【Special Note】

This policy only applies to the products and services provided by Shanggu (Shanghai) Industrial Technology Co., Ltd. and its affiliated companies (hereinafter referred to as "we" or "Shanggu Industrial Technology") and their extended functions (hereinafter referred to as "Shanggu Industrial Technology Services"), including the various products and services provided to you by Shanggu Industrial Technology's website, official account, video account, and new forms that emerge with the development of technology. If a product or service we provide has a separate privacy policy or a special agreement in the corresponding legal statement, the privacy policy of that product will take precedence. Content not covered by the privacy policy and user service agreement of that product or service shall be subject to the content of this policy. If the products or services of our affiliated companies use products or services provided by Shanggu Industrial Technology but do not set an independent privacy policy, this privacy policy also applies to those products or services.

Please read the "Shanggu Industrial Technology Privacy Policy" carefully (especially the bold content) and make sure you understand our rules for handling your personal information. If you have any questions during the reading process, you can contact us through the contact information in the "Shanggu Industrial Technology Privacy Policy".

Introduction

Welcome to the website of Shanggu (Shanghai) Industrial Technology Co., Ltd. ("this website")!

This website is provided and controlled by Shanggu (Shanghai) Industrial Technology Co., Ltd. ("we"), and our registered address is Building 16 (Building F), No. 288, Xinsheng Road, Qingpu Industrial Zone, Shanghai, People's Republic of China

We attach great importance to the privacy and personal information protection of users. When you use our products and/or services, we may collect and use your relevant information. We hope to explain to you through the "Shanggu Industrial Technology Privacy Policy" ("this Privacy Policy") how we collect, use, save, share and transfer this information when you use our products and/or services, as well as the ways we provide you with to access, update, delete and protect this information.

This privacy policy will help you understand the following:

1. What types of information we collect from you

2. How we use your information

3. How we share your information

4. Entrusted processing

5. How we protect your information

6. How long we retain your information

7. Protection of personal information of minors

8. Notice and revision

9. Third-party links

10. Contact us

Table of contents

1. What types of information do we collect from you

2. How do we use your information

3. How do we share your information

4. Entrusted processing

5. How do we protect your information

6. How long do we keep your information

7. Protection of personal information of minors

8. Notice and revision

9. Third-party links

10. Contact us

1. What types of information do we collect from you?

When you use this website, we may collect the following categories of information from you:

Information You Provide to Us.

We may collect personal information that you provide to us. When you send us a message through the "Contact Us" page on this website, you will be asked to provide your personal identification and contact information, such as your name, email address, phone number, country and city, etc. You may also provide us with your employment information, such as your employer and job title. We may also obtain information about you in your communications with us, such as in your comments, questions, feedback and other content you provide in the course of using the features of this website.

Information We Collect About You.

We may automatically collect some information about you during your use of the Site. This information may include:
● Technical and device information. We may collect certain technical information about you and your device. This information may include, but is not limited to, your IP address, system time zone, system language, and other system or network identification information.
● Action and behavioral information. We automatically collect information generated when you visit the Site and record your usage activities on the Site, including how long you stay on the Site, which parts of the Site you visit, and what information you access.
● Cookies and similar technologies. The Site may use "Cookies" and other tracking technologies to store information provided by users of the Site. Cookies are pieces of information sent by a web server to a user's browser. Cookies may include information such as user preferences, time spent on the Site, and pages visited. We use this information to recognize you and to customize and improve your experience on the Site. You can manage Cookie settings on your device through the features built into most browsers. For example, you can set your browser to notify you when you receive Cookies, or you can choose to block Cookies with your browser, but please note that not accepting Cookies may limit your use of certain features of the Site. In addition, please note that the Site is currently unable to respond to "Do Not Track" instructions issued by you.

Information we collect about you from third parties.

We may obtain personal information about your use and visits to the Website from third-party platforms and our service providers, such as your system country, device make and model, what you are browsing, browsing history, including other services you access to access our Website, search history, and click history.

2. How we use your information

We may use your information in the following ways:

Based on our legitimate interests in providing this website, we may use your information for the following purposes:

● Review your comments or questions and provide you with appropriate services;

● Enforce our terms and policies;

● Process and respond to your requests, inquiries, applications, complaints and feedback;

● Provide support and respond to your requests, feedback and inquiries;

● Monitor, operate, maintain and manage this website;

● Process and resolve technical issues and failures of this website;

● Ensure that this website operates effectively and efficiently;

● Detect, prevent or otherwise resolve security, fraud or technical issues;

● Improve and enhance the functionality and performance of this website and related services;

● Properly manage and operate our relationship with you;

● Manage our business; and protect, enforce or defend our rights and interests (including our rights and interests in the event of a breach of our terms and conditions);

● Use based on academic research;

● Use based on social public interests and public health emergencies in accordance with laws and regulations.

We may use your information for the purpose of fulfilling our legal obligations and responsibilities. If we obtain your consent or as permitted by laws and regulations, we may also process your information for other purposes we disclose to you.

3. How we share your information

We may share your information with the following third parties:

Service Providers. We may share your information with third parties who provide services to us to operate and maintain the Site, such as web hosting providers, development service providers, and cloud service providers.

Our Affiliates. We may share your information with any member, subsidiary, or affiliate of our company to provide the Site for purposes including preventing unlawful use and supporting users.

Law Enforcement and Regulatory Authorities. We may share your information with regulatory authorities, courts, third parties, and other agencies in response to a court order, subpoena, legal process request, regulatory request, or where the law permits or requires information, including where we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, or potential threats to the physical safety of any person.

Sales or Mergers. We may disclose your information to any third party that meets the following circumstances:

● A third party that acquires or intends to acquire all or part of our assets or shares;

● A third party that is acquired by us in whole or in part.

● A third party that merges with us; or

● A third party that succeeds all or part of our business,

In each of the above cases, the third party is legally obligated not to disclose and use your information without our authorization.

Please note that the information you voluntarily share or even publicly share when using our services may involve your or others' personal information or even sensitive personal information. Please consider and decide carefully when sharing.

4. Entrusted processing

We may entrust authorized partners to process your personal information in order to provide you with corresponding products or services. However, we will only share your personal information for legitimate, legitimate, necessary, specific and clear purposes, and will only share personal information necessary to provide products or services. If our partners use your personal information for purposes not entrusted by us, they will obtain your consent separately.

Our partners include the following types:

Suppliers who provide technical services. We may provide your personal information to third parties that support our functions, including suppliers who provide us with infrastructure technical services, data analysis services and data processing services.

Advertising and analysis service partners. We will comply with laws and regulations and industry-wide security technologies and entrust these partners to process information related to advertising, coverage and effectiveness.

For partners we entrust to process personal information, we will sign a data protection agreement with them and require them to process personal information in accordance with the agreement, this privacy policy and relevant laws and regulations.

5. How we protect your information

We implement security measures in accordance with this Privacy Policy and have physical, electronic and managerial procedures in place to protect and secure the information we process about you. However, no data transmission over the Internet is completely secure and we cannot ensure the security of your information. All transmission of your information to us is at your own risk.

6. How long do we retain your information

During your use of the services of this website, your personal information will be kept for the period necessary to achieve the purposes described in this policy, and will also be determined in conjunction with the mandatory retention period required by law, such as the "E-Commerce Law of the People's Republic of China" requiring that information on goods and services and transaction information be kept for no less than three years from the date of completion of the transaction. After the retention period expires, we will delete your personal information or anonymize it in accordance with the requirements of applicable laws.

We may also retain your information when we have other legitimate purposes; for example, when we are subject to mandatory requirements of laws and regulations, administrative and judicial departments, contracts or similar obligations and need to retain personal information, we respect and attach great importance to your rights related to your personal information, including:

Data access rights. You have the right to ask us to confirm whether we process your personal information and to ask us to provide a copy of your personal information.

Right to correction. If any of your personal information collected by us is incomplete or inaccurate, you can ask us to correct or update this information.

Right to deletion. In certain circumstances, you can ask us to delete all or part of your personal information.

Withdrawal of consent. If our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. However, if your consent is withdrawn, you may not be able to use some of the features of this website and our services.

You may exercise any of your rights by contacting us in accordance with Section 10 (Contact Us) of this Privacy Policy. To protect your privacy, we may ask you to provide additional information to prove your identity before we process your request.

7. Protection of Minors’ Personal Information

Shanggu Industrial Technology attaches great importance to the protection of minors' personal information. If you are a minor under the age of 18, you should obtain the consent of your guardian before using our products and/or services. Shanggu Industrial Technology protects minors' personal information in accordance with relevant national laws and regulations.

We will not actively collect personal information from minors directly. In the case of collecting minors' personal information with the consent of their guardians, we will only use, share, transfer or disclose this information when permitted by law, with the consent of the guardian or necessary to protect minors.

8. Notices and Revisions

We reserve the right to amend this Privacy Policy from time to time at our sole discretion. We will notify you of any material changes to this Privacy Policy through a notice posted on this website, and such changes will apply only to information collected after the revised Privacy Policy becomes effective. Any revisions to this Privacy Policy will be effective immediately upon posting. We encourage you to review this Privacy Policy periodically to learn about changes to this Privacy Policy and how we are protecting your personal information.

9. Third-party links

This Privacy Policy does not apply to any other website or platform, unless the context indicates otherwise. Please note that this website may include links to other websites, platforms or products whose privacy policies and practices differ from ours. These links are provided for your convenience and more information only and do not constitute an affiliation or sponsorship relationship between us and third-party websites, nor do they represent our endorsement of the information on third-party websites. If you provide your information to any of these third parties or interact with these third-party websites, we are not responsible for the collection and processing of your information by them.

10. Contact Us

If you have any questions about this privacy policy, please contact us at [400-7167-8001].

Generally, we will respond within 15 days. If you are not satisfied with our response, especially if our personal information processing behavior has damaged your legitimate rights and interests, you can also complain or report to the Internet Information Office, Telecommunications, Public Security and Industrial and Commercial Regulatory Department.

Attachment: Examples of personal information and sensitive personal information (personal information collected by non-Shanggu Industrial Technology websites, public accounts, and video accounts, for example only)

Personal information: various information related to identified or identifiable natural persons recorded electronically or otherwise, excluding information after anonymization.

Sensitive personal information: personal information that, once leaked or illegally used, is likely to infringe on the personal dignity of a natural person or endanger personal and property safety, including biometrics, religious beliefs, specific identities, medical health, financial accounts, whereabouts, and other information, as well as personal information of minors under the age of fourteen.

Device information: including device identification code (IMEI, IDFA, AndroidID, MAC, OAID, IMSI and other device-related information), application information (application crash information, notification switch status, application installation list and other application-related information), device parameters and system information (device type, device model, operating system and hardware-related information), device network environment information (IP address, WiFi information, base station information and other network-related information).