Last Updated: October 2023

This privacy policy (“Privacy Policy”) explains the when, how, and why when it comes to

processing your personal information on the Shanghai Flexem Technology Co., Ltd.’s

(“Shanghai Flexem”) and its subsidiaries’ software and sets out your choices and rights in

relation to that information. Please read this carefully – it is very important for you to

understand how we collect and use your information and how you can manage it.

If you do not agree to the processing of your personal information in the way this

and stop using the

software

. By continuing to use the

software,

you are

acknowledging our rules regarding your personal information as described in this

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and

how we collect it. If you would like to know more about specific types of data and how we

use that data, please see the section below.

The following is a high-level summary of the types of personal information we use:

- Information you provide directly to us

When you submit personal information through our software or contact us using the

contact information specified in this Privacy Policy, you provide us with certain information

in relation to your inquiry.

- Information we collect automatically

We may collect certain information automatically when you use our Sites, such as your

Internet protocol (IP) address, device and advertising identifiers, browser type, operating

system, Internet service provider, pages that you visit before and after using the Sites, the

date and time of your visit, information about the links you click, the pages you view, the

general manner in which you navigate the Sites, and other standard server log information.

We may also collect certain location information when you use our Sites, such as your

computer’s IP address, your mobile device’s GPS signal, or information about nearby

WiFi access points and cell towers.

2. How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you

and why.

When you submit an inquiry to us, in order to contact you and handle your questions, we

will, in accordance with the law, only collect information that is strictly necessary and will

not use it for other services. The specific information collected is as follows:

Personal Information

Use

Information you provide to us.

Inquiry Information:

 First Name

 Last Name

 Company Name

 Role

 Work Email

 Phone Number

 Country

We use this information to understand who is

making the inquiry, what the inquiry relates to

and to contact the person who made the inquiry.

3. How We Store and Share Your Personal Information

We will follow legal provisions and regulations strictly and will take strict and secure

protective measures to safeguard your rights in accordance with this Privacy Policy.

Only where reasonably necessary will we share your personal information. Situations

where this occurs are:

 Corporate subsidiaries or affiliates who process your personal information in

order to respond to your inquiries. All related subsidiaries or affiliates may only use your

personal information in accordance with this Privacy Policy.

 Legal purposes. There are circumstances in which we are legally required to

disclose information about you to authorities, such as to comply with a legal obligation or

processes, enforce our terms, address issues relating to security or fraud, or protect our

users. These disclosures may be made with or without your consent, and with or without

notice, in compliance with the terms of valid legal process such as a subpoena, court

order, or search warrant. We are usually prohibited from notifying you of any such

disclosures by the terms of the legal process. We may seek your consent to disclose

information in response to a governmental entity’s request when that governmental entity

has not provided the required subpoena, court order, or search warrant. We may also

disclose your information to:

enforce our terms and conditions and other agreements, including

investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud, or technical issues;

o protect the rights, property or safety of us, our users, a third party or the

public as required or permitted by law (exchanging information with other companies

and organizations for the purposes of fraud protection and credit risk reduction).

 A third party that acquires all or substantially all of us or our business. We

may also disclose your information to third parties if we either: (a) sell, transfer, merge,

consolidate, or re-organize any part(s) of our business, or merge with, acquire or form a

joint venture with, any other business, in which case we may disclose your data to any

new owner or other third party involved in such change to our business; or (b) sell or

transfer any of our assets, in which case the information we hold about you may be sold

as part of those assets and may be transferred to any new owner or other third party

involved in such sale or transfer.

4. The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no

matter where it is stored. We have information security and access policies that limit

access to our systems and technology, and we protect data through the use of

technological protection measures such as encryption.

Unfortunately, although we have implemented and maintained reasonable measures to

protect your personal information, the transmission of information via the internet is not

completely secure. In the event of a security incident, such as a personal data breach, we

will initiate an emergency plan to prevent the magnification of the security incident and will

notify you via push notifications, announcements, etc.

5. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so

under the law. We will retain your information as follows:

 Information you provide to us when submitting the inquiry form or contacting us

using the details specified in this Privacy Policy: until your inquiry is resolved, and then

erased within one hundred and eighty (180) days of such resolution, unless you agree to

have this data retained and receive more information in the future.

 If we are required to retain your information beyond the retention periods set out

above, for example, to comply with applicable laws, we will store it separately from other

types of personal information.

6. Your Rights

You have legal rights in relation to the personal information we hold about you (to the

extent permitted under applicable laws and regulations). You may request access or

corrections to the data we process about you.

To exercise any of your rights, please contact us at marketing@flexem.com

Please note that the Webpage does not engage in any personalized advertising. Any

emails sent are in response to inquiries submitted by you and are service messages only.

7. Children

Children must not use the Webpage for any purpose except where their parent or

guardian has provided consent.

By children, we mean users under the age of 18 years old.

We do not knowingly collect personal information from children for any purpose. If you

believe that we have personal information of a child without parental/guardian consent, or

if you are the parent or guardian of the user and wish to withdraw consent, please contact

us at marketing@flexem.com and we will delete such information.

8. Contact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcome. We have

set up a personal data protection team and assigned a designated personal data

protection officer. If you have any questions, complaints, or suggestions about this Privacy

Policy or data protection-related matters, please contact the data protection officer (the

person in charge of personal data protection) for purposes of compliance with the

applicable privacy law. The data protection officer can be contacted

at marketing@flexem.com.

In the event that you wish to make a complaint about how we process your

personal information, please contact us in the first instance

at marketing@flexem.com and we will endeavour to deal with your request as soon

as possible.

9. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here.

Please check this page frequently to see if there are any updates or changes to this