Privacy Policy

Effective Date: March 30, 2026

Last Updated: March 30, 2026

Introduction

Shanghai Zhenyun Information Technology Co., Ltd. (“we,” “us,” or “our”) is committed to protecting your privacy.

This Privacy Policy explains how we collect, use, store, and transfer your personal information when you interact with our website, including when you submit information through online forms. It also outlines your rights regarding your personal information.

This Privacy Policy forms an integral part of our terms governing the processing of your personal information. We are committed to handling your data in a transparent and responsible manner, ensuring your right to be informed and your ability to exercise oversight.

1. Information We Collect

When you interact with our website (e.g., by submitting forms or engaging with content), we may collect the following categories of personal information:

1.1 Identity and Contact Information

(1)Full name

(2)Phone number

(3)Company name

(4)Job title

(5)Message or additional information you provide

1.2 Technical and Device Information

(1)IP address

(2)Device model

(3)Operating system and version

1.3 Usage and Interaction Information

(1)Date and time of access

(2)Type of inquiry or submission

(3)Pages visited and buttons clicked

(4)Referral source (e.g., marketing channels)

(5)Search keywords

(6)Whether the visit was generated through promotional activities

1.4 Approximate Location Information

General geographic location inferred from your IP address

2. Purposes and Legal Basis for Processing

We process your personal information based on your consent and other applicable legal bases under relevant data protection laws, for the following purposes:

2.1 Business Communication

To identify you and respond to your inquiries regarding our products or services.

2.2 Operations and Website Optimization

To analyze search keywords, traffic sources, and user behavior in order to evaluate marketing performance and improve our website experience.

2.3 Security and Risk Management

To maintain access logs and detect, prevent, and respond to cybersecurity threats, including unauthorized access, malicious bots, and fraudulent activities.

In addition to your explicit consent, we may process your personal information where necessary to:

(1)Comply with legal obligations (e.g., regulatory requirements, law enforcement requests)

(2)Protect against cybersecurity risks (e.g., detection of malicious or automated activities)

(3)Fulfill other lawful bases for processing as permitted under applicable laws and regulations

3. Data Storage and Cross-Border Transfers (Important)

As we operate using globally distributed infrastructure, your personal information may be transferred across national borders:

3.1 Data Storage Location

Your original data is securely stored in encrypted form on cloud servers located in Tokyo, Japan (Asia-Pacific region).

3.2 Cross-Border Access

For business and operational purposes, authorized personnel located in China may remotely access such data where necessary.

3.3 Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Policy, including:

(1)Up to 12 months after the relevant processing purpose has been achieved (e.g., 12 months after completion of business follow-up)

(2)Security logs are retained for up to 6 months

Upon expiration of the retention period, your personal information will be permanently deleted or irreversibly anonymized, and will not be used for any further purpose.

3.4 Compliance Safeguards

We implement appropriate safeguards to ensure that cross-border data transfers comply with applicable laws:

(1)In accordance with the Act on the Protection of Personal Information (APPI) of Japan, we ensure that data recipients maintain a level of data protection equivalent to that required under Japanese law

(2)In accordance with the Personal Information Protection Law (PIPL) of China, we enforce strict role-based access control (RBAC) and secure transmission protocols such as TLS/SSL encryption

(3)All cross-border access activities are logged and subject to regular security audits

4. Sharing and Disclosure of Information

4.1 Sharing

We do not sell or disclose your personal information with any third-party companies, organizations, or individuals, except in the following circumstances:

(1)With your explicit consent

(2)Where required to fulfill legal or regulatory obligations

4.2 Disclosure

We may disclose your personal information without your consent where required by law, including:

(1)Legal proceedings

(2)Government or regulatory enforcement requests

5. Data Security and Protection

We implement industry-standard technical and organizational measures to protect your personal information, including:

(1)Encryption: Sensitive data (e.g., phone numbers) is protected using strong encryption during both transmission and storage

(2)Least Privilege Access: Access to personal data is restricted to authorized personnel on a need-to-know basis

(3)Data Masking: Personal data fields displayed in internal systems are dynamically masked to minimize exposure

6. Your Rights

Subject to applicable laws and regulations, you have the following rights regarding your personal information:

(1)Right of Access and Correction: You may request access to, correction of, or supplementation of your personal information

(2)Right to Erasure (“Right to be Forgotten”): You may request deletion of your personal information within the scope permitted by law

(3)Right to Withdraw Consent: You may withdraw your consent to data processing at any time

(4)Right to Object: You have the right to object to the processing of your personal information for purposes such as operational optimization, and we will cease such processing upon your request

To exercise your rights, please contact us using the details provided below. You will be required to provide identity verification information (e.g., name, phone number).

(1)We will verify your identity within 15 business days

(2)We will respond to your request within 30 business days after verification

7. Contact Us

If you have any questions, comments, or requests regarding this Privacy Policy or your personal information, or if you wish to exercise your rights, please contact our Data Protection Officer (DPO) or Information Security team:

Company Name: Shanghai Zhenyun Information Technology Co., Ltd.

Email

marketing@going-link.com