Privacy Policy

Transwarp Technology (Shanghai) Co., Ltd. having its registered address at 3rd Floor(Block A & Block B) and 11th Floor(Block B), No. 88 Hongcao Road, Xuhui District, Shanghai and its affiliates (collectively, "Transwarp", "we", "us" and "our") respect your privacy. Please read the following carefully to learn more about our Privacy Policy ("this Policy").

Please understand that we may update or modify this Policy from time to time according to the information processing situation in the future. Please refer to Chapter 9 How we update this Policy of this Policy for the scope of application and history version.

This Policy applies to our websites (including but not limited to www.transwarp.cn), products, and services that display or provide links to this Policy, except as otherwise indicated. This Policy does not apply to how third parties define personal information or how they use it. We encourage you to read their privacy policies and know your privacy rights before interacting with them.

This Policy describes how we handle personal information whether you interact with us on our websites or in person (including by phone or when using our products, or services), but it may not address all possible data processing scenarios. we may inform you of product- or service-specific data collection through supplementary policies or notices provided before collection.

If you have any questions, comments, or suggestions, please refer to Chapter 10.How to Contact Us in this Policy.

This Policy describes:

1.How We Collect & Use Your Personal Information

2.How We Use Cookies & Similar Technologies

3.How We Share & Disclose Your Personal Information (Third-Party Providers and Their Services)

4.How Long We Retains Your Personal Information

5.How to Access & Control Your Personal Information (Your Privacy Rights at Transwarp)

6. How We Protect Your Personal Information

7. How We Process the Personal Information of Children

8. How Your Personal Information Is Transferred

9. How We Update This Policy

10. How to Contact Us

1. How We Collect & Use Your Personal Information

At Transwarp, we believe strongly in fundamental privacy rights. That’s why we treat any data recorded electronically or in other ways that relate to an identified or identifiable individual as “personal information”. This means that data that directly identifies you — such as your name — is personal information, and also data that does not directly identify you, but that can reasonably be used to identify you — such as the serial number of your device — is personal information. Anonymized data is considered non-personal information for the purposes of this Policy. Sensitive information is a type of personal information. If revealed, it can leave an individual vulnerable to discrimination or harassment.

1.1 How We Collect Your Personal Information

We strive to collect only the personal information needed to provide a safe experience for users. Here are some examples of the types of personal information we may collect and use.

(a)Information you provide when applying for registration

When you create an account, we may collect your account information (email address and password), phone number, name, company name, occupation, and the business industry your company engaged in.

(b) Information you provide when inquiring about cooperation business

When you have any questions about our business or wish to cooperate with us, we may collect the query information you provide, including your account information (email address and password), phone number, name, company name, occupation, and the business industry your company engaged in.

(c)Information you provide when submitting a resume

When you submit a resume on our website to apply for jobs, we may collect your name, phone number, email address, and other content of the resume you send us.

(d)Information you provide when completing real-name verification

When you enter and submit the required information to complete real-name verification, we may collect your legal name, selfie, certificate image of resident identity cards, and other information required by the verification authority

(e)Information you provide when conducting a transaction

When you conduct a transaction, we may collect information about the transaction information (including the date, time, and amount of the transaction, a description of the goods or services purchased, the type of payment method used and other information associated with the transaction, if any), and bank account information to process your transaction.

(f)Information you provide when applying for an event

When you apply to attend an onsite or virtual event, we may collect your name, phone number, and email address.

(g)Necessary Information processing on our websites

When you visit our website and use related functions, we may collect the necessary personal information to realize these functions and business processes.

•Device Information. Data from which your device could be identified, such as device serial number, or about your device, such as browser type.

•Usage Data. Data about your activity on and use of our offerings, such as app launches within our services, including browsing history; search history; product interaction; crash data, performance and other diagnostic data; and other usage data.

(h)Information you provide when applying for delivery services

When an invoice, contract, or gift is to be sent to you, we may collect your contact information (including your name, phone number, email address, physical address, or other contact information needed).

(i)Information you provide when adjusting your security settings

When you reset your password, we may collect your account information, including your email address, phone number, and new password.

(j)Information you provide when applying for service support

When you contact us for service support or submit in-sales, or after-sales service requests, you should provide the necessary personal information to verify your identity to protect the security of your account and system.

To contact you and provide services as soon as possible, we may collect your contact information (including your name, phone number, email address and company name) and records of your communication/call with us and relevant content (including order information, and other information you provide to prove relevant facts,). If you have inquiries, complaints, or suggestions regarding specific orders. Due to the reasonable need to provide services and improve service quality, we may record the solutions and results of relevant problems.

(k)Other information you provide to us

For example, when you use our services, we collect personal information that is included in the input, file uploads, or feedback that you provide to our services.

In the above scenario, your sensitive personal information may be involved, including your identity certificate, detailed physical address, payment information (bank account details and transaction history) and invoice information, for identity verification purposes, depending on the requirements of relevant laws and regulations for network real-name authentication, or for purposes of providing support services, invoicing, delivering products, managing event registrations, etc.

1.2 How We Use Your Personal Information

We may use your personal information for the following purposes:

(a)Creating and managing your account.

(b)Sending you important notices, such as installation of and updates to the operating system or application, communications about purchases, and changes to our terms, conditions, and policies. From time to time, we may use your personal information to send important notices. because this information is important to your interaction with us, you may not opt out of receiving these important notices.

(c)Fulfilling the contractual obligations that we are responsible for you, such as delivering, activating, or verifying products or services, providing training and certification, managing and processing training and certification exams, providing technical security support, responding to or fulfilling your transaction or service requests(for example, order requests and your requests for changes or providing you with the requested information), qualifying and managing suppliers and business partners, and communicating or working with suppliers and business partners.

(d)Responding to your communications. When you visit our website, participate in online or offline activities, apply for your requests for changes or provide you with the requested information (such as marketing materials for products and services, and white papers) and contact us for technical support or with your inquiries, complaints, or suggestions, we may reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback.

(e)Recommending products and services to you, such as sending you information about products and services that may interest you with your consent; inviting you to participate in Transwarp activities (including promotional activities), market surveys, or satisfaction surveys; or sending you marketing information. If you do not want to receive these types of information, you can opt-out at any time at the Transwarp Customer Request Service Platform（https://kb.transwarp.cn/posts/641）.

(f)Providing you with personalized user experience and content. We may track or analyze statistical data by fully automated or semi-automated solution and provide you with personalized user experience and content based on it with your consent. If you do not want to receive these types of information, you can opt-out at any time at the Transwarp Customer Request Service Platform（https://kb.transwarp.cn/posts/641）.

(g)Analyzing the efficiency of our business operations and evaluating market share. We may also collect and use non-personally identifiable information (non-PII), which cannot be used to identify a particular individual. For example, we may collect and analyze statistical data, such as the number of visits to its website and the characteristics, attributes, and behavior of website visitors, to understand how users use our websites, products, and services so that we can improve our services and better satisfy your needs. Meanwhile, we may collect, use, process, transfer or disclose non-PII for other purposes at our discretion. We will endeavor to isolate your personal information from non-PII and ensure that the two types of data are used separately. If personal information is combined with non-PII, it will still be treated as personal information during processing.

(h)Synchronizing, sharing, and storing the data you upload or download, and the data needed for the uploading and downloading.

(i)ensuring operational excellence, security, reliability, performance efficiency, and cost optimization of services and products, such as troubleshooting when you send us error reports, improving our products and services through internal audits, data analysis, and research, ensuring the security of our products, services and customers or users, executing and improving our loss prevention and anti-fraud programs, complying with and enforcing applicable legal requirements, industry standards, and our policies.

(j)Improving our services and conduct research.

(k)Developing new programs and services.

We may process your personal information following the requirements of applicable laws on an appropriate legal basis, including:

(a)Processing your personal information to fulfill the contract when responding to a transaction or service request.

(b)Processing your personal information with your consent.

(c)Processing based on the legitimate interests of Transwarp or a third party when we use your personal information to contact you, conduct marketing or market surveys, improve our products and services, execute and improve our loss prevention and anti-fraud programs, and other purposes. Legitimate interests include enabling us to more effectively manage and operate our business and provide our products and services; protecting the security of our businesses, systems, products, services, and customers; internal management; complying with internal policies and processes; and other legitimate interests described in this Policy.

(d)Processing your personal information as necessary to comply with and fulfill legal obligations.

2. How We Use Cookies & Similar Technologies

To ensure the website's daily operation, a small data file known as a Cookie will be stored on your computer or mobile device. We will not use Cookies for any purposes other than those stated in this Policy.

2.1 Cookie

Cookies are small files placed on your computer or mobile device when you visit a website. The content of a Cookie can be retrieved and read only by the server that created the Cookie. Cookies are unique to the browser or mobile application you are using. Cookies serve different purposes, like helping us understand how our website is being used, letting you navigate between pages efficiently, and remembering your preferences. Using Cookies, we can provide you with more thoughtful services and generally improve your browsing experience.

We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer or mobile device for six months, or until you withdraw your consent or delete them, as applicable). We use three broad categories of Cookies:

(a) Essential Cookies: we use Cookies to store user authentication information and authenticate the user if the user logs in to a secure area of our website. This results in faster and more convenient access since, for example, you don't have to log in again.

(b) Personalization Cookies: we use Cookies to store your preferences and settings, such as the language setting and font size on your computer or mobile device, items in your shopping cart, and other browser preferences.

(c) Analytic Cookies: we collect information about your use of the Services, either for a single visit (using a session Cookie) or for repeated visits (using a persistent Cookie). These Cookies help us understand how the services of our website are performing and being used.

Many of the services of our website require Cookies to operate. If you choose not to allow Cookies related to these services, you may not be able to use those services or certain features of the services.

2.2 Other Similar Technologies

In addition to Cookies, we may use other technologies to collect information automatically. We may use browser web storage (including via HTML5), also known as locally stored objects (“LSOs”), for similar purposes as Cookie. Browser web storage enables the storage of a larger amount of data than Cookie. Your web browser may provide the functionality to clear your browser’s web storage.

2.3 Do Not Track

Many web browsers provide a Do Not Track function that can release Do Not Track requests to websites. Currently, major Internet standards organizations have not established policies to specify how websites should handle these requests. If you enable Do Not Track or other similar functions your browser may provide, we will not change the way we collect and use your data as described in this Cookie Policy and our Privacy Statement. However, we reserve the right to respond to your Do Not Track request and stop the collection of your data without prior notice to you.

2.4 Your Choices

Cookies can be managed or deleted, based on your preferences. The process for enabling or disabling browser Cookies may vary, depending on the web browser you use. In most cases, you can clear all Cookies saved on your computer, and web browsers can block Cookies. Please refer to the instructions in your browser settings for further details.

Many browsers accept Cookies by default until you change your settings. However, if you do not accept or block our Cookies, you may experience some inconvenience in your use of our website. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit the Website and re-configure any personalized settings every time you visit our website, and such features may prevent you from being able to log in or make use of Cookie-dependent services or functions.

3. How We Share & Disclose Your Personal Information (Third-Party Providers and Their Services)

3.1 How We Share Your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances:

(a) sharing with your consent: we will share your personal information with third parties after obtaining your explicit consent.

(b) sharing with authorized partners: we may share some of your information with our partners or enable partners to collect information directly via the Services, such as your billing information, account information, and device Information.

Your information will only be processed for specific, clear, and lawful purposes, and only the necessary information for providing such services will be shared. Please refer to the Third-Party List for details. To implement our services and/or other reasonable purposes, our authorized partners may include:

• third-party vendors: Some Services may be provided directly by third-party providers. In such cases, we may share some of your information (such as contact/account information, device Information, and order/transaction information, if any) with our partners to achieve the committed purpose of personal information in this Policy to fulfill the transaction, after-sales service or service delivery. For example, due to Chinese express and delivery regulations, we must share your information (your name, contact address, phone number) with logistics service providers to arrange the delivery of gifts to you (if any), or arrange partners to provide the service.

• Service providers and professional advisors: We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the website and the services (such as supply, payment, marketing, data analytics, and compliance assessment). We share such data only for purposes consistent with this Policy or under your authorization. For example, we may need to share your order information with logistic service providers to arrange delivery, and we may need to share your payment information with payment service providers in order to confirm and proceed with your payment instructions. We may share your personal information with professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

(c) For compliance, fraud prevention. and security. we may share your information with other parties as required under laws and regulations, by litigation and dispute resolution request, or as required by an administration or law enforcement agency. We may also share your related information with the designated third party by network real-name authentication requirements. We may also share your personal information to protect the rights or property of Transwarp and protecting our customers and/or the public. For example, we may share your personal information, when we believe sharing is necessary or appropriate to prevent or defend against cyber threat, fraud, physical harm, or financial loss, or when it is in connection with an investigation of suspected or actual illegal activity.

(d) Sharing information publicly available or previously published

(e) Sharing with Transwarp affiliates and subsidiaries. We may share your personal information with our affiliates including Transwarp Industry Technology Development Institute; Transwarp Technology (Beijing) Co., Ltd., Transwarp Technology (Nanjing) intelligence Co., Ltd., Transwarp Technology (Nanjing) Co., Ltd. located in China, for purposes of transactions support, Services support, delivery and maintenance support, customer service support and technical support or security support, and other reasonable purposes, to the extent required by the Services.

3.2 How We Disclose Your Personal Information

To comply with applicable laws or respond to valid legal procedures, we may also disclose your personal information to law enforcement or other government agencies. We may also disclose your data when appropriate, for example, when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or when it is in connection with an investigation of suspected or actual illegal activity.

3.3The Third Party SDK

We may use third-party software development kits (“SDKs”) on our website, please see the Third Party SDK List for details. An SDK is third-party computer code that may be used for a variety of purposes, including to provide us with analytics regarding the use of our applications, to integrate with social media, to add features or functionality to our app, or to facilitate online advertising. SDKs may enable third parties to collect information directly via our website. We have no control over such third parties' privacy statements or practices, and this Policy does not apply to how the third parties process your personal information. Before providing your personal information to third parties, please check out their privacy policy.

4. How Long We Retain Your Personal Information

We will retain your personal information for no longer than is necessary for the purposes set out in this Policy unless otherwise required by laws or requested by you. The data storage period may vary depending on the processing purpose and the relevant service.

We will maintain your account information as long as is necessary for us to provide the services to you, to perform our obligations or exercise our rights under agreements related to the services. You can choose to close your account. After you close your account, we will stop providing you with the services and delete your relevant personal information within a reasonable time.

5. How to Access & Control Your Personal Information (Your Privacy Rights at Transwarp)

It is your responsibility to ensure that all personal information submitted to us is correct. We are dedicated to maintaining the accuracy and completeness of your personal information and keeping your personal information up-to-date based on the information you provide to us.

According to the applicable laws and regulations of some countries and/or regions, data subjects may have the rights to make requests (hereinafter referred to as “requests”) of accessing, correcting, deleting or erasing the personal information retained by us. You can easily access, correct, and amend the personal information relating to you, which we hold, as follows:

(a)Account information: If you want to add or update personal information related to your account, please access the Website and log in to your Account via Log in > My Account.

(b)Cookie: Regarding the management of Cookie, please see How We Use Cookies & Similar Technologies in this Policy.

(c)Messages: If you do not want to receive the message or you want to set your preferences, you can reach out at any time at Transwarp Customer Request Service Platform（https://kb.transwarp.cn/posts/641）.

You may have the following rights regarding your personal information under applicable laws:

(a) Right to access the personal information we hold about you and obtain copies thereof.

(b) Right to request us to update or correct your personal information.

(c) Right to request us to erase your personal information.

(d) Right to change the authorized personal information collection scope or withdraw your consent, meaning object/restrict to our processing of your personal information.

(e) Right to obtain your personal information and have us transfer it to a third party of your choice (data portability);

(f) Right to complain with the competent data protection authority.

Please note that these rights are not absolute and may be restricted by applicable laws. If you need our assistance to exercise the rights above, please contact us at the Transwarp Customer Request Service Platform（https://kb.transwarp.cn/posts/641）

Generally, we will respond to you within 30 days, unless otherwise required by applicable laws.

Depending on the complexity of your requests, we may extend the period by a further two months. In this case, we will inform you of the extension and its reasons within 30 days of receiving your request. Please note that under some circumstances, for example where we cannot verify your identity, where we are prohibited by law from giving effect to your request, or your request exceeds your rights under applicable laws, we may refuse your request. In this case, we will inform you in writing that your request is refused together with the reasons for our refusal.

6. How We Protect Your Personal Information

We take the security of your personal information seriously, avoiding unauthorized access, disclosure, use, modification, and loss or damage of data. We take appropriate physical, organizational, and technical measures to protect your personal information. For example:

(a)we ensure that the personal information collected is minimal and relevant to what is necessary about the purposes for which they are processed. We will only retain your personal information for no longer than is necessary for the purposes set out in this Policy, unless otherwise required by laws or requested by you.

(b)we deploy access control mechanisms to ensure that only authorized personnel can access your personal information.

(c)we strictly select business partners and service providers and incorporate personal information protection requirements into commercial contracts, audits, and appraisal activities.

(d)we raise awareness among employees about the importance of protecting personal information.

We are committed to protecting your personal information. Nevertheless, no security measure is perfect and no product, service, website, data transfer, computing system, or network connection is absolutely secure. While we take the utmost care to protect your personal information, please note that no security measures are completely infallible. Please keep your login information properly. If you find that your account is being used by others without your permission, please promptly notify us.

In the unfortunate scenario that our physical, technical, or management protection measures are damaged, we will promptly initiate contingency plans to prevent security incidents from expanding and will report to the national competent authority by the requirements of laws and regulations and inform you in time. The report includes the basic information and possible impact of the security incident, the actions taken or to be taken by us in response to the security incident, recommendations for personal risk prevention and mitigation, and any remedial actions to you. We will notify you of such incidents via mail, letter, and telephone. If it is infeasible to notify each user, we will issue a public notice reasonably and effectively.

7. How We Process Personal Information of Children

Our products, websites, and services primarily target adults interested in our products and businesses. If you are a minor, you may use our services only with the involvement of a parent or guardian. Minors under the age of 14 are not allowed to create their user account without the consent of a parent or guardian.

If a minor under the age of 14 provides us personal information with the consent of their parents or guardians, we shall collect, use or disclose such personal information by the following requirements of laws and regulations.

(a)Necessary for protection to minors under the age of 14.

(b)Within the scope of the explicit consent of the parents or guardians.

The website does not attempt to collect any personal information of minors. If we discover that we have collected a minor's personal information without the permission of their parents or guardians , we will delete such information as soon as possible.

8. How Your Personal Information Is Transferred

For Chinese mainland users, the personal information that we collect and generate in China will be stored on servers within the Chinese mainland.

9. How we update this Policy

Update history:

Last updated: March 12, 2024; You can see what is updated in the Privacy History Version, if any.

We reserve the right, at its sole discretion, to update or modify this Policy from time to time. If we update this Policy, we will post the latest version of the policy on the Website or otherwise notify you through different channels, for example, by setting a pop-up on our website or sending you noticeable notifications via e-mail or other means. For material changes, we will notify you and require your consent through the appropriate channels. The modified terms will come into effect immediately upon posting. You understand and confirm that if you do not agree to the updated content, you should immediately stop using the corresponding services, and we will stop collecting your relevant personal information. If you continue to use the service, you accept the update. Your continued use of our service following the posting of changes will mean that you accept and agree to the changes.

10. How to Contact Us

If you have any questions, comments, or suggestions, please contact us at privacy@transwarp.io. You can also raise a concern or complain with a data protection authority or other official with jurisdiction.

Notice

This policy does not apply to Your Content that we process as a provider of our website and our services, on behalf of our customers as their data processor. "Your Content"covers all data (including personal information), software, devices, text, images, video, audio, photos, third-party applications, and materials that you entrust to our website and our services.