Privacy Policy

Last updated: March 20, 2025

Latest effective date: March 20, 2025

This Privacy Policy (hereinafter referred to as "this Policy") applies to the personal information provided by Shenzhen Pudu Technology Co., Ltd. and its subsidiaries and affiliates (hereinafter referred to as "Pudu Tech", "the Company" or "we") to customers (hereinafter referred to as "you") through PUDU Link, Merchant Management Platform, mini programs, etc. We will introduce to you the principles of personal information protection, the collection and handling of your personal information, the general protection measures and mechanisms, and show you the basic standards and systematized construction of personal information protection of Pudu Tech.

We endeavor to present this Policy in a concise, clear, and easy-to-understand manner. Pudu Tech recognizes the importance of personal information to you and will do our best to protect the security of your personal information. We are committed to maintaining your trust in us and abide by the following principles to protect your personal information: consistent rights and liabilities, clarity of purpose, consent of choice, minimum sufficiency, security guarantee, subject participation, transparency and so on. At the same time, Pudu Tech promises that we will protect your personal information according to the mature security standards in the industry and take corresponding security protection measures.

Before using our products, please read this Policy carefully so that you can better understand our products and the services we provide and make appropriate choices.Unless otherwise provided by laws and administrative regulations, you have the right to know and decide how we handle your personal information and have the right to restrict or refuse the handling of your personal information by us or other parties; at the same time, you have the right to ask us to explain the rules of handling personal information that we provide to you. In order to make you fully aware of and understand our rules on the processing of your personal information, the scope of processing and the consequences of processing, as well as to serve as a basis for you to exercise your relevant rights, we have written "1. Our basic rules for handling your personal information” to implement the legal obligation of notification that we should fulfill to you. For this reason, we strongly recommend that you first read this Section carefully and give your authorized consent based on a full understanding of the contents of this Policy.

If you choose Pudu Tech to deliver to you a product that adopts or includes a privately deployed system structure, i.e., the product is deployed on servers owned or legally used by you, you are aware that all data collection, security measures, and restrictions on permissions are independently controlled by you. Without your authorisation, Pudu Tech cannot access or acquire your data or data that you have authorised to be acquired.

You are aware and understand that the Pudu Tech products that have been privately deployed are of the same nature as your own systems and are segregated from Pudu Tech' data. Without your authorised consent, Pudu Tech does not and cannot access, collect, use or control any information or data on privately deployed products and services, and therefore cannot be held liable for the risk of compliance of your data with local privately deployed services.

In the event that you authorise and consent to Pudu Tech's use of local data, Pudu Tech will still use your authorised local data in a data-isolated environment.

If you have any questions, comments or suggestions, please contact us through the [Chinese Mainland customer service contact: +86 755-86952935; Hong Kong SAR (China), Macao SAR (China), and China's Taiwan region customer service contact: +86 755-86952935; other countries or regions contact: +86 755-86952935].

This Policy will help you understand the following content:

1. Our basic rules for handling your personal information

2. What information do we collect or process and how is it used

3. How we protect your personal information

4. Your rights

5. What we do with children's personal information

6. Protection of personal information of our deceased users

7. How your personal information is transferred globally

8. How we update our privacy policy and how the law applies

9. How to contact us

1. Our basic rules for handling your personal information

The important definitions in this Policy are based on the relevant definitions in the Personal Information Protection Law and the Information Security Technology – Personal Information Security Specification (GB/T35273-2020), and we have made relevant additions in response to our actual situation, and in case of any inconsistency, the provisions of the Personal Information Protection Law and the Information Security Technology – Personal Information Security Specification shall prevail. We would like to draw your attention to the fact that the core purpose of this Section is to guide you to fully know and understand our rules on the handling, the scope of handling and the consequences of handling of your personal information, so as to fulfill our legal obligation to inform you. For this reason, we strongly recommend that you read this Section carefully and give your authorized or express consent on the basis of a full understanding of its contents.

1.1 Personal Information: refers to all kinds of information related to an identified or identifiable natural person recorded electronically or by other means. For example, personal telephone number, personal information subject account, IP address, unique device identification code, etc. Sensitive Personal Information: refers to personal information that, once leaked or illegally used, is likely to lead to infringement of a natural person's human dignity or jeopardize the safety of his or her person or property, including biometrics, religious beliefs, specific identity, medical care, financial account, tracking and other information, as well as personal information of minors under the age of 14 (or the age of minors as stipulated by the laws of the jurisdiction in which you are located). Where personal information is sensitive in this Policy, we will use bolded text to draw your attention and obtain your individual consent, and you should pay additional attention to the listing of such information. You can find out what types of personal information we process in what circumstances and for what purposes by referring to the descriptions in the table set out in "2.1 Collection and Use of Personal Information", and the scope of your personal information that we process in relation to the services we provide to you is set out below:

1.2 Personal Information Processor: an organization or individual who independently decides on the purpose and manner of processing personal information in the course of personal information processing activities.

1.3 Processing: This includes the collection, storage, use, processing, transfer, provision, disclosure and deletion of personal information. For more information on how we collect and use your personal information, you can refer to "2. How We Collect and Use Your Personal Information".

1.3.1 Collection: It refers to the act of obtaining control over personal information and deciding independently on the purpose and manner of handling personal information, including "automatic collection" by the subject of the personal information providing it to us on our own initiative, through our interactions with the subject of the personal information or by recording the subject of the personal information's behaviors and "indirect acquisition" by us through the receipt of other personal information and/or the collection of public information.

1.3.2 Use: We will explain the scenarios and purposes for which we will use your personal information in the table at "2.1 Collection and Use of Personal Information" and will set out the corresponding lawful processing grounds so that you are aware of the corresponding obligations we need to comply with. When we want to use information collected for a specific purpose for another purpose, we will ask for your consent or inform you of other legitimate reasons for processing. The term "use" in this Policy refers to the way we process data to store, access and display, aggregate and merge, statistically analyze, and other uses and applications of the data.

1.3.3 Storage: Refers to the act of recording personal information in electronic or non-electronic form on media that are accessible and retrievable by us. For normal business operations, we will store the personal information required for products within the retention periods required by different legitimate processing reasons:

a) Personal information processed based on your authorized consent will be retained from the date of collection until the processing purpose is achieved, the user cancels/deletes the account and all information, or withdraws consent and the agreed rescission period expires;

b) Personal information necessary for the conclusion or performance of a contract to which you are a party will be retained from the date of collection until the contract has been performed and the statute of limitations has expired;

c) Personal information necessary for the fulfillment of legal obligations will be retained from the date of collection until the legal obligations have been fulfilled and the statute of limitations has expired.

If there are different requirements for the above retention periods under laws, regulations, standardized documents and regulatory requirements, we will comply with the requirements under laws, regulations, standardized documents and regulatory requirements. In addition, for your personal information that we collect based on our products, we will comply with the permitted legal bases and exceptions and will comply with the requirements of applicable laws relating to the transfer and storage of such information. Your information may be processed on servers located outside of your country of residence. Regardless of where your information is processed, we will apply the safeguards described in this Policy.

Personal information that we generate or collect within the People's Republic of China is stored on servers located in China. We will not provide any of your personal information to subjects outside of China without meeting the conditions and procedures set forth in laws, regulations, standardized documents and regulatory requirements.

1.3.4 External Provision: An activity in which a processor of personal information provides personal information to another processor of personal information and in which the recipient processes the personal information under the categories of personal information, the purposes of processing and the manner of processing of which the subject of the personal information has been informed.

1.3.5 Entrusted Processing: This refers to an activity in which a personal information processor entrusts a trustee with the processing of personal information and supervises the trustee's personal information processing activities. The trustee may only handle personal information within the scope of the entrustment, and the trustee may not subcontract others to handle personal information without the consent of the personal information processor.

1.3.6 Anonymization: Refers to the process by which personal information is processed in a way that it cannot be used to identify a specific individual and cannot be restored.

1.3.7 Affiliate: Refers to entities directly or indirectly controlled by Shenzhen Pudu Technology Co., Ltd., or any company or legal entity under common control with Shenzhen Pudu Technology Co., Ltd. The term "entity" in this definition includes but is not limited to individuals, partnerships, companies, and other legal entities.

2. What information do we collect or process and how is it used

We will follow the principle of lawfulness, legitimacy and necessity to collect and process your personal information for the purpose of providing you with relevant products and services, and disclose it to you in the form of a list (please see below for an example), and we will disclose the collection and use of your personal information to you as fully, completely and timely as possible, and If you become aware of any errors or omissions in our disclosures, please contact us via the contact information described in this Policy.

2.1 Collection and Use of Personal Information

With the iteration, expansion and upgrading of our products or services, the types of your personal information we collect and use will change, and in the event of such a situation, we will explain it to you in detail by updating this Policy and pop-ups and pages in the products of Pudu Tech, and ask for your consent. The categories of personal information that we need to collect and process for different processing purposes in this service are listed below:

Basic Functions:

2.2 Collection and Use of Device Privilege Information

In order to comply with laws and regulations, normative documents, regulatory requirements, and necessity to ensure transaction security, as well as to achieve the purpose of collecting personal information, we need to apply for the corresponding device access permissions based on the different business functions you select. In situations where your system allows, we will explain the purpose and seek your consent through pop-ups when permissions need to be granted. By granting these permissions, you authorize us to collect and process this information to achieve the corresponding functions. You can revoke authorization through the relevant device settings, but after revocation, we will not be able to provide you with the corresponding business functions. The permissions that need to be granted and their specific usage scenarios are listed in the table below:

2.3 How We Use Cookies and Similar Technologies

2.3.1 Use of cookies and similar technologies

To fulfill the needs of your online experience and to make your visit easier, we may send one or more small data files or similar technical files called cookies on your computer or mobile device, which are assigned to you uniquely and can only be read by the web server in the domain that issued the cookie to you. We send you Cookies to simplify the process of logging in repeatedly, to help determine your login status, and for account or data security.

We do not use cookies for any purpose other than those described in this Policy. According to your preferences, you can manage or delete cookies, or clear all cookies stored on your computer, most web browsers automatically accept cookies, but you can usually modify your browser settings to refuse cookies if you wish, or you can clear all cookies stored in your software. However, if you do so, you may need to change your user settings each time you visit the site, and any previously recorded information about you will be deleted, which may have an impact on the security of the service you are using. For more information on how to change your browser settings, please visit the settings page of your browser.

2.3.2 Do Not Track

Many web browsers have a ＂Do Not Track＂ feature that allows you to post a ＂Do Not Track＂ request to a website. At this time, the major Internet standards organizations have not established policies that dictate how websites should respond to such requests. However, if your browser has ＂Do Not Track＂ enabled, we will respect your choice.

2.4 Use of Your Personal Information Within Pudu Tech

2.4.1 We will aggregate, merge and co-use all of your information in the table listed in "2.1 Collection and Use of Personal Information" of this Policy within Pudu Tech in accordance with Pudu Tech's unified information security management requirements and operational control strategies. If the scope of our provision or the recipient's purpose of use exceeds that described in this Policy, the recipient of the change in purpose shall obtain your consent again. You have the right to lodge a complaint with us at or with any of our affiliates who have collected and processed your personal information from you at via the contact information described in this Policy, or to request an explanation and response from us or any of our affiliates who have collected and processed your personal information from you in connection with the sharing of company data as described in this Section.

2.4.2 Your personal information may be shared and made available for common use within Pudu Tech for the following processing purposes:

a) Create a unified login account to verify your identity within the Company, unify identity authentication and enjoy the corresponding rights and benefits.

b) Providing services to you jointly with affiliates or jointly implementing business functions for specific products.

c) Preventing security risks, making comprehensive judgment on your personal information and labeling information within the Company, detecting and preventing security risks (such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusion, etc.), and more accurately identifying violations of laws and regulations or rules of agreements related to product and services, in order to protect the legitimate rights and interests of you, other users, and us or our affiliated companies.

d) Identify, analyze and process Company-wide to form tagged information and use it among various affiliates within the Company for automated decision-making, operational security, academic research, notification and push (including sending you commercial advertisements and information pushes), and improvement of products and services.

e) Other purposes permitted by laws, regulations, normative documents and regulatory provisions, as well as your authorized consent.

2.4.3 We will control the security of data flow within Pudu Tech through systems, agreements and technical means. At the same time, in order to ensure the security of data flow within Pudu Tech, we will implement internal routine checking measures and require all affiliates within Pudu Tech to strictly implement the Company's information security management requirements and operation control strategies.

2.4.4 Pudu Tech: To avoid ambiguity, for the purposes of this Policy only, Pudu Tech includes Shenzhen Pudu Technology Co., Ltd. and its subsidiaries, and entities under common control with Shenzhen Pudu Technology Co., Ltd.

2.5 Provision to Third Parties

2.5.1 We will not provide your personal information to third parties unless we are authorized by laws, regulations, normative documents and regulatory provisions or have other legitimate reasons for processing. We will only provide your personal information to third party processors of personal information for legal, legitimate, necessary, specific and clear purposes. We will enter into confidentiality agreements with recipients in accordance with the law, requiring them to handle personal information in accordance with the requirements of this Policy and other necessary confidentiality and security measures. The circumstances in which we provide your personal information to third parties mainly include:

a) Entrusted processing: In order to fulfill the business functions of a specific product, we may delegate the provision of services to you to external providers. Under delegated processing, the third party that receives the Personal Information is only authorized to provide the services to you on our behalf under our instructions, and we will be liable to you for its delegated actions within the scope of the delegation. For example, we may entrust vendors, service providers and other partners that support our business to provide us with technical infrastructure services (e.g., SMS authentication services), analysis of how our services are being used or the potential risks, advertising services, transportation, warehousing, customs clearance, terminal collection and delivery, payment facilitation, customer service, data storage or data analytics services, and third party add-on business function services (e.g., voice input, mapping functions). voice input, map functions).

b) External provision: In order to fulfill the agreement concluded with you or for other reasonable purposes, we may provide certain of your personal information to a third party processor of personal information, and we will disclose it to you in accordance with laws and regulations, and the third party processor of personal information who receives the personal information has the right to process the personal information within the scope of the purpose of the processing, the manner of the processing, and the types of personal information that have been notified to you. In the event that the recipient changes the original purpose and method of processing, it shall obtain your consent again, unless otherwise provided by laws and regulations.For details on the information we provide to third parties, please see the following list of third party sharing.

In particular, you should be aware that if you authorize a third party to request all or part of your personal information from us in connection with the Service, you agree that we have the right to verify, based on our own experience, the authenticity of your identity and your authorization to the third party, and to consent to or refuse to provide the foregoing personal information of you at our sole discretion, unless you separately instruct us to do so through the contact information described in this Policy.For example, if you authorize a third party financial institution to obtain certain personal information about you from us, and that third party asks us to provide your personal information based on the content of that authorization, we will respond to the third party's request to provide it to the extent you have authorized.

c) Third party SDKs

We will access and provide your personal information to third party personal information processors in the form of SDKs. If you refuse to allow us to provide your personal information to the relevant affiliates and third party processors, you will not be able to use the corresponding business functions. For details of the SDKs that we have integrated with, please refer to the "List of Third Party Information Sharing" below.

List of Third Party Information Sharing:

2.5.2 For the avoidance of ambiguity, you should be aware and understand that the Products may contain links to websites, applications, products and services operated by other independent third parties, and that we make no express or implied warranties about such third party websites, applications, products and services, and that such links are provided solely for the purpose of facilitating the browsing of the relevant pages. When you visit such third party websites, applications, products and services, we will provide your personal information to the third party based on your explicit authorization, you should note that you agree to the privacy policy or terms of protection of your personal information provided by the third party, and you should pay special attention to the fact that the SDK independently connected to such third-party websites and applications is the joint responsibility of the accessing party and the SDK provider to you. We and the providers of such third party websites, applications, products and services shall each be responsible for the protection of your personal information to the extent required by law and agreed by both parties.

2.6 Transfer

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

2.6.1 Transfer with Explicit Consent: We may transfer your personal information to other parties with your explicit consent;

2.6.2 If we need to transfer personal information due to a merger, demerger, dissolution, or bankruptcy, we will notify you of the name and contact information of the recipient, and ask the recipient to continue to be bound by this Policy. If the recipient changes the original purpose or method of processing, we will require the recipient to obtain your consent again.

2.7 Public Disclosure

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

2.7.1 With your individual consent;

2.7.2 Disclosure based on law: We may publicly disclose your personal information if required to do so by law, legal process, litigation, or mandatory requirements from governmental authorities.

2.8 Collection or Processing and Use of Non-Personal Information

We may also collect other information that does not identify a specific individual (i.e., information that is not personal information). For non-personal information, we will not ask you to register for an account, nor will we collect information that directly identifies an individual, such as your name, contact information, or identification number. The purpose of collecting or processing such information is to improve the service we provide to you. The type and amount of information we collect will depend on how you use our products and/or services.

2.8.1 When you use the Voice Interaction App

a) Categories of Non-Personal Information

b) Handling of Non-Personal Information

Although we do not collect personal information, the Voice Interaction App processes the following data to provide AI voice interaction features:

Voice input and AI text is used for real-time processing to provide dialogue, search and navigation capabilities, and content is anonymised for us to optimise the product experience. We do not associate any data with personal identity and all data is anonymised.

c) Permission Requirements for Voice Interaction App

The Voice Interaction App may request the following device permissions to provide AI voice functionality:

These permissions are only enabled when the user utilizes the AI voice function and do not continuously collect data in the background.

d) Third Party Services

These third parties may store data temporarily during data processing, but we do not actively store or share your voice data.

• We recommend that you read the privacy policies of the above services to understand how they handle data.

3. How we protect your personal information

3.1 We have used industry standard security measures to protect the personal information you provide against unauthorized access, use, modification, public disclosure, damage or loss of data. We will take all reasonably practicable steps to protect your personal information. For example, we use encryption technology to ensure data confidentiality; we use trusted protection mechanisms to prevent malicious attacks on data; we deploy access control mechanisms to ensure that only authorized personnel have access to personal information; and we conduct data security and privacy protection training courses to enhance employee awareness of the importance of personal information protection.

3.2 Our Data Security Capability: Pudu Tech has established an Information Security Department to build a complete and advanced data security protection system for Pudu Tech's products, including classifying and grading user information, encrypting storage, and controlling data access permissions; establishing an internal data management system and operating procedures, with strict process requirements for data collection, use, deletion, or anonymization to avoid illegal use of user privacy data; determining the security management responsibilities of each department and their responsible persons who have access to user personal information; establishing a workflow and security management system for the collection, use, and related activities of user personal information; implementing permission management for staff and distributors, reviewing batch queries, modifications, copies, exports, and deletions of personal information, and taking anti leakage measures; properly storing paper media, optical media, electromagnetic media, and other media that record user personal information, and taking corresponding security storage measures; implementing access checks on information systems that store user personal information, and taking measures such as intrusion prevention and virus protection; recording information such as personnel, time, location, and matters involved in operating user personal information; regularly hold training on data security and privacy protection to enhance employees' awareness of personal information protection.

3.3 We will take all reasonably practicable steps to ensure that we do not collect irrelevant personal information. We will only retain your personal information for as long as is necessary to achieve the purposes set out in this Policy, unless we need to extend the retention period or are permitted by law to do so. After exceeding the retention period mentioned above, we will delete or anonymize the personal information we hold about you within a reasonable period of time. (For the purposes of this Privacy Policy, "anonymization" means the technical processing of personal information so that the subject of the personal information cannot be identified and the processed information cannot be recovered. Information derived from the anonymization of personal information is not personal information.)

3.4 Before we cease to provide a product or service, we will notify you of the cessation of provision by way of an announcement, message push or other reasonable means, and when we cease to provide a product or service, we will promptly cease to collect your personal information and delete or anonymize the personal information that we already hold about you within a reasonable period of time. The internet environment is not 100% secure and we will endeavor to ensure or warrant the security of any information you send to us. If our physical, technical or management protective facilities are breached, resulting in unauthorized access to, public disclosure, tampering, or destruction of information, which in turn results in damage to your legitimate rights and interests, we will be held liable.

3.5 In the event of an unfortunate personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation of the security incident and its possible impact, the disposal measures that we have taken or will take, the suggestions that you can independently prevent and reduce the risk, and the remedial measures for you. We will promptly inform you of the situation related to the incident by email, letter, phone call, or push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to make a public announcement.

We will also proactively report on the handling of personal information security incidents as required by the regulatory authorities.

If you find that your personal information has been leaked, please contact us immediately via the contact details described in this Policy so that we can take prompt action.

4. Your rights

In accordance with the prevailing practice of relevant Chinese laws, regulations and standards, we will endeavor to protect your rights in our personal information processing activities, including but not limited to:

4.1 Access, copying and transfer of your personal information

4.1.1 You have the right to access and copy your personal information by logging in to the relevant websites, APPs and mini programs of Pudu Tech through your Pudu Tech account, except for the exceptions stipulated by laws and regulations. Where technically feasible, we will provide you with the function of exporting relevant personal information by yourself, please note that some personal information cannot be exported by yourself due to the requirements of laws and regulations and/or our technical ability, and the specific personal information that can be exported should be subject to the prompts on the export interface.

4.1.2 You have the right to obtain a copy of your personal information or request us to transfer your personal information to a third party designated by you. You can contact us at any time through the contact information of the department in charge of the protection of personal information disclosed in Section 9 of this Policy [ privacy@pudutech.com ] and make your request, and we will complete the processing and reply to you within fifteen business days. The types of personal information that will be copied or transferred to your designated third party include: personal account numbers, e-mail contact information, and other personal information.

If you are unable to access, copy or transfer such personal information through the above paths, you may contact us at any time through the contact information described in this Policy, and we will complete the processing and reply to your request for access, copy and transfer within fifteen business days and provide the corresponding transfer paths when the conditions of transfer fulfill the conditions stipulated by the cyberspace affairs department of the state.

4.2 Correcting and Supplementing Your Personal Information

4.2.1 When you find that your personal information is inaccurate or incomplete, you have the right to make corrections and additions in the following ways: you can contact your distributor for information revision.

4.3 Deleting Your Personal Information

4.3.1 In the following circumstances, if we do not proactively delete your personal information, you may request the deletion of your personal information from us by contacting us as described in this Policy:

a) The purpose of the treatment has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose of the treatment;

b) We cease to provide the product or service or the retention period has expired;

c) You withdraw your consent;

d) We process your personal information in violation of laws or administrative regulations or in violation of an agreement;

e) Other cases stipulated by laws and administrative regulations.

4.3.2 For some of your personal information, you can delete your account and information after contacting your distributor.

4.3.3 When you delete information from our Services, we may not immediately delete the corresponding information in our backup system, but we will delete the information when the backup is updated.

4.3.4 If the retention period stipulated by laws or administrative regulations has not expired, or if deletion of personal information is technically difficult to achieve, we will stop processing other than storing it and taking the necessary safety protection measures.

4.4 Changing the Scope of Your Authorized Consent or Withdrawing Your Authorization

4.4.1 Each business function requires some basic personal information in order to be completed, after you withdraw your consent, the corresponding business function will not be able to continue to use, for some of your personal information, you can withdraw your consent in the relevant function page of the product service, specifically:

You can revoke the terms by checking the Revocation of Consent box on the login page.

4.4.2 If you have other requirements for withdrawing consent that cannot be fulfilled, you may change the scope of the authorized consent by sending us a notice via the contact information described in this Policy.

4.4.3 When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization.

4.4.4 In particular, if you do not want to receive commercially oriented marketing messages from us, you can reply to cancel the push through the unsubscribe method clearly stated in the marketing email or text message, or contact us through the contact information described in this Policy.

4.5 Cancellation of Accounts by Subjects of Personal Information

You can cancel your account by contacting your distributor, who will cancel the account through the merchant management function; or by contacting customer service to cancel account and contact information. We will complete the processing and reply within fifteen business days.

4.6 Automated Decision-Making in Constrained Information Systems

4.6.1 In certain business functions, such as login environment detection, we may make decisions based solely on non-human automated decision-making mechanisms, including information systems, algorithms and the like. Such decisions may significantly affect your legitimate rights and interests, and you have the right to ask for clarification through the contact information described in this Policy, and the right to object to our decisions made solely through automated decision-making, and we will provide appropriate remedies to protect your legitimate rights, such as explaining the logic of the automated decision-making and the related impact on you, or introducing manual audits to double-check the correctness of the results of the automated decision-making.

4.7 Responding to Your Request Above

4.7.1 For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

4.7.2 We will process and respond to your request within fifteen business days. If you are not satisfied with our response, you can also complain to us using the contact information described in this Policy.

4.7.3 In principle, we do not charge you for reasonable requests, but we will charge you a fee for costs incurred for requests that are repeated more than is reasonable. We may refuse unnecessarily repetitive requests, require excessive technical means (e.g., requiring the development of a new system or a fundamental change in existing practices), pose a risk to the legal rights of others, or are highly impractical.

4.7.4 We will not be able to respond to your request if we are required to do so by law or regulation in the following circumstances:

a) Related to the fulfillment of the obligations of the processor of personal information as stipulated by laws and regulations;

b) Directly related to national security and national defense security;

c) Directly related to public safety, public health, and significant public interest;

d) Directly related to criminal investigations, prosecutions, trials and enforcement of sentences;

e) The personal information processor has sufficient evidence to show that the personal information subject has subjective malice or abused rights;

f) To protect the life, property and other major legitimate rights and interests of the personal information subject or other individuals but it is difficult to obtain the consent of the individual;

g) Responding to your request will result in serious damage to the legitimate rights and interests of the subject of personal information or other individuals or organizations;

h) Involving trade secrets.

5. What we do with children's personal information

5.1 When you browse our products while you are not logged in, we will only collect information about your personal current device status and necessary personal common device information in the course of using the specific product, and due to the limitations of the existing technology, we are unable to determine whether you are a child under 14 years of age (or the age of a minor under the law of your jurisdiction). However, we will use such information strictly in accordance with the scope of your authorized consent and protect your personal information in accordance with the commitments of this Policy.

5.2 If we find ourselves collecting personal data from minors under the age of 14 (or the age of a minor under the laws of your jurisdiction) without verifiable parental or guardian consent, we will seek to delete the relevant data as soon as possible.

6. Protection of personal information of our deceased users

6.1 Upon the death of a user (natural person only), his/her next of kin may, for his/her own lawful and legitimate interests, exercise the right of access, copying, correction, deletion, etc. of the personal information of the deceased user through the contact information described in this Policy, unless the deceased user has made other arrangements before his/her death.

6.2 You understand and acknowledge that in order to fully protect the personal information rights and interests of the deceased user, the next of kin of the deceased user who applies for exercising the rights in this Section is required to submit the identity document of the deceased user, the death certificate document, the identity document of the applicant, the identity document of the applicant, and the relationship between the applicant and the deceased user according to the designated process of Pudu Tech or customer service reminder, and to provide the type of the right to be applied for exercising and the purpose of such exercise. You can call the customer service contact +86 755-86952935 or further obtain more information about the process and conditions for the protection of personal information of deceased users through the contact information described in this Policy.

7. How your personal information is transferred globally

7.1 In principle, personal information collected and generated by us in the People's Republic of China will be stored within the territory in accordance with the requirements of applicable law.

7.2 We will only provide your personal information outside the country for purposes necessary for the performance of our contract with you or for other legitimate processing reasons, and we undertake to comply with the conditions required by the laws and regulations in force.

7.3 Where, under applicable law, we are required to also comply with the data protection laws of other countries or regions in order to protect your personal information, we will also make appropriate compliance safeguards and adjustments.

8. How we update our privacy policy and how the law applies

8.1 Our Privacy Policy is subject to change. We will not reduce your rights under this Policy without your explicit consent. We will post updated versions of this Policy.

8.2 For material changes, we will also provide more prominent notification (including pop-up notifications or message notifications, and for some services, we may send notifications via email).

8.3 Material changes to this Policy include, but are not limited to:

8.3.1 Material changes in our service model. For example, the purpose of processing personal information, the type of personal information processed, and how personal information is used;

8.3.2 Material changes in our ownership structure, organizational structure, etc. Such as changes in ownership due to business restructuring, bankruptcy mergers and acquisitions, etc.;

8.3.3 There is a change in the primary audience to which personal information is made available, transferred or publicly disclosed;

8.3.4 Material changes in your rights to participate in the processing of personal information and how you exercise them;

8.3.5 In the event of a change in the department responsible for handling the security of personal information, our contact details and complaint channels;

8.3.6 When the personal information security impact assessment report indicates a high risk.

8.4 We will also keep an older version of this Policy on file for you to review.

8.5 This Policy only applies to our customers who are located in China. If you would like to know the privacy policies of other countries in which we operate, please refer to the relevant privacy protection documents in Section 7.3 of this Policy.

8.6 The laws of the People's Republic of China (excluding Hong Kong, Macao and Taiwan) shall apply to the formation, implementation, interpretation and dispute resolution of this Policy, excluding the application of conflict of laws rules.

9. How to contact us

9.1 If you have any questions, comments or suggestions, you can contact our After-Sales Services team or our department responsible for protecting personal information by the following. We will reply to you within fifteen business days normally.

Company Name: Shenzhen Pudu Technology Co., Ltd.

Registered Address: Rm 501, Block A, Building 1, Shenzhen International Inno Valley Phase I, Dashi 1st Rd, Nanshan District, Shenzhen, P.R.

China.Office Address: Rm 501 Block A, Building 1, Shenzhen International Inno Valley Phase I, Dashi 1st Rd, Nanshan District, Shenzhen, P.R. China.

Customer Service Contact: +86 755-86952935

Contact Information of the Department in Charge of Personal Information Protection: privacy@pudutech.com

9.2 You have the right to contact us and make a complaint by the means disclosed in Section 9.1 of this Policy. We will process and respond to your complaint within fifteen business days from the date of receipt. If you are not satisfied with our response, especially if you believe that our personal information processing behavior has harmed your legitimate rights and interests, you can also file a complaint or report to the regulatory authorities such as cyberspace administration, public security, industry and commerce, or file a lawsuit with the People's Court of Nanshan District of Shenzhen, or any other court of competent jurisdiction.