Digital China Group Co., Ltd. and its affiliates (hereinafter referred to as “Digital China”, “we” and “our”) understand the importance of privacy to you and respect your privacy. Please read and understand this Privacy Policy (hereinafter referred to as “This Policy”) before submitting personal data to Digital China. This Policy describes the way Digital China processes your personal data, but it may not involve all possible data processing scenarios. Digital China may release the information on collecting specific data of products or services in the complementary policy or the notices provided at the time of data collection.

We have developed This Policy to help you understand the following contents:

1.How does Digital China collect and use your personal data?

2.How does Digital China use cookies and similar technologies?

3.How does Digital China disclose your personal data?

4.How to access or modify your personal data?

5.How does Digital China protect your personal data?

6.How does Digital China process children’s personal data?

7.Third party providers and their services

8.Notification of disclosure of personal information

9.How to update This Policy?

10.How to contact Digital China?

1. How does Digital China collect and use your personal data?

Personal data refers to information that can be used to identify personal identity when separately used or used together with other information. Such data will be directly submitted by you when you use our website, products or services, or when you interact with us, for example, when you create a Digital China account or contact us for support; or we can obtain such data by recording how you interact with our website, products or services, for example, by technologies including Cookie, or receive data from the software on your device. Provided that the law permits, we can acquire relevant data from a public or commercial third party. The data we collect depend on the way by which you interact with Digital China, including the website you access or the products and services you use, involving your name, gender, employer's name, position, address, email, telephone, login information (account and password), photo, and certificate information, etc. We also collect information you have provided for us and messages you send to us, such as the inquiry information you input or the questions or information you provide for getting customer service supports. You may need to provide your personal data when using products or services of Digital China. In some cases, you can choose not to provide Digital China with personal data, in this case Digital China may neither provide you with relevant products or services, nor respond to or solve the problems you have encountered.

We may use your personal data for the following purposes:

(a) Create an account.

(b) Fulfill your transaction or service requests, including executing an order; delivering, activating or validating product or service; offering training and certification services, managing and processing training and certification results; taking part in online or onsite activities; making changes at your request or providing information you have requested (such as product/service marketing materials, white paper); and providing technical supports.

(c) Contact you with your consent; send you information on products and services you may be interested in; invite you to take part in Digital China's activities (including sales promotion), market researches or satisfaction surveys; or send you marketing information. You can unsubscribe such information at any time if you do not want to receive them anymore.

(d) Send you important notices, such as notices on update and installation of operating system or applications.

(e) Provide you with personalized user experience and personalized content.

(f) Accredit and manage suppliers and business partners, communicate or cooperate with suppliers and business partners.

(g) Conduct internal audits, data analysis and research to improve our product and service.

(h) Analyze business operational efficiency and measure market share.

(i) Troubleshoot errors if you choose to send us error details.

(j) Synchronize, share and store the data you have uploaded or downloaded, and the data needed for uploading and downloading.

(k) Protect our products, services and safety of our customers and users, carry out and improve our loss-prevention and anti-fraud plan.

(l) Comply with and act applicable legal requirements, relevant industry standards or our policies.

Digital China may collect and use non-identifying data. Non-identifying data refer to data that cannot be used to identify personal identity. For example, Digital China may collect summarized statistical data such as website visits for the purpose of learning about how the users use their websites, products and services. By this, Digital China can improve their services to better meet its customers' needs. Digital China may decide at its own discretion to collect, use, process, transfer or disclose non-identifying data for other purposes. We will try to isolate your personal data and non-identifying data, and use these two types of data separately. Personal data are still deemed as personal data even they are mingled with non-identifying data.

When Digital China processes your personal data, we will comply with applicable legal requirements on the appropriate legal basis, including:

(a) Process your personal data for contract performance when responding to your transaction or service request; process your personal data with your consent;

(b) When contacting you, carrying out marketing or market survey, or processing your personal data to improve our products and services and carrying out and improve our loss-prevention and anti-fraud plan, we will base ourselves on our or third-party legitimate interests, which include, enable us to manage and operate our business more effectively and offer our products and services; protect our business, system, products, services and customers; ensure compliance with internal policies and process through internal management; other legitimate interests we describe in This Policy, etc.;

(c) We may also process your personal data based on compliance with and performing legal duties.

2. How does Digital China use cookies and similar technologies?

2.1 Cookie

To ensure proper operation of the website, we may occasionally store a small data file named Cookie in your computer or mobile device. Cookie is a type of plain text files stored by network servers on the computer or mobile device. The contents of a Cookie can only be retrieved or read by the server creating it. Each Cookie is unique to your web browser or mobile application. Cookie usually consists of identifier, site name and some numbers and characters. By using Cookie, a website can store data such as user preferences or goods in the shopping cart.

The purpose that Digital China uses Cookie is the same as that of most websites and Internet service providers, namely improving user experience. By using Cookie, the website can remember users' single visit (by means of session Cookie) or multiple visits (by means of permanent Cookie). By using Cookie, the website can save the settings, such as languages and font sizes of computer or mobile device, and other browsing preferences. It means that it is no need for users to reconfigure their preferences at each access. In the event that a website does not use Cookie, each time the user opens a webpage, he/she will be deemed as a new visitor. For example, provided that you turn to another webpage after logging in a website, the website will not recognize you, and you will be logged out once again. Digital China will not use the Cookie for any other purpose beyond the purposes stated in this Policy. You may manage or delete Cookie in accordance with your preferences. For details, please see AboutCookies.org. You can remove all cookies saved in your computer as most web browsers have functions of blocking Cookie. However, if you do so, you need to change the browser user setting by yourself whenever you assess our website.

2.2 Web beacon and pixel tag

Besides Cookie, we will use other similar technologies such as Web beacon and pixel tag on the website. For example, the email that Digital China sends to you may contain URL linking to the contents of the website of Digital China. If you click the link, Digital China will track the link to help us learn about your product and service preferences and improve customer services. Web beacon is usually a type of transparent graphic image embedded in a website or email. By using pixel tag in an email, we can know whether the email has been opened. If you do not want your activities being tracked in this way, you can unsubscribe from the mailing list of Digital China at any time.

Your use of our website means you agree to use Cookie, Web beacon and pixel tag as mentioned above.

3. How does Digital China disclose your personal data?

In the event that certain services are provided by authorized partners of Digital China, Digital China will share your personal data with those partners as described in This Policy. For example, when you purchase a Digital China product online, Digital China have to share your personal data with a logistics service provider to arrange delivery or arrange for a partner to provide services. In addition, we may share personal data among Digital China affiliates.

Digital China may also disclose your personal data to relevant law enforcement agencies or other government agencies when required by applicable law or in response to legal process. In some jurisdictions, your personal data may also be disclosed to counterparties in the event that Digital China is involved in reorganization, merger or bankruptcy and liquidation proceedings. Digital China may disclose your data in view of reasonable requirements. For example, disclosing the data for performing a contract. We believe that such disclosure is necessary and appropriate for preventing from physical harm or property loss or investigating possible or actual illegal behavior.

4. How to access or modify your personal data?

You should ensure that all personal data you have submitted are accurate. Digital China tries to ensure accuracy and integrity of personal data, and update these data in a timely manner.

In the case of compliance with appropriate legal requirements, you may (1) have the right to access your specific personal data held by us; (2) require us to update or change your inaccurate personal data; (3) refuse or restrict us to use your personal data; and (4) require us to delete your personal data. In order to ensure safety, you may need to provide a written request. Provided that we have reasonable grounds believing these requests are deceptive, cannot be put into practice or harm the privacy rights of others, we will refuse your requests.

In the case of compliance with appropriate legal requirements, provided that Digital China processes your personal data with your consent, you have the right to cancel your consent at any time, but the cancellation neither affect the validity and effectiveness of our processing of your personal data based on your consent before the cancellation, nor affect our processing of your personal data on other appropriate basis of legitimacy.

Where you believe that our processing of your personal information does not comply with laws of data protection, you may contact with the legal organization for data protection.

5. How does Digital China protect and retain your personal data?

Digital China values the security of personal data. We employ appropriate physical, administrative and technical safeguards to protect your personal data from unauthorized access, disclosure, use, modification, damage or loss. We will do our best to protect your personal data till all the security measures are perfect.

We will keep your personal data within the period needed to achieve the purpose stated in This Policy, unless we need to extend the retention period in accordance with legal requirements or permission. The period of data storage may vary with different scenarios, products and services. The standards we use to determine the retention period include: the time of personal data storage required for achieving the business goal, involving providing products and services, maintaining corresponding transactions and business records, managing, controlling and enhancing the performance and quality of products and services, ensuring safety of system, products and services, coping with possible user queries or complaints, and localizing the problems, etc.; whether the user agrees longer period of retention; whether there are special requirements on data retention in law and contract. We will reserve your registration information as long as your account is at your service. You may also choose to unsubscribe your account, after which we will stop providing products and services based on the account, and delete your relevant personal data in view of no special legal requirement.

6. How does Digital China process children’s personal data?

Our products, website and services are mainly for adults. Without the consent of parents or guardian, no child may create his/her user account. In view of collection of children’s personal data without consent of their parents, we will use and disclose the data only when it is legally permitted, it has been explicitly agreed by children’s parents or guardians or it is necessary for protecting the children. In the event that Digital China finds that it has collected children’s personal data without obtaining explicit consent of their parents, we will try to delete relevant data as soon as possible.

7. Third Party providers and their services

To ensure a smooth browsing experience, you may receive contents or links from Digital China and its external third-party partner (hereinafter referred to as “third Parties”). Digital China has no right to control such third parties. You can choose whether to access the links, contents, products and services provided by these third parties.

Digital China has no control over the privacy and data protection policies of third parties and those third parties are not bound by This Policy. Before submitting personal information to third parties, please refer to the privacy policies of those third parties.

8. Notification of disclosure of personal information

In case of any personal data disclosure, loss, theft or tampering caused by force majeure affecting the normal operation of the network due to hacker attacks, computer virus intrusion or outbreak, government regulation, etc., we will report the disclosure to the regulatory authorities within 72 hours after the disclosure of your personal information. Where the disclosure of personal information may pose a significant risk to your rights or freedoms, we will notify you immediately to enable you take timely measures to protect your personal information.

9. How to update This Policy?

Digital China reserves the right to update or modify This Policy from time to time. In the case of amendments on our Privacy Policy, we will release the latest edition of the Privacy Policy here. In view of material changes to our Privacy Policy, we may also notify you of the changes via different channels, such as releasing a notice on our website or sending a separate notice to you.

10. How to contact Digital China?

If you have any privacy complaint or question, please click Contact Us.