Privacy Policy Statement

Last Updated: August 27, 2022

Effective Date: August 28, 2022

Notice

Adhering to the principle of user privacy and information security as a top priority, ZHENYUN Technology is committed to providing high-quality cloud services to users worldwide. This Privacy Policy Statement (“Statement”) aims to inform you how ZHENYUN Technology collects, uses, stores, and deletes your personal information when providing SRM services, and to outline your rights regarding your personal information. ZHENYUN Technology attaches great importance to your privacy and will take all necessary measures to protect your personal information and privacy rights. This Statement applies if you register an account, use the platform, or conduct business on the ZHENYUN SRM platform. In addition, ZHENYUN may issue targeted privacy statements for specific products or services.

If our services contain links to third-party websites, applications, or services, this Statement does not apply to any products, services, websites, or content provided by those third parties. If your company or other business entity uses our products or services to provide services to your clients, you are responsible for issuing a personal information protection statement appropriate to your business context.

ZHENYUN Technology kindly reminds you to carefully read and understand this Privacy Policy before using any of our products or services. By confirming that you fully understand and agree to this Statement, you may use the relevant products and services. Once you begin using ZHENYUN’s products or services, you are deemed to have accepted and agreed to the terms of this Statement, and your use of the website or client applications constitutes your consent to the collection and use of information as described herein.

If you have any questions, comments, or suggestions, please contact us via:

Customer Service Hotline: 400-116-0808

Email: marketing@going-link.com

Part 1: Definitions and Statements

Definitions

1)ZHENYUN: Refers to Shanghai ZHENYUN Information Technology Co., Ltd., with its registered address at Room 046, Area A, 1st Floor, Building 3, No. 7, Jiayi Village, Xianghuaqiao Subdistrict, Qingpu District, Shanghai, China.

2)SRM: Refers to the innovative one-stop procurement management platform developed by Shanghai ZHENYUN Information Technology Co., Ltd., providing a complete solution for the digitalization of enterprise procurement processes. The software copyright of this product belongs to Shanghai ZHENYUN Information Technology Co., Ltd.

Statements

1)The ZHENYUN SRM platform does not provide products or services to minors under the age of 18. By agreeing to this Policy and applying to access relevant features, you represent and warrant that you are a natural person with full civil capacity and full civil conduct capacity, capable of independently assuming civil liability. If you do not meet the above conditions, you should immediately cease using or applying for the Service.

2) The ZHENYUN SRM platform is an enterprise-level digital business platform based on SaaS (Software as a Service). This Statement explains the personal information that may be collected, the purposes of collection, the methods of collection, and the potential consequences of refusing to provide personal information.

3)This Statement also explains the device permissions that the ZHENYUN SRM platform may require, the purposes of accessing such permissions, the corresponding business functionalities, whether prior consent is requested, and how users can disable such permissions. Please note that by agreeing to this Policy, the corresponding device permissions will not be automatically enabled. For important or sensitive device permissions, a separate prompt will be presented when you use the relevant functionality, requesting your explicit consent before activation. Once granted, you may disable these permissions at any time via your device settings. Your refusal to enable certain permissions will not affect the normal use of other unrelated business functionalities.

Table of Contents of This Statement:

1.What Personal Information We Collect

2.The Purpose of Collecting Personal Information

3.The Cookies We Use

4.How We Use Your Personal Information

5.How We Store, Share, Transfer, and Disclose Your Personal Information

6.6.How We Protect the Security of Your Personal Information

7.How Long We Retain Your Personal Information

8.Your Rights Regarding Personal Information

9.How We Protect Minors’ Personal Information

10.Changes to This Statement

11.Questions, Concerns, or Complaints

1.What Personal Information We Collect

1.1 Personal information refers to various information recorded electronically or by other means that relates to an identified or identifiable natural person.

1.2 When you register and conduct business on the ZHENYUN SRM platform, we may collect and use the following personal information from you:

(1) Platform Modules (including registration, login, workflow, personalization, etc.) When using platform module services, you are required to provide your phone number, email address, full name, avatar, nickname, gender, date of birth, region, country, and detailed address. This information is used for account registration, system login, and message notifications.

(2) Collaboration Modules (including demand, orders, logistics, quality, etc.) When using collaboration module services, you are required to provide your phone number, telephone, email, full name, address, and vehicle license plate number. This information is used for creating business documents and for shipping and receiving purposes.

(3)Sourcing Modules

When using sourcing module services, you are required to provide your phone number, telephone, email, full name, gender, identification number (including ID card, passport, Mainland Travel Permit for Hong Kong and Macao Residents, Mainland Travel Permit for Taiwan Residents, etc.), professional achievements, work experience, and educational background. This information is used for business cooperation between enterprises. Identification numbers, professional achievements, work experience, and educational background are required for expert registration.

(4) Supplier Modules

When using supplier module services, you are required to provide your phone number, telephone, email, full name, address, gender, identification number (including ID card, passport, Mainland Travel Permit for Hong Kong and Macao Residents, Mainland Travel Permit for Taiwan Residents, etc.), and bank account number. This information is used for business cooperation between enterprises. Identification numbers and bank account numbers are required for supplier registration and verification.

(5) Marketplace Modules

When using marketplace module services, you are required to provide your phone number, email, full name, and address. This information is used for shipping and receiving purposes.

(6) Digital Intelligence Modules (including intelligent applications, data reports, application marketplace, etc.) When using digital intelligence module services, you are required to provide your phone number, email, and full name. This information is used for business communication.

(7)Others:

a)Electronic Signing. Before using certain products and/or services, you may be required to complete electronic signing through our online electronic signing system. In accordance with applicable laws and regulations, we may collect your personal identification information, personal biometric information, and personal financial information during the use of this system, including: the electronic contract text, signer information (signer’s name, address, and contact number), signer’s ID number, facial recognition features, and bank account number. In addition, we may collect other electronic signing-related information, including contract amount, signing time, contract number, and contract status. This information is collected to help you complete the electronic signing process smoothly, ensure the security of your signing, enable contract inquiries, and provide contract management services.

b) Payments. When making payments in scenarios such as purchasing goods, you will need to use the payment function. During the payment process, we may collect your user ID from third-party payment channels (e.g., Alipay user ID, WeChat OpenID, QQ Wallet OpenID, or bank card information). This information is necessary for providing the purchased goods and/or services. We cannot obtain your personal financial information solely from this data, nor can we identify you as a specific natural person.

c) Third-Party Login Information. Depending on the scenario and your choices, third-party login may require your authorization to access your device camera, facial recognition, photo albums, contacts, SIM or IMEI information, or login via WeChat, QQ, or fingerprint authentication. If you do not provide such information, SRM cannot use the convenient third-party login option; you may continue logging in with your account and password. The SRM mobile application may also collect your location or preferred communication method. Unless combined with personal data, this information cannot identify you or any other user of the website.

d) Information from Other Sources. To improve our ability to provide marketing, promotions, and services, we may obtain information about you from other sources, such as public databases, co-marketing partners, social media platforms, and other third parties.

e) Device Tracking Information. Most browsers or devices automatically collect certain information, such as your media access control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version, and the name and version of the site or application you are using. Your IP address is a number automatically assigned to your computer by your Internet Service Provider (ISP). Whenever you access the site, your IP address, access time, and visited pages can be automatically recorded in our server logs. ZHENYUN uses IP addresses to calculate site usage, help diagnose server issues, manage the site, and monitor the regions navigating to ZHENYUN sites.

f) Information of Other Users. If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing such information to ZHENYUN.

g) Exceptions to Obtaining Consent. Certain situations may exist where prior consent is not required, as permitted by applicable laws and regulations.

1.3 You fully understand and agree that, in accordance with applicable laws and regulations, ZHENYUN may collect and use your personal information without obtaining your authorization or consent under the following circumstances:

a)When it concerns national security or defense security;

b)When it concerns public safety, public health, or other significant public interests;

c)When it is related to criminal investigation, prosecution, trial, or execution of judgments;

d)When it is necessary to protect the life, property, or other major lawful rights and interests of the personal information subject or other individuals, but obtaining your consent is impractical;

e)When the personal information has been voluntarily disclosed by you to the public;

f)When the personal information is collected from legally publicly available sources, such as legitimate news reports or government information disclosures;

g)When it is necessary for signing or performing agreements or other written documents with you;

h)When it is necessary to maintain the secure and stable operation of the provided products or services, such as detecting and handling product or service failures;

i)When academic research institutions conduct statistics or research in the public interest, and personal information included in the research results is de-identified before being disclosed externally;

j)Other circumstances as stipulated by laws and regulations.

Please note that, under applicable laws, if we process personal information using technical measures or other necessary methods such that the data recipient cannot re-identify specific individuals or restore the data, or if we de-identify the collected information for research, statistical analysis, or predictive purposes—to improve ZHENYUN content and layout, support business decision-making, or enhance our products and services (including using anonymized data for machine learning or model training)—such use of processed data does not require separate notice or consent from you.

2.Purposes for Collecting Personal Information

ZHENYUN collects your personal information for the following purposes. If we intend to use the collected information for purposes not stated in this Privacy Policy, we will obtain your prior consent and authorization:

(1) To provide, maintain, and improve our products or services;

(2) To send you important notifications regarding system security, product or service updates, and other relevant information;

(3) To activate or verify products or services;

(4) To comply with applicable laws or relevant industry standards. For example, if the law requires real-name verification, collected information, including bank card numbers, will only be used for real-name authentication and will not be used for other purposes;

(5) To provide logistics services, which require your contact information and address;

(6) To protect the technical security of our products, services, and user information;

(7) Other purposes authorized by you.

If you have any concerns about the purposes of data processing or wish for us to stop using your data in one or more of these ways, please contact our customer service team.

3.Cookies We Use

3.1 To ensure the normal operation of the website, we store small data files called cookies on your computer or mobile device. Cookies typically contain identifiers, site names, and some numbers and characters. ZHENYUN SRM can only read the cookies provided by ZHENYUN SRM.

3.2 The purposes for which we enable cookies are the same as those for most websites or internet service providers, namely, to improve user experience. Specifically, cookies are used for the following purposes:

(1)Preferences: Cookies allow the website to save settings, such as language, font size, and other browsing preferences on your computer or mobile device. This means users do not need to reconfigure their preferences every time they visit the site.

(2)Authentication: When you access and log in to ZHENYUN SRM, we generate a unique identifier to recognize your identity. Without cookies with this function, users will not be able to log in properly.

(3)Analytics: We use cookies to count the number of users visiting the site and to understand your sources of access.

(4)Security: We use cookies to ensure the safe operation of the website.

3.3 We will not use cookies for any purposes other than those described in this Privacy Policy. You may manage or delete cookies according to your preferences. You can clear all cookies stored on your computer, and most web browsers provide the ability to block cookies. However, if you do so, you will need to manually adjust your settings each time you visit our website. For detailed instructions on changing browser settings, please refer to the relevant settings page of the browser you are using.

4.How We Use Your Personal Information

We use your personal information for the following purposes:

1、Responding to your inquiries and fulfilling your requests, such as sending you requested materials, newsletters, and information or content regarding our products and services.

2、Sending you administrative information, such as information related to the Sites and changes to our terms, conditions, and statements.

3、Sending you marketing communications, in accordance with applicable laws and your preferences, including emails and text messages regarding products or services we believe may be of interest to you.

4、Personalizing your experience on the Sites, including by presenting tailored products, features, and promotional offers.

5、For our business purposes, including data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Sites and services, identifying usage trends, determining the effectiveness of promotional campaigns, and operating and expanding our business activities.

6、We may use and disclose your personal information:

(a)to comply with applicable laws, including laws outside your country/region of residence;

(b)to comply with legal processes;

(c)to respond to requests from public or governmental authorities, including public or governmental authorities outside your country/region of residence;

(d) to enforce our terms and conditions;

(e)to protect our business or the business of any of our affiliates;

(f)to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others;

(g)6.to allow us to pursue available remedies or limit the damages we may sustain.

The legal basis for collecting and using the personal data described above depends on the specific personal data and the context in which we collect it. We collect and use your personal data where such processing is in our legitimate business interests, for example, directly marketing ZHENYUN applications to potential business-to-business (B2B) customers. In some circumstances, the legal basis may be your consent, or the processing may be necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract. In other circumstances, we may be required by legal obligation to collect personal data from you.

Where we request personal data in order to comply with a legal requirement or to enter into a contract with you, we will clearly inform you at the relevant time whether the provision of your personal data is mandatory, as well as the possible consequences if you choose not to provide such information.

5.How We Store, Share, Transfer, and Disclose Your Personal Information

5.1 Storage

ZHENYUN stores your personal information for the duration required by applicable laws and regulations or the retention period agreed under relevant contracts, in order to ensure your continued access to our products and services. Upon the expiration of such statutory or contractual retention periods, we will delete or anonymize your personal information.

Depending on your interaction with ZHENYUN products, your personal information may be stored in the country or region specified in the applicable user agreement. Where cross-border transfers of personal information are required, we will obtain your prior consent and ensure such transfers comply with this Privacy Policy and applicable personal information protection laws.

We may retain your information for a longer period only under the following circumstances and solely for the purposes related to them:

(1)To comply with applicable laws and regulations;

(2)To comply with court judgments, rulings, or other legal procedures;

(3)To comply with requests of relevant governmental or regulatory authorities;

(4)Where we have reasonable grounds to believe it is necessary to comply with laws or regulations;

(5)Where it is necessary for the purposes of enforcing relevant service agreements or this Privacy Policy, safeguarding public interests, handling complaints/disputes, or protecting the personal and property safety or other lawful rights and interests of our customers, other users, our employees, or our affiliates.

5.2 Sharing

We will not share your personal information with any company, organization, or individual outside of ZHENYUN, except under the following circumstances:

5.2.1 Subsidiaries and Affiliates

We may disclose personal information to our subsidiaries and affiliates for the purposes stated in this Privacy Policy. Before sharing such information, we will obtain your consent, and only after receiving your explicit authorization will we share your personal information with these parties.

5.2.2 Third-Party Business Partners

To provide you with more comprehensive and high-quality products and services, certain services may be provided by our authorized partners. We may share some of your personal information with such partners in order to offer better customer services and user experience. We will only share your personal information for lawful, justified, necessary, specific, and explicit purposes, and only the minimum personal information required to provide the relevant services. Meanwhile, we will enter into strict confidentiality agreements with our partners, requiring them to process your personal information in accordance with our instructions, this Privacy Policy, and other relevant confidentiality and security measures. Our partners shall not use the shared personal information for any other purposes.

If you choose not to provide necessary personal information required by our partners in order to deliver certain services, you may be unable to use such third-party services on our platform.Typically, our partners fall into the following categories:

(1)Service providers offering functional support for our products and/or services: for example, payment institutions providing payment services, third-party companies providing delivery services, and other service providers. We share information solely for the purpose of enabling the functions of our products and/or services.

(2)Third-party merchants on our platform: to fulfill your purchase of products or services (including after-sales support), we will share your order and transaction-related information with third-party merchants on our platform (e.g., JD.com, Suning, ZKH Industrial Supermarket).

(3)Third-party SDK services: our products may contain third-party SDKs or similar applications. When you use services provided by third parties through our platform, you agree that such third parties may directly collect and process your information (e.g., through embedded code or plug-ins). For details about third-party SDKs currently integrated into our products, please refer to the “ZHENYUN SRM Third-Party SDK Directory.” The information collection and processing activities of such service providers are governed by their own privacy policies, rather than this Privacy Policy. To better protect your information, we recommend that you review their privacy terms before using any third-party SDK services. If you identify risks associated with such SDKs or applications, we suggest that you immediately discontinue use and contact us promptly.

(4)Marketing and advertising partners: You acknowledge and agree that we may share indirect user profiles and de-identified or anonymized analytical/statistical information derived from your information with partners who entrust us with marketing and advertising activities. This allows them to improve advertising effectiveness, offer decision-making support, and better understand user needs. We commit that we will not share personal information that can identify you without your explicit consent.

(5)Agents and service providers engaged by us: We engage other companies and individuals to perform tasks on our behalf and may share personal data with them in order to provide products or services to you or communicate with you (e.g., removing duplicate customer information, data analysis, marketing support, billing, payment processing, technical support, and customer services). We also provide your personal data for verification or aggregated usage analysis to partners. When we share such information, we require such parties to maintain the privacy, confidentiality, and security of your personal data.

(6)ZHENYUN social media pages: You may disclose personal data through features such as websites, message boards, chat functions, profile pages, or other services where you can post information or materials. Such information may be publicly visible—e.g., via search engines or publicly accessible platforms—and may be crawled or captured by third parties. Please do not publish any information that you do not wish to be disclosed publicly.

(7)Protection of ZHENYUN and others: We may share personal data with law enforcement, tax authorities, fraud prevention agencies, credit risk institutions, and other organizations when we deem it necessary and appropriate to protect ZHENYUN, our affiliates, users, employees, or other individuals.

5.2.3 Others

We may share your personal information with third parties under other circumstances only with your explicit consent. After informing you of the third party’s name and the purpose of processing, and obtaining your explicit consent, ZHENYUN will share your personal information within the scope authorized by you.

5.3 Transfer of Personal Information

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

5.3.1 We will transfer your personal information to other parties after obtaining your explicit consent.

5.3.2 We may transfer your personal information based on a request initiated by you or your controller.

5.3.3 In the event of a merger, acquisition, or bankruptcy liquidation involving ZHENYUN and if such transaction involves the transfer of personal information, we will require the new entity holding your personal information to continue to be bound by this Privacy Policy. Otherwise, we will require such company, organization, or individual to obtain your explicit consent again.

5.4 Public Disclosure of Personal Information

We will only publicly disclose your personal information under the following circumstances:

5.4.1 With your explicit consent or based on your voluntary choice, we may publicly disclose your personal information.

5.4.2 If we determine that you have violated laws, regulations, or materially breached applicable agreements or rules of ZHENYUN, or if it is necessary to protect the personal and property safety of ZHENYUN’s users or the public, we may disclose your personal information (including relevant violations and measures taken against you) in accordance with laws and regulations or with your consent.

5.4.3 Disclosure Based on Law: We may publicly disclose your personal information when required by laws, legal procedures, litigation, or mandatory requests from government authorities.

Please note: When you voluntarily share or publicly disclose information while using our services, such information may involve your own or others’ personal or sensitive personal information (e.g., when you upload images containing personal information). Please carefully consider whether to share such information when using our services.

5.5 Exceptions to Consent for Sharing, Transferring, and Public Disclosure

We may share, transfer, or publicly disclose your personal information without obtaining your prior consent under the following circumstances:

(1) Where it is related to national security or national defense security;

(2) Where it is related to public safety, public health, or major public interests;

(3) Where it is related to criminal investigation, prosecution, trial, or enforcement of judgments;

(4) Where it is necessary to protect the life, property, or other significant lawful rights and interests of you or others and obtaining consent is difficult;

(5) Where your personal information is disclosed to the public by yourself;

(6) Where personal information is collected from legally and publicly disclosed information, such as legal news reports or government information disclosure.

Please be aware: According to applicable laws, if we take technical or other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot restore the data, then such processed data may be shared, transferred, or publicly disclosed without further notice to you or requiring your consent.

6.How We Protect Your Personal Information

ZHENYUN attaches great importance to the security of your information. We strive to implement various reasonable technical and administrative security measures to protect your user information from unauthorized access, public disclosure, use, modification, damage, or loss. We use encryption technology to enhance the security of user information; employ trusted protection mechanisms to prevent malicious attacks on user information; deploy access control mechanisms to ensure that only authorized personnel can access user information; and conduct security and privacy protection training to strengthen employees’ awareness of the importance of protecting user information.

Data exchanged between your browser and our servers is encrypted using SSL protocol. We also provide HTTPS protocol for secure browsing. Currently, our critical information systems have passed the Level 3 certification of China’s network security protection standards. To more effectively safeguard your information, we also encourage you to strengthen your personal security awareness: please properly safeguard your account and password information, avoid leaking your personal information, and use complex, mixed passwords.

We will make every effort to ensure the security of any information you send to us. Although we take reasonable measures to protect your personal data from loss, misuse, interference, and unauthorized access, modification, and disclosure, you should be aware that no security program or protocol can guarantee 100% protection against intrusion or hacking, so sharing personal data online always carries some risk. If you have reason to believe that your interactions with us are no longer secure (for example, if you suspect that the security of your account has been compromised), please immediately notify us as described in the “Questions, Concerns, and Complaints” section below.

7.Retention Period of Your Personal Data

When you proactively deactivate your account, we will promptly anonymize or delete your personal information in accordance with applicable laws and regulations.

(一)Retention of Personal Information

1.Retention Timeframe: Unless otherwise required by laws and regulations or agreed between both parties, we will retain your personal information only for the shortest period necessary to achieve the purposes.

We will take reasonable and feasible measures to avoid collecting irrelevant personal information. We will only retain your personal information for the period necessary to achieve the purposes stated in this Privacy Policy, unless there are legally mandated retention requirements. The criteria we use to determine the retention period include:

1) To achieve the purposes related to your use and to respond to your possible inquiries;

2) To ensure the security and quality of services provided to you;

3) Whether you have agreed to a longer retention period;

4) Whether there are other specific agreements regarding the retention period.

Once your personal information exceeds the retention period, we will delete it or anonymize it in accordance with applicable laws.

2.Retention Location: Personal information collected and generated within the territory of the People’s Republic of China will be stored in China, except under the following circumstances:

a)Where required by laws and regulations;

b)Where explicit consent has been obtained from you;

c)Where you voluntarily disclose personal information to the public.

In such circumstances, we will ensure through contractual or other means that your personal information is protected at a level not lower than that set forth in this Privacy Policy.

If cross-border business is involved and it is necessary to transfer relevant personal information collected domestically to overseas institutions, ZHENYUN will take measures to ensure that the collected data is processed in accordance with this Privacy Policy and applicable laws. For example, when personal data of EU data subjects is transferred to countries or regions not recognized as having equivalent data protection levels by the EU, ZHENYUN will use legal mechanisms such as signing the EU Commission-approved Standard Contractual Clauses, obtaining your consent for cross-border transfer of personal data, or implementing data anonymization and other security measures prior to the cross-border transfer.

8.Your Personal Information Rights

ZHENYUN’s clients come from all over the world, and we strictly comply with the laws of the client’s country to protect their personal information rights. For example, we strictly adhere to the Civil Code of the People’s Republic of China, the Personal Information Protection Law of the People’s Republic of China, the EU General Data Protection Regulation (GDPR), and other applicable laws and regulations.

When the applicable conditions are met, you will enjoy the following rights:

8.1 Right to Refuse or Withdraw Consent

As a principle, we will obtain your consent and authorization before collecting information about you. If you do not agree to the collection of information, or if you consider it necessary to withdraw consent, we will stop collecting your personal information. However, this does not affect the legality of information collection conducted prior to your withdrawal of consent or authorization.

8.2 Right to Access and Copy

Except in cases otherwise provided by laws and regulations, you may access and copy the personal information we hold about you through the ZHENYUN SRM Personal Center.

8.3 Right to Rectification

If you find that your personal information is incorrect or incomplete, you have the right to update or correct it in the ZHENYUN SRM Personal Center.

8.4 Right to Deletion

You have the right to request that we delete the personal information collected about you, for example:

(1)The purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve the processing purpose;

(2)ZHENYUN SRM has stopped providing the product or service, or the retention period has expired;

(3)You withdraw consent;

(4)Personal information is processed in violation of laws, administrative regulations, or agreements;

(5)Other circumstances as stipulated by laws and administrative regulations.

In accordance with our contract with you, if it is no longer necessary to retain your personal information, or after you voluntarily deactivate your account, we will stop providing products or services to you and delete, anonymize, or de-identify your personal information in accordance with applicable laws.

8.5 Right to Object to Processing

You have the right to request that we stop processing your personal information or stop sending you marketing communications.

8.6 Right to Restrict Processing

You have the right, in certain circumstances, to request that we restrict the processing of your personal information. For example, if you believe that the personal information we hold about you is inaccurate or processed unlawfully.

8.7 Rights Regarding Automated Individual Decisions and User Profiling

When we employ automated decision-making technologies or conduct user profiling, we will obtain your prior consent or make relevant arrangements in the contract. If these decisions significantly affect your lawful rights and interests, please contact us via the contact information provided.

8.8 Right to Data Portability

Subject to applicable laws, regulations, and technical feasibility, we will, upon your request, transfer the personal information you provided or that we collected based on contract or consent to a designated personal information processor.

8.9 Right to Lodge Complaints with Local Data Protection Authorities

If you are dissatisfied with our response, or believe that our processing of your personal information infringes your lawful rights, and we fail to provide a satisfactory reply or refuse to make improvements after your feedback, you may lodge a complaint with the relevant supervisory authority.

Specifically, if you are from the European Union, European Economic Area, or other countries and enjoy rights under local laws beyond those listed above, you may exercise such additional rights.

To exercise any of the above rights, please email us at marketing@going-link.com.

8.10 Right to Opt-Out

For non-administrative users, you may submit an opt-out request to your company, and the company administrator will decide on deletion. For administrative users, you may submit an opt-out request directly to ZHENYUN. Please note that ZHENYUN may delete your personal data provided that ZHENYUN has no legal obligation or legitimate interest to retain such data. Also note that if you request ZHENYUN to delete your personal data, you will no longer be able to use the ZHENYUN services corresponding to the deleted data.

If you encounter difficulties exercising the above rights, you may also submit your request to us via the contact methods provided in this policy. For security purposes, you may need to provide a written request or otherwise verify your identity. We may first require you to verify your identity before processing your request. After you submit a personal rights request, we will respond and review your request as quickly as possible and provide a response within 15 business days after verifying your user identity. If a delay is required due to the complexity of your request, we will inform you of the reason and expected timeline (usually 15 business days).

If you have any questions or concerns, you may contact us via online customer service, call our customer service hotline, or send an email to marketing@going-link.com.

9.How We Protect the Personal Information of Minors

9.1 我Our products and services are primarily intended for enterprises or adults. If you are a minor under the age of 18, you should have your parents or legal guardians carefully read this Privacy Policy and only use our products and services or provide information to us with their consent.

9.2 If you use our products or services with the consent of your parents or legal guardians, we will only collect, store, use, share, or delete the personal information of minors under 18 in circumstances permitted by laws and regulations, with the explicit consent of parents or guardians, or when necessary to protect the minor.

If you believe that we have mistakenly or inadvertently collected such information, please notify us at 400-116-0808 so that we can delete it from our servers.

10.Changes to This Privacy Policy

10.1 Our Privacy Policy will be updated periodically in accordance with legal revisions or changes in business development.

10.2 We will publish any changes to this policy on the SRM platform website.

10.3 For material changes, we will provide more prominent notifications (including sending emails for certain services to explain the specific changes to the Privacy Policy).。

10.4 Material changes to this policy include but are not limited to:

(1) Significant changes in our service model, such as changes in the purpose of personal information processing, types of personal information processed, or ways personal information is used;

(2) Major changes in ownership, organizational structure, or similar aspects, such as changes caused by business adjustments, bankruptcy, or mergers and acquisitions;

(3) Changes in the main recipients of shared, transferred, or publicly disclosed personal information;

(4) Significant changes in your rights regarding personal information processing and the ways to exercise those rights;

(5) Changes in the departments responsible for personal information security, contact methods, or complaint channels;

(6) Personal information security impact assessments indicating high risks.

We strongly recommend that you visit our SRM platform website regularly to review the Privacy Policy. Where required by applicable data protection laws, we will also seek your consent again for material changes.

11.Questions, Concerns, or Complaints

Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we, as the data controller, collect and process your information, you may send an email to marketing@going-link.com. Since email communication is not always secure, please do not include credit card information or other sensitive data in your emails.

ZHENYUN takes any privacy complaint seriously. All complaints will be assessed by the appropriate personnel to address any issues promptly and effectively. We request that you cooperate with us during this process and provide any relevant information we may need.

You may have the right to file a complaint with a data protection authority regarding our collection and use of your personal data. For more information, please contact your local data protection authority.