Shanghai Huaxun Network System Co., Ltd.

ECCOM User Privacy Protection Policy

ECCOM Network Systems Co., Ltd. (hereinafter referred to as “ECCOM”, “we”) respects and protects user privacy. While providing you with accurate and personalized services, we will collect and use your personal information with a high degree of diligence and prudence. By using our products or receiving our services, you agree to the content of the ECCOM User Privacy Protection Policy (hereinafter referred to as "this policy"). We hope that you carefully read and confirm that you fully understand this policy and make the choices you deem appropriate in accordance with this policy guide.

This policy explains how ECCOM processes your personal information, but may not cover all situations where data may be processed. Some products or services have their own specific privacy statement, which specifically explains how we treat your personal information. If there is any inconsistency between this policy and a specific privacy statement, the specific privacy statement shall prevail.

1. Collection and use of personal information

Personal information refers to all kinds of information recorded electronically or in other ways that can identify the identity of a specific natural person or reflect the activity of a specific natural person, either alone or in combination with other information. When you use our products, receive our services, or interact with us, you will directly submit personal information to us; to the extent permitted by law, we will also obtain personal information from third-party partners; we will also collect you The content of the message sent to us to obtain your personal information. In some cases, you may choose not to provide us with personal information, and if you choose not to provide it, you may not be able to use the related products or receive related services.

1.1. We may, but are not limited to, collecting or using your personal information for the following purposes

a) Provide services to you and meet your individual needs. Send you important notifications.

b) Product development and service optimization. For example, when our system fails, we record and analyze the information generated when the system fails to optimize our services.

c) security. For example, we use your information for purposes such as identity verification, security protection, anti-fraud monitoring, archive backups, and customer security services.

d) contact you with your consent. Recommend you ads, news, etc. that may interest you.

e) Management software. For example, software certification, software upgrades, etc.

f) Certification and management of suppliers and business partners, communicating with or conducting business with suppliers and business partners.

g) Comply with and enforce applicable legal requirements, relevant industry standards or our policies.

h) invite you to participate in surveys about our services.

1.2. Non-personal information refers to information data that by itself cannot directly contact any particular individual. We may collect, use and disclose non-personal information for any purpose. We will try our best to distinguish your personal and non-personal information, and process the above information separately. If personal information data is mixed with non-personal information data, it will be treated as personal information.

1.3. In the following situations, we do not need to obtain your authorization to collect or use personal information

a) those related to national security and national defense security;

b) related to public safety, public health, and major public interests;

c) related to crime investigation, prosecution, trial and judgment enforcement;

d) Out of the protection of the important legal rights and interests of the personal information subject or other individuals, but it is difficult to obtain their consent;

e) The personal information collected is disclosed by the subject to the public;

f) your personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure, etc .;

g) necessary to enter into a contract at your request;

h) necessary for maintaining the safe and stable operation of the products and services provided;

i) necessary for legal news reporting;

j) It is necessary for academic research institutions to conduct statistical or academic research based on the public interest, and to provide the results of academic research or description to the outside world, and de-identify the personal information contained in the results;

k) Other circumstances required by laws and regulations.

1.4. Personal Information Use Rules

We will use your personal information in accordance with this policy. After collecting personal information, we will de-identify the data through technical means, and the de-identified information will not be able to identify the subject. Please understand and agree that we have the right to use the de-identified information; and without disclosing your personal information, we have the right to analyze and commercialize the user database. All personal information provided by you while using our products or receiving our services will be deemed to be your continued authorization to us unless you delete or refuse our collection. We collect statistics and may share these statistics with the public or third parties to show usage trends. When we display your personal information, we will desensitize your information by using methods such as content replacement and anonymous processing to protect your information. Your consent will be obtained when we use your personal information for other purposes not specified in this policy, or when we use personal information collected for specific purposes for other purposes.

2. Cookies and similar technologies

2.1. Cookies

A cookie is a plain text file stored on a computer or mobile device by a web server, whose content can only be retrieved or read by the server that created it. Cookies usually contain identifiers, site names, and numbers and characters that help websites store user preferences.

You have the right to choose to accept or reject cookies. If you do not explicitly refuse, ECCOM or third-party partners will store or retrieve cookie files on your computer or other devices for statistical research, management of the website, and to provide you with a personalized user experience and services. If you choose to decline cookies, you may not be able to enjoy the best service experience, and some services may not work properly.

2.2. Similar technologies

In addition to cookies, ECCOM also uses other similar technologies on the website, including but not limited to web beacons and pixel tags. For example, the email we send you may contain a click URL linking to the content of the ECCOM website. If you click on the link, we will track the click to understand your preferences and use it to improve our products and services. A web beacon is usually a transparent image embedded in a website or email. With the help of the pixel tags in the email, we can know if the email was opened. If you don't want your activity to be tracked this way, you can unsubscribe at any time.

3. Personal Information Disclosure

ECCOM may disclose your personal information to third parties in order to provide the products or services you require. Where required by law or policy, we may also disclose your personal information to law enforcement or other government agencies. We may also disclose your personal information where reasonably necessary and appropriate.

We may disclose your personal information including, but not limited to:

a) if you agree in advance, we may share your personal information with third parties;

b) For the purpose of external processing only, we may share your personal information with third-party partners and ask the third-party partners to properly handle the relevant information;

c) As your business grows, share your personal information with third parties in transactions such as mergers, acquisitions, and asset transfers. In this case, we will inform you through notices, announcements and other forms, and continue to protect or require new managers to continue to protect your personal information in accordance with laws and regulations and standards not lower than those required by this policy;

d) Use the collected personal information for big data analysis. We may disclose and share with the partners personal information that does not contain identified content after processing to understand user preferences and let the public understand the overall use trends of our products and services;

e) disclose your personal information to third parties based on legal or policy requirements.

4. Personal Information Management

ECCOM is aware of the importance you attach to the security of your personal information and protects your rights to manage your personal information. You can access, modify, delete your personal information when using our products or receiving our services, or contact us to assist you in managing your personal information. The scope and manner in which you can access, modify and delete personal information will depend on the specific products you use and the specific services you receive , and we recommend that you read the relevant privacy statement carefully.

Within the scope of this policy and other reasonable circumstances, ECCOM will collect and use your information. If you find that we have violated laws, regulations or related agreements to collect and use your personal information, you can ask us to delete it. If you find that your personal information we collected and used is incorrect, you can ask us to correct it. Please contact us using the contact details listed in this policy. However, due to policy restrictions and technical limitations, we may not be able to meet all your requirements. And when you access, modify and delete relevant information, we may require you to verify your identity to ensure the security of your personal information.

5. Personal information security

ECCOM promises to do its best to take reasonable measures to protect the security of your personal information. To prevent unauthorized access, disclosure, or other similar risks, we have implemented reasonable physical, electronic, and management measures processes to protect your personal information.

Your personal information is stored on secure servers and is always protected. We categorize your information based on importance and sensitivity, and guarantee the highest level of security for your personal information. We guarantee that employees who use your personal information for providing products and services to you and third-party service providers have signed strict confidentiality contracts. We have special access control measures for data storage. We regularly review the collection, storage and use of information, including physical security measures to prevent any unauthorized access and use.

You should be aware of the risks of using the Internet. Therefore, we cannot guarantee the security or integrity of any personal information when transmitted bidirectionally over the Internet. If there is any leakage of personal information or data, we will promptly notify the supervisory authority, launch an emergency plan, and inform the relevant parties in the form of push notifications and announcements.

6. Third parties

In order to guarantee and enrich your service experience, third parties other than ECCOM and its partners (hereinafter referred to as "third parties") may provide you with content or Internet links. You can choose whether to access third-party links and whether to use third-party products. We have no control over third parties, and the collection and use of personal information by third parties is not subject to this policy. Please review the third party's privacy policy before submitting personal information to the third party.

7. Personal Information Protection Across Countries

The products and services provided by ECCOM to you may involve resources and servers in different countries or regions. Your personal information may be transmitted or accessed across countries, and the countries or regions involved may have different personal information protection laws, and there may not even be laws related to personal information protection. In such cases, we will take appropriate measures to protect your personal information data , such as using standard contracts approved by relevant authorized units when necessary, and taking other reasonable technical and organizational information security measures when necessary.

8. Update of this policy

ECCOM reserves the right to update and modify this policy. In order to provide you with better service, we will update this privacy policy in due course and publish the latest version here. If there are major changes to this privacy policy, we will take appropriate steps to send you notice of the changes through possible channels. However, without your explicit consent, we will not reduce your rights under this privacy policy. The updated new version of the privacy policy will apply from the effective date specified in the notice or website, and we recommend that you regularly check this page for the latest privacy policy terms. If you continue to use our products or accept our services, you will be deemed to accept the updated version of the privacy policy.

9. Contact Us

If you have any questions, comments or suggestions about this policy or other related matters, please contact us through the following methods. We will review the issues and respond as soon as possible.

Email: TAC@safrn.com

Customer Service Phone: 400-820-5-820, 800-820-5-820

Note: This ECCOM User Privacy Protection Policy takes effect on November 20, 2018.