we will no longer be able to provide you with account login and related products and services.

(7) Right to complain. If you have any objections to our handling of personal information activities and this privacy policy, you have the right to complain to the relevant regulatory authorities.The way you exercise your rights may vary depending on the specific products or services you use.Additionally, you can directly contact the company's Compliance Department or Data Compliance Officer by email (compliance@chint.com; ylyang@chint.com). We will ensure the security of your personal information throughout the process of exercising your rights.

For reasonable requests, we generally do not charge a fee. However, for requests that are repetitive or beyond a reasonable limit, we may charge a cost-based fee depending on the situation. For requests that are unnecessarily repetitive, require excessive technical measures (such as needing to develop new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are highly impractical (such as involving information stored on backup tapes), we may refuse them.

Under the following circumstances, we may not be able to fulfill your request:

1. When it is necessary for personal information controllers to fulfill obligations mandated by law or regulations;

2. When directly related to national security or defense security;

3. When directly related to public safety, public health, or significant public interest;

4. When directly related to criminal investigations, prosecutions, trials, and judgment enforcement;

5. When there is sufficient evidence to indicate that the data subject is acting maliciously or abusing rights;

6. When necessary to protect the significant lawful interests, such as life and property, of the data subject or others, and consent cannot be easily obtained;

7. When fulfilling the data subject’s request would severely harm the lawful rights and interests of the data subject or other individuals and organizations;

8. When involving trade secrets.

VII. How We Protect the Personal Information of Minors

Our products, websites, and services are not intended for minors. If we accidentally collect personal information from minors, we will attempt to delete such information promptly after verification.If you discover that we have collected personal information from minors while using our products and services, please contact us using the contact information provided in this privacy policy. We will promptly verify and delete the information if the claim is verified.

VIII. How We Use Cookies and Similar Technologies

Our websites and certain products or services employ

technologies such as cookies, web beacons, and pixel tags. These are used to enhance your user experience and allow us to improve our products and services.

IX. Third-Party Service Providers and Their Services

Our websites, products, applications, and services may include links to third-party websites, products, and services. You have the choice to access or accept websites, products, and services offered by third parties.We do not control the privacy and data protection policies of third parties, and such parties are not governed by this policy.Before submitting personal information to third parties, please refer to their privacy policies.

X. How Your Personal Information is Transferred Across Borders

If some of our products or services involve cross-border operations, we need to transfer your personal information to foreign regions where you are located. Regardless of where these personal data are processed, we will take all reasonably necessary measures to ensure the security of your data, legally and timely inform you of the destination, recipients, and other information about the transfer, and implement measures to comply with applicable legal and regulatory requirements.

In principle, personal information collected and generated within the People's Republic of China will be stored within the country.

Due to our globally distributed resources and servers, after obtaining your consent, your personal information may be transferred to or accessed from outside jurisdictions of the country/region where you use the products or services.

These jurisdictions may have different data protection laws or may not have relevant laws established. In such cases, we will ensure that your personal information receives an equivalent level of protection as it would within the People's Republic of China.For instance, we may ask for your consent for the cross-border transfer of personal information or implement security measures such as data de-identification before transferring data across borders.

XI. How This Policy is Updated

We reserve the right to update or modify this privacy policy from time to time. If revisions are made to this privacy policy, we will promptly post the latest version on our official website at a prominent location. For significant changes, we will also provide more prominent notice.If there are changes to the processing purposes, methods, and types of personal information covered by the privacy policies of specific products and services, we will reobtain your consent.

The policy allows adjustments, but without your explicit consent, we will not reduce the rights you enjoy under this policy.

>If you do not agree with the above privacy policy, we will not be able to collect and use the information necessary to provide services, thereby unable to provide you with normal services.

XII. How to Contact Us

We have established a dedicated department (or commissioner) for personal information protection. If you have any questions, comments, or suggestions about this privacy policy, you can contact us through the following methods:

(1) Email: compliance@chint.com;

(2) Phone number: 021-67777777-880080;

Generally, we will respond within thirty days.

If you are not satisfied with our response, especially if our handling of personal information has infringed upon your legal rights, you can also seek resolution through external avenues such as filing a lawsuit with the competent people's court or filing a complaint with industry self-regulatory associations or relevant government regulatory agencies. You can also ask us for information about possible relevant complaint channels that may apply.

This policy is effective from the date of its update.