POLICY OF PERSONAL INFORMATION PROTECTION ON FLEXIV’S WEBSITE

Dear users:

Thank you for visiting the website of Flexiv (www.flexiv.com, hereinafter referred to as“the Website”). The Website is operated by Flexiv Ltd. (hereinafter referred to as "Flexiv" or"We"). We are fully aware of how important your personal information is to you and will do our best to keep your personal information safe. We will protect your personal information in accordance with the national laws and regulations and the principles of consistency of power and responsibility, specific purpose, choice of agreement, minimum necessity, security, subject participation, and openness and transparency. We have formulated the Policy of Personal Information Protection on Flexiv's Website (hereinafter referred to as this"Policy") to let you know which of your personal information the Websitehas collected and how we will use, save, share, and transfer such information during your visit to the Website. Please read this policy carefully, especially the content in bold. If you have any questions, comments, or suggestions, please contact us through the contact information specified in this policy.

This policy will help you understand the followings:

  1. I. Scope of Application
  2. II. How We Collect and Use Your Personal Information
  3. III. Exception with Obtaining Your Authorization
  4. IV. How We Use Cookies and Similar Technologies
  5. V. How We Save Your Personal Information
  6. VI. How We Entrust, Share, Transfer and Disclose Publicly Your Personal Information
  7. VII. How We Protect Your Personal Information
  8. VIII. Your Rights
  9. IX. How We Deal with the Personal Information of Minors
  10. X. Changes and Revisions to This Policy
  11. XI. How to Contact Us
  12. XII. Effectiveness of This Policy

I. Scope of Application

This Policy applies to the services we provide to you through the Website. It should be noted that this Policy does not apply to services provided to you by other third parties, like third-party services or websites linked to by you through the Website. You understand that these services are independently provided to you by a third party, and the third party will be solely responsible for the processing of your personal information in accordance with its policy or user agreement.

We may formulate personal information protection policies, statements, and notices (hereinafter referred to as "specific policies") for specific online or offline services or products. Such specific policies shall prevail in the event that there are special regulations provided under other specific policies or there is anything that is not covered in such specific policies.

II. How We Collect and Use Your Personal Information

"Personal information" refers to all the information related to an identified or identifiable natural person recorded electronically or by other means, excluding anonymized information.

"Sensitive personal information" refers to personal information that, once leaked or used illegally, may easily lead to the infringement of personal dignity of a natural person or do harm to the personal and property safety of a natural person, including biometrics, religious beliefs, specific identities, medical health, financial accounts, whereabouts, and personal information of minors under 14.

When you use the Website, we will collect and use the personal information necessary for providing related services in the following ways; if you do not use this function, we will not collect the related information.

（1） Business operation

When you apply for business cooperation with us, we need to collect information including your name, position, email address, contact number, country/region, industry, company name, and specific requirements for business cooperation, so that we may understand your specific needs and contact you for business cooperation.

We may also use the above information to (i) process and respond to questions and comments from you or your organization; (ii) provide information about products and services that may be of interest to you or your organization; (iii) solicit information and feedback from you or your organization, including conducting surveys and questionnaires.

（2） Apply for the job we provide

When you apply for the job we provide, we need to collect information about your identity and resume, including your name, date of birth, gender and hometown, education, work experience and contact information, so as to help us have a basic understanding of you.

（3） Subscribe to our newsletter

When you subscribe to our newsletter through the Website, we will collect your unsolicited email address to send the newsletter. If you wish to stop receiving any communications at any time, or want your name deleted from our mailing list, you may also contact us.

（4） Leave message to us

When you leave message to us through the Website, we will collect your name, phone number, company, industry, e-mail address, city and the message sent from you.

You understand and agree that after reading your message, we may get in touch with you through email, site letter, phone, SMS, and system messages to promote our products or services. If you wish to stop receiving any communications at any time, or want your name deleted from our mailing list, you may contact us through the contact information specified in this Policy.

III. Exception with Obtaining Your Authorization

According to relevant laws and regulations, we may collect and use your personal information without your authorization when it is:

  1. 1. required for performing statutory duties or obligations;
  2. 2. directly related to national security and defense;
  3. 3. directly related to public safety, public health, and major public interests, like responding to public health emergencies, or protecting the life, health and property of natural persons in emergencies;
  4. 4. directly related to criminal investigation, prosecution, trial and execution of judgment;
  5. 5. necessary for protecting your or other individuals' life, property and other major legal rights and interests but difficult to obtain your own authorization;
  6. 6. for collecting your publicly disclosed personal information in a reasonable range in accordance with laws and regulations;
  7. 7. required for establishing and executing the contract to which you are a party;
  8. 8. for collecting your personal information from legally disclosed information in a reasonable range in accordance with laws and regulations, like legal news reports, government information disclosure and other channels;
  9. 9. required for providing products or services you asked for;
  10. 10. required for maintaining the safe and stable operation of the products or services provided, like identifying and handling product or service failures;
  11. 11. other circumstances specified in laws and regulations.

IV. How We Use Cookies and Similar Technologies

To ensure the proper functioning of this website, we may store small data files called cookies on your computer or mobile device. Cookies typically contain identifiers, website names, and some numbers and characters. By using cookie technology, we can provide you with more personalized services and allow you to set specific service options. We will not use cookies for any purposes other than those described in this policy. You can manage cookies according to your preferences, and you can also clear all cookies stored on your device. Most web browsers have the option to block cookies. However, if you do so, you may need to change your user settings every time you visit the Website. For detailed instructions on how to change browser settings, please visit the relevant settings page of the browser you are using.

V. How We Save Your Personal Information

We save and process your personal information to a law-required period or to the shortest period required to achieve the above-mentioned purposes. After end of this period, we will delete or anonymize your personal information. For mandatory provisions under laws and regulations, we will dispose of the personal information in accordance with such mandatory provisions.

If we stop operating the Website and related services, we will promptly stop further collection of your personal information, and will issue a “Shutdown” notice in an announcement. At the same time, we will delete or anonymize the saved personal information.

VI. How We Entrust, Share, Transfer and Disclose Publicly Your Personal Information

i. Entrust

Some specific modules or functions in Flexiv’s services are provided by external vendors. For companies, organizations and individuals that we entrust to process personal information, we will establish with them strict confidentiality agreements or other data protection agreements that request them to handle personal information in accordance with our requirements, laws and regulations, and other measures that can ensure the confidentiality and security of personal information.

ii. Sharing

In principle, we will not share your personal information with any companies, organizations, or individuals, except in the following circumstances:

  1. 1. Your explicit authorization or consent has been obtained.
  2. 2. It must be provided as requested by applicable laws and regulations, legal procedures or mandatory government requirements or judicial rulings.

iii. Transfer

We will not transfer your personal information to any other companies, organizations, or individuals, except in the following circumstances:

  1. 1. Your explicit consent has been obtained;
  2. 2. When there is a merger, division, dissolution, acquisition, or bankruptcy, we will inform you of the name and contact way of the recipient of your personal information if it needs to be transferred. We will ask the new companies and organizations that hold your personal information to be continuously restricted by such personal information protection policy, otherwise we will require such companies and organizations to re-seek authorization and consent from you.

iv. Disclose Publicly

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

  1. 1. Your consent has been obtained;
  2. 2. We may publicly disclose your personal information when required by law, legal procedures, litigation, or government authorities.

v. Exceptions

In the following circumstances, we may share, transfer, and disclose publicly your personal information without obtaining your prior authorization:

  1. 1. required for performing statutory duties or obligations;
  2. 2. directly related to national security and defense;
  3. 3. required for establishing and executing the contract to which you are a party;
  4. 4. directly related to public safety, public health, and major public interests, like responding to public health emergencies, or protecting the life, health and property of natural persons in emergencies;
  5. 5. directly related to criminal investigation, prosecution, trial and execution of judgment;
  6. 6. necessary for protecting your or other individuals' life, property and other major legal rights and interests but difficult to obtain your own authorization;
  7. 7. for handling your voluntarily disclosed personal information or other legally disclosed personal information in a reasonable range in accordance with laws and regulations, like legal news reports, government information disclosure and other channels;

VII. How We Protect Your Personal Information

We attach great importance to the security of your personal information, and have adopted industry-standard security measures to protect the personal information you provide to prevent unauthorized access, public disclosure, use, modification, damage or loss of data.

1. Flexiv has set up the special personnel responsible for personal information protection, including handling all issues related to Flexiv's products and services that may involve users' personal information, planning and formulating the company’s policies, reviewing the user agreement of each product, and monitoring the working principle and information processing mechanism of each product. The contact information of the personnel responsible for personal information protection is as follows:

Contact: Director of Information Security, Flexiv

Email:xinyi.liu@flexiv.com

2. We have established special management systems, procedures, and organizations to ensure information security. For instance, we have formulated an overall policy and security strategy for information security, established a security management system at all levels, and clarified the responsibilities, division of labor, and skill requirements of each department and post within the security management organization.

3. We deploy an access control mechanism on the server side, and provide the minimum sufficient authorization for staff who may have access to your personal information.

4. We will perform account audits and monitoring for server operations. If a server operating system with security issues is found in external announcements, we will immediately update the server to ensure the security of all server systems and applications.

5. We have developed an emergency plan for cyber security incidents and allocated sufficient resources to ensure its implementation. If our physical, technical or management protection measures are damaged, we will promptly activate the emergency plan to prevent the expansion of security incidents, report to the national competent authority in accordance with the requirements of laws and regulations, and timely inform you of the basic situation, possible impact, measures taken or to be taken in reasonable and effective methods such as information pushes and announcements.

VIII. Your Rights

During your use of the Website, you may access and manage your personal information in the following ways:

i. Access your personal information

You have the right to access your personal information, apart from the exceptions provided by laws and regulations. If you need to exercise the right to access personal information, you may contact us through the contact information specified in this Policy.

ii. Correct your personal information

When you find anything wrong with our processing of your personal information, you have the right to request a correction. If you need to exercise the right to correct personal information, you may contact us through the contact information specified in this Policy.

iii. Delete your personal information

You may send us a request to delete your personal information when:

  1. 1. We process your personal information against laws and regulations or the agreement with you;
  2. 2. You no longer use our products or services;
  3. 3. We have achieved or cannot achieve the processing intent, or it is no longer necessary to achieve the processing intent;
  4. 4. We stop providing products or services, or the storage period reaches its end;
  5. 5. You withdraw your consent.

When you delete information from our service, we may not delete the corresponding information in the backup system immediately, but will delete it in a backup update. Please be aware and understand that according to laws and regulations, we will stop any processing other than storing and taking necessary security measures, if the storage period as allowed by laws and administrative regulations has not expired, or it is technically difficult to delete the personal information.

iv. Withdraw your authorization

Each business function requires some basic personal information before it can be completed. In the event that a service relies on your authorization before it can function or operate normally, if you withdraw the related authorization, we cannot further provide you with the corresponding service, or some functions of the service will be restricted. You may contact us through the contact information specified in this Policy.

v. Obtain a copy of your personal information and right of portability

You have the right to obtain a copy of your personal information, and may contact us through the contact information specified in this Policy. If it’s technically feasible, under the laws and regulations, you may also ask us to transfer your personal information to other subjects you have designated.

vi. Right to interpretation

You have the right to request us to interpret the rules for handling personal information. You may contact us through the contact information specified in this Policy.

vii. Respond to your request above

To make sure safety, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request, and will reply in 15 working days. If you are not satisfied, you may contact us through the contact information specified in this Policy.

In principle, you don't need to pay for any reasonable requests, but we will charge as appropriate some cost for requests that are too repetitive and beyond reasonable limits. We may reject requests that are unnecessarily repetitive, technically complicated (like involving the need to develop new systems or fundamentally change current practices), risky to the legitimate rights and interests of others, or too unrealistic (like involving information stored on backup tapes). We are unable able to respond to your request when it is:

  1. 1. related to our fulfillment of obligations stipulated by laws and regulations;
  2. 2. directly related to national security and defense;
  3. 3. directly related to public safety, public health, and major public interests;
  4. 4. directly related to criminal investigation, prosecution, trial and execution of judgment;
  5. 5. proved in our evidence that you are subjectively malicious or abusing rights (for example, your request will impair public safety and the legitimate rights and interests of others, or your request is beyond the general technical means and commercial costs.);
  6. 6. necessary for protecting your or other individuals' life, property and other major legal rights and interests but difficult to obtain your consent;
  7. 7. likely to cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
  8. 8. involving any business secret.

IX. How We Deal with the Personal Information of Minors

Our products, website and services are mainly designed for adults and not open to minors under the age of 14 unless we obtain consent of their parents or guardians.

In the case of collecting personal information of minors with their parents’ consent, we will only use or publicly disclose such information when permitted by law, with the explicit consent of parents or guardians, or necessary for protecting the minors.

We will delete relevant data as soon as possible if it’s found out that the personal information of minors was collected without obtaining confirmed prior consent of parents.

X. Changes and Revisions to This Policy

Our personal information protection policy may change. Without your explicit consent, we will not restrict your rights in accordance with this Policy.

For major changes to this Policy, we will post a notice in a prominent way. You may also browse the Website at any time to check for the latest policy.

The major changes mentioned in this Policy include but are not limited to:

  1. 1. Major changes in our service model, like the purpose and type of processing personal information, the way in which personal information is used, etc.;
  2. 2. Major changes in our control rights, like owner changes from mergers and acquisitions, etc.;
  3. 3. Changes in the main objects for sharing, transferring or disclosing publicly the personal information;
  4. 4. Major changes in your right to involve in processing personal information and the way in which it is exercised;
  5. 5. Changes in our department in charge of personal information security, contact information and complaint channels;
  6. 6. High risks in the report that assesses the impact of personal information security.

Your continued use of our website after such changes and revisions occur will be deemed as your agreement to such changes and revisions of this Policy.

XI. How to Contact Us

Flexiv Ltd. is the operator of the Flexiv website and the controller of your personal information, registered at 4500 Great America Parkway, STE 210, Santa Clara, CA 95054. If you have any questions, comments, suggestions or complaints about our policies and the handling of your personal information, please contact us by addressing to pr@flexiv.com. We will get back to you in 15 working days.

XII. How This Policy Comes into Effect

Formulated on October 31, 2021, this Policy came into effect as of November 30, 2021.

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