Personal Information Protection Policy

Updated on July 15, 2025

This Personal Information Protection Policy (this “Policy”) applies to the websites (the “Platforms”) established and operated within the territory of the People’s Republic of China by Sailun Group Co., Ltd. and its affiliated companies ( “we”, “us”, “our”).

Affiliated companies refer to companies and organizations that currently or in the future, control, or are controlled by, or are under common control with Sailun Group Co., Ltd. “Control” refers to the ability to govern or influence the management or operations of the controlled party, directly or indirectly, through ownership, voting shares, contracts, de facto operational connections, or other means recognized by law.

We strive to present this Personal Information Protection Policy clearly and understandably and to truly explain our practices, thus ensuring you are well-informed of the purposes, potential uses, and other relevant aspects of data processing before you provide certain information (which may include your personal information) to us and permit us to process and share such information.

Our Platform fully recognizes the importance of your personal information and ensures strict compliance with applicable laws and regulations, including but not limited to the Personal Information Protection Law of the People’s Republic of China, during information processing. We are committed to safeguarding the security and confidentiality of your personal information, maintaining your trust in us, and upholding the following principles in the protection of your personal information: balance of rights and obligations, purpose specification, explicit consent, data minimization, security assurance, individual participation, and transparency. Furthermore, we pledge to implement appropriate security measures aligned with established industry security standards to protect your personal information.

By agreeing to this Policy, you acknowledge and consent to our processing of your personal information in connection with related activities for specified purposes. However, this does not mean that we will be processing all categories of personal information described in this Policy as soon as you begin using our products/services or participating in our activities. We will only process your personal information in accordance with the “data minimization” principle when you use specific products/services or engage in specific activities.

Before using our products or services or participating in our activities, please read this Policy carefully to ensure full understanding and make informed decisions. We draw your particular attention to terms in bold font within this Policy, as these provisions significantly affect your rights and interests.

This Policy outlines:

1. How we collect, process, and use your personal information.
2. How we use cookie and similar technologies.
3. How we share, transfer, and disclose your personal information.
4. How we protect your personal information.
5. Your rights.
6. How we process children’s personal information.
7. Global transfer of your personal information.
8. How we update this Policy.
9. How to contact us.

Ⅰ. How we Collect, Process, and Use your Personal Information
    

Personal information refers to various kinds of information recorded electronically or by other means, which, either alone or in combination with other information, can be used to identify a specific natural person or reflect the activities of a specific natural person. Personal sensitive information refers to personal information that, if leaked, illegally provided, or misused, may endanger personal or property safety, or easily lead to harm to personal reputation or physical and mental health, or result in discriminatory treatment, among other consequences. If the information we collect and use involves your personal sensitive information, we will use bold and underlined text to clearly mark it and bring it to your attention. Simultaneously, we will adopt security measures to transmit and store your personal sensitive information. Please consider carefully if the information you intend to publicly disclose involves your personal sensitive information or information about others. If the information you intend to publicly disclose involves minors’ personal information, you must obtain the consent of the corresponding minor’s guardian before the disclosure. This Platform will only collect and use your personal information for the purposes specified in this Policy and with your consent.

Exceptions to Obtaining Consent
Please be advised that, in accordance with the provisions of relevant laws and regulations, we may collect and use your personal information without obtaining your prior consent under the following circumstances:

1. Where it is necessary for the conclusion or performance of a contract to which you are a party.
2. Where it is necessary for the performance of a legal obligation or statutory duty, including but not limited to those related to national security, national defense, as well as statutory obligations in areas such as criminal investigation, prosecution, trial, and the execution of court judgments.
3. Where it is necessary to respond to public health emergencies or, in urgent circumstances, to protect the life, health, or property safety of natural persons.
4. Where your personal information is processed within a reasonable scope for the implementation of activities in the public interest, such as news reporting and public opinion supervision.
5. Where your personal information, which has been disclosed by yourself voluntarily or has otherwise been lawfully made public, is processed within a reasonable scope.
6. Other circumstances stipulated by laws and administrative regulations.

If we need to collect or process your personal information for any purpose or in any context not described above, or if we intend to use your personal information—collected for a specific purpose—for any other purpose not stipulated in this Policy, we will notify you separately prior to such collection or use, and will only collect or use the information after obtaining your consent.

Ⅱ. How we Use Cookie and Similar Technologies

We use cookies to enhance your experience on our website. Cookies are text files placed on your device that enable us to provide specific features and functionality.
Please refer to our Cookie Policy for more information.

Ⅲ. How we Share, Transfer, and Disclose your Personal Information.

A. Share
We are committed to maintaining the strict confidentiality of your personal information. Unless otherwise required by laws, regulations, or the stipulations of regulatory authorities, we will not share your personal information with any companies, organizations, or individuals, except under the following circumstances:

1. Sharing with your explicit consent: We will share your personal information where permitted by law and where such sharing falls within the scope of the authorization you have provided.
2. Sharing under statutory circumstances: We may share your personal information as required by laws and regulations, or for the purpose of resolving litigation or arbitration disputes, or in response to lawful requests from judicial or administrative authorities.
3. Sharing for the purpose of handling disputes, controversies, mediation, arbitration, or litigation related to you: Under such circumstances, we may share your personal information with our appointed representatives (including but not limited to legal counsel, agents, and consultants).
4. Sharing with third-party service providers: To achieve the purposes specified in this Policy, we may share your personal information with third parties that cooperate with us or provide services on our behalf, within the scope permitted by applicable laws and regulations and within the scope of your authorization.

We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and will only share the personal information that is necessary for providing the services. The third-party companies we engage will not be authorized to use the shared personal information for any other purposes. We will enter into binding confidentiality agreements with these third-party companies, to ensure that your personal information is processed in accordance with our instructions, this Personal Information Protection Policy, and other relevant confidentiality and security measures.

B. Transfer
We will not transfer your personal information to any companies, organizations, or individuals, except under the following circumstances:
1. Obtain your prior explicit consent.
2. In the event of a transfer of your personal information due to reasons such as merger, division, dissolution, and declared bankruptcy, we will notify you of the name and contact information of the recipient and require the recipient to continue to observe the provisions of this Policy. Should the recipient alter the purposes or methods of personal information processing as specified in this Policy, we will require them to obtain your consent anew.

C. Disclose
As a general principle, we will not publicly disclose your personal information, unless compelled to do so by mandatory requirements of applicable laws, regulations, judicial authorities, or administrative bodies. Should public disclosure become necessary, we will inform you of the purpose of the disclosure, the categories of information involved, and any potential sensitive information, and will obtain your separate consent prior to the disclosure.

D. Exceptions to Sharing, Transferring, and Publicly Disclosing Your Personal Information
Please be advised that the six exceptions to obtaining consent as stipulated in Article Ⅰ of this Policy also apply to the sharing, transferring, and public disclosure of your personal information. This means that under the aforementioned exceptional circumstances, we may share, transfer, or publicly disclose your personal information without obtaining your prior consent.

Ⅳ. How we Protect your Personal Information

A. During your use of our Platform, we will retain your personal information for the minimum period required to achieve the purposes specified in this Policy, and will take into account any mandatory retention periods stipulated by laws and administrative regulations.
B. In accordance with applicable laws, we have implemented industry-standard security safeguards to protect your personal information from unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonably practicable measures to safeguard your personal information.
C. While absolute security cannot be guaranteed for data transmitted over the internet, we will endeavor to ensure or guarantee the security of any information you send to us.. Should our physical, technical, or administrative safeguards be compromised, resulting in unauthorized access, public disclosure, alteration, or destruction of your personal information that thereby infringes upon your legitimate rights and interests, we will assume corresponding legal liability.
D. In the event of a personal information security incident, we will, in accordance with applicable laws and regulations, promptly notify you of: the basic details of the security incident and its potential impact; the measures we have taken or will take in response; recommended proactive measures to mitigate risks; and the remedies available to you. We will promptly notify you of the incident via email, letter, phone, push notification, or other methods. If it is not feasible to notify each individual personally, we will issue a public announcement through appropriate and effective channels. Additionally, we will proactively report the progress in addressing the personal information security incident to the relevant regulatory authorities as required.

Ⅴ. Your Rights
In accordance with the provisions of applicable laws and regulations of the People’s Republic of China, we safeguard your rights to exercise the following controls over your personal information:

A. Requesting Correction, Supplementation, Access, and Copying of your Personal Information, and Withdrawing your Consent
You may contact us by email at privacy@sailuntire.com to submit your request. Please understand that after you withdraw your consent, we will no longer be able to provide you with the specific services that were associated with that withdrawn consent. However, your decision to withdraw consent will not affect the personal information processing activities that were conducted based on your authorization prior to the withdrawal.

B. Deleting your Personal Information
You may contact us by email at privacy@sailuntire.com to request deletion of your personal information. However, if the retention period stipulated by laws or administrative regulations has not expired, or if deletion is technically infeasible, we will cease all processing activities other than storage and implementation of necessary security safeguards.

C. Our Response to your Requests
We will respond to your requests regarding the aforementioned rights within 15 business days after receiving your request and verifying your identity. If you are not satisfied with our response, you may lodge a complaint with us through the contact details provided in Article Ⅸ of this Policy.
To ensure security, we may require you to verify your identity before processing your request. In case your identity fails verification, we will not be able to process the relevant request.
For reasonable requests, we generally do not charge a fee. However, we may charge a fee to cover our costs for repeated and excessive requests. We may decline requests that are manifestly unfounded or excessively repetitive, or require disproportionate technical means (such as developing new systems or fundamentally changing existing practices), or pose a risk to the rights and interests of others, or are deemed impractical.

D. Protection of Deceased Individuals’ Personal Information
We protect the personal information of deceased individuals in accordance with applicable laws and regulations. Unless otherwise arranged by the deceased individual during their lifetime, their immediate relatives may exercise rights such as access, copying, correction, and deletion with respect to the relevant personal information of the deceased individual for their own lawful and legitimate interests. Please understand that, in order to fully protect the personal information rights of the deceased individual, when immediate relatives of the deceased individual apply to exercise the relevant rights, we may require the applicant to provide documentation such as the deceased individual’s identity certificate, death certificate, the applicant’s identity certificate, and proof of relationship with the deceased individual.

E. Exceptional Circumstances
We will be unable to comply with your request under the following circumstances:

1. Where it is related to our compliance with obligations under laws and regulations.
2. Where it is directly related to national security or national defense.
3. Where it is directly related to public safety, public health, or significant public interests.
4. Where it is directly related to criminal investigation, prosecution, trial, or the execution of court judgments.
5. Where we have substantial evidence indicating that you are acting in bad faith or abusing your rights.
6. Where it is necessary to protect the vital legitimate interests, such as life or property, of you or another individual, and it is difficult to obtain your consent.
7. Where responding to your request would cause severe harm to the legitimate rights and interests of you or any other individual or organization.
8. Where it involves trade secrets.

Ⅵ. How we Process Children’s Personal Information

A. We consider minors under the age of fourteen (14) as children.
B. As soon as we become aware that we have collected or may have collected children’s personal information, we will take steps to delete such information promptly.
C. If you, as a parent or guardian of a child, discovers that your child has provided us with personal information, you may contact us through the details provided in Article Ⅸ of this Policy to request deletion. Upon verification, we will promptly delete the relevant information.

Ⅶ. Global Transfer of your Personal Information

Any personal information collected and generated during our operations within the People’s Republic of China will be stored within the territory of the People’s Republic of China. Currently, we do not transfer such information overseas. Should overseas transfer become necessary in the future, we will, in accordance with relevant laws and regulations, inform you of the necessity for such transfer, obtain a separate consent from you, fulfill all legal obligations related to cross-border data transfer, and ensure that your personal information receives protection overseas equivalent to the level of protection provided within China.

Ⅷ. How we Update this Policy

A. We may update this Policy from time to time, based on changes to our products or services and in response to relevant legal and regulatory requirements. Your rights under this Policy will not be compromised without your explicit consent. In the event of any updates to this Policy, we will publish the revised version where it was originally made available and may notify you via text message of an updated version. Should such updates result in a material reduction of or significant changes to your rights hereunder, we will seek your consent again.

B. The aforementioned “significant changes” include but are not limited to:
1. Significant changes to our service model, for example, changes to the purposes of personal information processing, the types of personal information processed, or the methods of personal information processing.
2. Significant changes to our ownership structure or organizational framework, for example, changes to ownership due to business adjustments, bankruptcy, or mergers and acquisitions.
3. Changes to the primary recipients for sharing, transferring, or publicly disclosing your personal information.
4. Changes to your rights regarding personal information processing and/or the methods for exercising such rights.
5. Other circumstances that could significantly impact your personal rights and interests.

Ⅸ. How to Contact us

Should you have any questions, comments, or suggestions regarding this Personal Information Protection Policy or our processing of your personal information, or wish to exercise your rights in relation to personal information processing, you may contact us via privacy@sailuntire.com.

Sailun Group Co., Ltd.