Preamble

Your trust is of utmost importance to us. We fully understand the significance of personal information to you. We will collect your personal information within a reasonable and necessary scope in accordance with legal and regulatory requirements. We make every effort, through reasonable and effective information security technology and management processes, to take corresponding security protection measures to prevent your information from being leaked, damaged, or lost. In light of this, the provider of CLOU Platform services (hereinafter referred to as “we”) formulates this “Privacy Agreement” and reminds you to note the following:

This Agreement applies to all products and services of the CLOU Platform. The CLOU Platform refers to the CLOU website (domain name http://www.szclou.com) and related CLOU client applications operated by Shenzhen CLOU Electronic Technology Co., Ltd. and its affiliated companies.

It is important to note that this Agreement does not apply to services provided to you by third parties. For example, when redirected from the CLOU company website to third-party websites, client applications, or programs, your personal information provided to such third-party service providers is not subject to this Agreement.

Before using any product or service of the CLOU Platform, please be sure to read this Agreement carefully and thoroughly understand it, especially the terms highlighted in bold or underlined, which you should focus on. Please begin use only after fully understanding and agreeing to accept them. If you have any questions about this Agreement, you can consult CLOU customer service (0755-33309999) or contact us through any contact method provided on the CLOU Platform.

If you are a minor under the age of 18, please read this Agreement under the guidance of your legal guardian, paying special attention to the terms regarding minor use.

This Agreement primarily informs you of:

l  What information we collect from you.

l  How we use your information.

l  Under what circumstances we share your information.

l  How we store your information.

l  How we protect your information.

l  The rights you are entitled to.

l  Account deregistration by the personal information subject.

l  How the personal information of minors is protected.

l  How to contact us.

· What information we collect from you

1.1 The principle for our collection of your information is legality, reasonableness, and necessity. When providing you with a specific service, we will clearly inform you of the information to be collected and its purpose in response to your specific service request. Depending on the service you choose, we may collect one or more of the following types of information in the following scenarios:

(1) Account information. For example, your account ID, password, name, email, phone number, country/region, etc.;

(2) Personal contact information. For example, your name, email, phone number, country, city, company, position, address, etc.;

(3) User experience feedback. For example, your feedback on the use of CLOU-related products and services, purchase demand feedback, evaluations, satisfaction feedback, etc.1.2 Information obtained during your use of products and services

(1) Device information. We collect information about the device you use when accessing CLOU products and services, such as the operating system, IP address, browser type and version, and other technical information that may vary by product.

(2) Interaction information

√ Interaction records generated when you watch live streams, click on advertisements, open or click on marketing or business notification emails we send;

√ When interacting with our pre-sales or after-sales service centers and other customer communication channels face-to-face, online, or via phone or email, we may record the communication process, including phone numbers, recordings, chat records, and other information;

√ When you participate in offline activities such as CLOU exhibitions and summits, we may collect attendees’ participation records, as well as photos, audio, video, and other content related to the offline activities;

√ When using location-based products or services, you may need to authorize us to obtain your location information;

√ When you use CLOU products or services, CLOU automatically collects and stores necessary log information, such as access time, frequency, IP address, events (e.g., successful or failed access), and other information.

(3) Information from third-party sources

Where permitted by law, CLOU may also obtain information about you from public or commercial third-party sources, such as obtaining your nickname from a third-party social media platform when you log into our website through that social media account.

(4) Collection and use of non-identifiable data

Non-identifiable data refers to data that cannot be used to identify a specific individual. For example, CLOU collects aggregated statistical data such as website traffic. CLOU collects this data to understand how users use our websites, applications, products, and services to improve service levels and enhance user experience. CLOU may, at its discretion, collect, use, process, transfer, or disclose non-identifiable data for other purposes. We will endeavor to isolate your personal information from non-identifiable data and use the two types of data separately. If personal information is mixed with non-identifiable data, it will still be treated as personal information.· How we use your personal information

2.1 Purposes of using personal information

The purpose of CLOU collecting and using personal information is to provide you with a better product and service experience. Your personal information may be used for the following purposes:

(1) Identity verification. When you use our products or services, you may need to provide personal information for account creation and subsequent identity verification and permission management;

(2) Contacting you with your consent; sending you information or notifications about CLOU products or services; inviting you to participate in CLOU activities, surveys, etc. If you do not wish to receive the aforementioned information, you can unsubscribe or refuse at any time;

(3) When you register for our online or offline marketing activities, used by CLOU or authorized partners to confirm your participation request, send event information, collect survey information, etc.;

(4) With your consent, CLOU may share hashed user IDs with third-party social media platforms to show you information related to CLOU products or services;

(5) Fulfilling contracts related to CLOU products or services, processing payments, arranging shipping, delivery, and maintenance services;

(6) Providing technical support and after-sales service for CLOU products or services based on contractual agreements or at your request, including resolving issues you raise, providing solutions or suggestions, etc.;

(7) Organizing and managing CLOU certification exams, online learning, training organized by CLOU or authorized partners, ICT competitions, etc.;

(8) Certifying and managing suppliers and partners, communicating or conducting business with suppliers and partners;

(9) Providing you with a personalized user experience and personalized content;

(10) Complying with and enforcing applicable legal requirements.2.2 Legal basis for processing personal information

When CLOU processes your personal information, we will comply with applicable laws and regulations and process it based on appropriate legal grounds, including:

√ Processing your personal information based on your consent;

√ Processing your personal information based on the performance of a contract;

 √ Processing your personal information based on compliance with and fulfillment of legal obligations.During the initial login, you need to provide your mobile phone number to register your account and set your account password.

l  After successful registration, you can optionally fill in your personal information in the personal profile section, such as your nickname, gender, birthday, address, avatar, email, feedback, and other related information. This type of information is maintained by you and can save time delays caused by filling in forms when using CLOU-related services. However, we do not require you to fill it in; you can choose to maintain it optionally or fill it in when actually needed.

l  When you leave a message or comment on the CLOU website, we need to collect your nickname, avatar, message, and comment content. Your messages and comments will be stored on our servers. We will anonymize your CLOU Platform account and nickname before displaying them publicly. However, please note that information you publicly release may involve your or others’ personal information, even sensitive personal information. For example, if you choose to upload pictures containing personal information when commenting, please consider more carefully whether to share or even publicly share such information when using our services.

l  When using CLOU services, to provide you with more convenient and personalized information display, search, and push services, we will extract your preference characteristics based on your purchase information and service log information, and generate indirect user profiles based on characteristic tags for displaying, pushing information, and possible commercial advertisements.

l  To help us understand the operation of the CLOU website and related APPs, we use mobile analytics software statistical SDKs. We may record related information, such as your usage frequency, crash data, overall usage, performance data, etc. We will not associate information stored in the analytics software with any of your personal information.

l  When you use the products or services of the CLOU Platform, we automatically receive and record information on your browser and computer, such as your IP address, browser type, language used, access date and time, software and hardware characteristic information, and the web page records you request, etc.

l  When you use the products or services of the CLOU Platform, we may read location-related information about you, such as the device’s GPS signal or nearby WLAN access points, relevant information from cell towers, country code, city code, mobile network code, cell ID, latitude and longitude information, and language settings.

l  When you use CLOU Platform voice devices and voice services, after you activate or wake up the smart device, we automatically receive and record audio, video, and other information generated by your interaction with the device terminal. We use this information to improve the comprehension ability of the intelligent recognition system for the content you express. Please note that if the device or program is set to collect voice information only when the wake-up function is turned on. If you refuse us to collect the above information, please turn off the device’s information collection function or do not wake up the device, but this will also result in you being unable to obtain related services.

l  It is particularly important to note that device information and service log information alone are information that cannot identify a specific natural person. If we combine this type of non-personal information with other information to identify a specific natural person, or use it in combination with personal information, then during the period of combined use, this type of non-personal information will be regarded as personal information. Unless authorized by you or otherwise stipulated by laws and regulations, we will anonymize and de-identify this type of information.

l  Obtaining your personal information from third-party service providers: In third-party device management services, we will cooperate with third-party service providers, which involves us obtaining your personal information from these third-party service providers. We will obtain the following personal information from you under the condition that you bind a third-party account: Third-party account information, including your nickname and avatar, for display on the CLOU Platform; a list of some devices added on the third-party application, for displaying devices in the “CLOU” application; device and network information, including device identifiers, MAC address, device serial number, used to identify the currently working device and for device security control. If the personal information processing activities we need to carry out in conducting our business exceed the scope of your original authorization and consent when providing personal information to the third-party service provider, we will obtain your explicit consent before processing such personal information. In addition, we will strictly comply with relevant laws and regulations and require third-party service providers to ensure the legality of the information they provide. When we intend to use information for purposes not stated in this declaration, we will seek your consent in advance. When we intend to use information collected for a specific purpose for other purposes, we will seek your consent in advance.

l  In addition, we may also collect other information, for example, questionnaire response information you send us when participating in surveys; information you provide us when participating in user experience programs and when interacting with us.

l  To improve the security of your use of CLOU Platform services, protect the personal and property safety of you, other users, or the public from infringement, better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, and other security risks, and more accurately identify violations of laws and regulations or CLOU Platform related agreement rules, we may use or integrate your account information, device interaction information, network log information, and information we obtain with your authorization or share based on the law to comprehensively assess your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures according to the law.

l  If the information you provide contains personal information of other users, you must ensure you have obtained legal authorization before providing such personal information to us. If we use information for other purposes not stated in this Agreement, or use information collected for a specific purpose for other purposes, or if we actively obtain your personal information from third parties, we will obtain your consent in advance.

l  Exceptions to obtaining authorization and consent: You fully understand and agree that we may collect and use your personal information without your authorization and consent under the following circumstances, and we may not respond to your requests for correction/modification, deletion, deregistration, withdrawal of consent, or access to information:

l  Related to national security and national defense security;

l  Related to public safety, public health, and significant public interests;

l  Related to crime investigation, prosecution, trial, and execution of judgments in judicial or administrative law enforcement;

l  Where it is necessary to protect the significant legitimate rights and interests of your or others’ lives and property, but it is difficult to obtain the consent of the individual;

l  Personal information that you voluntarily disclose to the public;

l  Collecting personal information from legally publicly disclosed information, such as through legal news reports, government information disclosure channels, etc.

l  Necessary for signing and performing related agreements or other written documents with you;

l  Necessary for maintaining the secure and stable operation of the products and/or services provided, such as discovering and handling faults of the products and/or services;

l  Necessary for legitimate news reporting;

l  Necessary for academic research institutions to conduct statistical or academic research based on public interests, and when providing the results of academic research or descriptions to the outside world, the personal information contained in the results is de-identified;

l  Other circumstances stipulated by laws and regulations.

· Under what circumstances we share your information

We will not share your personal information with companies, organizations, or individuals outside of CLOU, except in the following cases:

l  Sharing under statutory circumstances: We may share your personal information externally as required by laws and regulations, for litigation dispute resolution needs, or in accordance with legally made requests by administrative or judicial authorities.

l  Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

l  Sharing among affiliated companies: To facilitate our provision of products and services to you, identify account abnormalities, and protect the personal and property safety of other users or the public from infringement, your personal information may be shared with our affiliated companies and/or their designated service providers. We will only share necessary personal information, and it will be bound by the purposes stated in this Agreement. If we share your sensitive personal information or if affiliated companies change the purpose of personal information use and processing, we will seek your authorization and consent again.

l  Sharing with authorized partners: We may entrust authorized partners to provide you with certain services or perform functions on our behalf. We will only share your information for the lawful, legitimate, necessary, specific, and clear purposes stated in this Agreement. Authorized partners can only access the information necessary for them to perform their duties and may not use this information for any other purpose. We do not need to separately notify you or obtain your consent for the use and sharing of such processed data.

Currently, our authorized partners include the following types:

l  Authorized partners for advertising and analytics services. Please be aware that to provide you with more convenient, high-quality, and personalized products and/or services and enhance your user experience, we may entrust these partners to process information related to advertising reach and effectiveness, but we will not provide your personally identifiable information, or we will de-identify this information so that it does not identify you personally. Such partners may combine the above information with other data they legally obtain to perform the advertising services entrusted by us or provide decision-making recommendations.

l  Suppliers, service providers, and other partners. We send information to suppliers, service providers, and other partners that support our business. This support includes providing technical infrastructure services entrusted by us, analyzing how our services are used, measuring the effectiveness of services, providing customer service, facilitating payments, or conducting academic research and surveys.

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

l  Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

l  In the event of merger, acquisition, or bankruptcy liquidation involving the service provider of the CLOU Platform, or other circumstances involving merger, acquisition, or bankruptcy liquidation, if personal information transfer is involved, we will require the new holder of your personal information to continue to be bound by this Agreement. Otherwise, we will require the company, organization, or individual to seek your authorization and consent again.

· How we store your information

l  Unless otherwise stipulated by law, the CLOU Platform will retain your information for the following periods:During your use of CLOU Platform products or services, we will continue to retain it for you, unless you actively delete information or deregister your CLOU account.

l  After you delete information or deregister your CLOU Platform account, the CLOU Platform will cease using your personal information and will delete your personal information within a certain period.

l  After anonymization and desensitization processing, your personal information will form usable circulation data. The CLOU Platform’s retention and use of this data does not require additional consent from you.

· How we protect your information

l  We have adopted reasonable and feasible security protection measures that comply with industry standards to protect your information and prevent personal information from unauthorized access, public disclosure, use, modification, damage, or loss. For example, data exchanged between your browser and the server is protected by SSL protocol encryption; we also provide HTTPS protocol secure browsing methods for various CLOU Platform websites; we use encryption technology to enhance the security of personal information; we use trusted protection mechanisms to prevent personal information from malicious attacks; we deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we conduct security and privacy protection training courses to strengthen employees’ awareness of the importance of protecting personal information.

l  The internet is not an absolutely secure environment. When using CLOU Platform products or services, we strongly recommend that you do not use communication methods not recommended by the CLOU Platform to send your information. You can establish contacts and share information with others through our services. When you create communications, transactions, or shares through our services, you can independently choose the objects of communication, transaction, or sharing, who, as third parties, can see your transaction content, contact information, communication information, shared content, and other related information.

l  In the unfortunate event of a personal information security incident, we will notify you in accordance with legal requirements: the basic situation of the security incident and its possible impact, the measures we have taken or will take to address it, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will inform you of the incident-related situation via email, letter, phone, push notification, etc. If it is difficult to inform each personal information subject individually, we will adopt reasonable and effective methods to publish an announcement. At the same time, we will also report the handling of the personal information security incident to the supervisory authorities as required.

· The rights you are entitled to

l  You have the right to manage your information, including:Access your personal information:

l  Account information: If you wish to access or edit the personal profile information in your account, change your password, recipe preferences, etc., you can access your information through settings after logging into your account.

l  Other personal information (e.g., when using services like the mall, after-sales, installation/repair registration, etc.): For personal information generated during your use of our products or services, if needed, you can contact us through the contact methods in Chapter 9.

l  Correct your personal information

l  When you find errors in our processing of your personal information, you have the right to request us to make corrections or supplements. You can make corrections or provide supplementary explanations through the personal information settings page or contact us directly.Delete your personal information

l  In the following circumstances, you can contact CLOU Platform customer service to request deletion of personal information:If our processing of personal information violates laws and regulations.

l  If we collect or use your personal information without obtaining your explicit consent.

l  If our processing of personal information seriously violates our agreement with you.

l  If you no longer need to use our products and services, or you have actively deregistered your CLOU account.

l  If you permanently no longer need us to provide products or services.

If we decide to respond to your deletion request, we will cease providing you with products or services and delete your personal information in accordance with applicable legal requirements.

l  Right to withdraw consent

When we rely on your consent to process data, you have the right to withdraw that consent at any time, specifically by deregistering your CLOU account to withdraw your consent.· Account deregistration by the personal information subject

l  You can deregister your previously registered account at any time. If needed, you can contact us through the contact methods in Chapter 9 to request deregistration of your account as the personal information subject.

l  After you deregister your account, we will stop providing you with products or services and, upon your request, delete your personal information.

· How the personal information of minors is protected

l  Our products and services are primarily aimed at adults. For cases where we collect the personal information of minors with the consent of their legal guardian, we will only use or publicly disclose the legally collected personal information of minors when permitted by law, with the explicit consent of the legal guardian, or when necessary to protect the minor.

l  If we discover that we have collected the personal information of a minor without prior consent from the legal guardian, we will endeavor to delete the relevant data as soon as possible. If a legal guardian has reason to believe that a minor has submitted personal information to the CLOU Platform without their prior consent, please contact us to ensure the deletion of such personal information and to ensure the minor unsubscribes from any applicable CLOU services.

· How to contact us

l  If you have any questions, comments, or suggestions regarding this Privacy Agreement, or if you wish to exercise any rights, or if you have any requests to discuss with us, please contact the department responsible for personal information protection matters through the following methods:

l  CLOU Platform service provider: [Shenzhen CLOU Electronic Technology Co., Ltd.]

l  Address: CLOU Building, Baoshen Road, North District of Science and Technology Park, Nanshan District, Shenzhen City, Guangdong Province, China

l  Service Hotline: 0755-33309999

l  For security purposes, you may need to provide a written request or prove your identity in other ways. Generally, we will respond within 15 days. If you are dissatisfied with our response, especially if you believe our personal information processing activities have infringed upon your legitimate rights and interests, you may also complain or report to regulatory authorities such as cyberspace administration, telecommunications, public security, and market supervision.

l  If you are dissatisfied with our response, particularly if you believe our personal information processing activities have harmed your legitimate rights and interests, you can also seek a solution by filing a lawsuit with the competent court in the jurisdiction of the defendant’s domicile.

[CLOU]

Update Date: 2023.08.22

Effective Date: 2023.08.22