Privacy Policy

Updated and effective on October 24, 2022

Welcome to XUNLU AI!

We are committed to protecting the privacy and personal information you provide when you use our website (collectively, "Personal Data") and to ensuring that our collection, use, storage and transfer of Personal Data complies with the relevant laws and regulations and consumer protection-related laws and regulations. To ensure that you have full confidence in our handling of personal data, please read and understand the terms of this Privacy Policy. In particular, by using our website, you will be deemed to have accepted the terms of this Privacy Policy in its entirety. We may revise the terms of this Privacy Policy from time to time based on XUNLU AI's operational, legal or compliance needs. If such revisions materially change the Privacy Policy, we will post the revised policy on the XUNLU AI website or notify you by other appropriate means. Your continued use of the XUNLU AI website and services after the revision is announced will be considered as your acceptance of the revised Privacy Policy.

This policy will help you understand the following:

I. Scope of application of this policy

II. Definition and scope of personal information

V. How we will share, transfer, and publicly disclose your personal information

VI. How we store your personal information

VII. How we protect your personal information

VIII. Your rights

IX. Protection of minors

X. How your personal information is transferred globally

XII. Revisions and Updates to this Policy

XIII. Application of law and dispute resolution

XIV. How you can contact us

I. Scope of Application

This privacy policy applies to all services provided by the platform, your visit to the platform website and/or login to the relevant client to use the services provided by the platform, are subject to this privacy policy. In particular, this privacy policy does not apply to services provided to you by other third parties, for example, when a seller relies on the platform to provide services to you, the personal information you provide to the seller does not apply to this privacy policy.

B. Definition and scope of personal information

(a) Personal information: refers to all kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding information after anonymization.

(2) Sensitive personal information: personal information that, if leaked or used illegally, could easily lead to the infringement of a natural person's human dignity or endanger the safety of his or her person or property, including biometric, religious beliefs, specific identity, medical and health care, financial accounts, trajectory and other information, as well as the personal information of minors under 14 years of age.

III. How we collect and use your personal information

We collect personal information from you when you register for our services, access our services or otherwise provide us with information. The information collected as described below will be used by our website to provide you with refined and quality services.

(i) Merchant Information

What information we collect How we use this information

Information you provide to us about yourself and your business, such as your name, the names of your employees or others associated with your business, company name, address, email address, phone number, and microphone number To provide you with our Platform services or other related services (for example, to identify you, to contact you about the Platform, to invoice you) To advertise and market products or features to you To fulfill legal requirements To prevent fraudulent use of our services

For payment information that you provide to us, such as your credit or debit card number or bank account number or other financial information To provide you with the use of our platform or other related services To charge you for our services To provide you with a third party payment service channel

Information about how you access the XUNLU AI website, your account and our Platform, including information about the device and browser you are using, your Internet connection, your IP address, and details about how you navigate our website and Platform. We collect some of this information directly from your device through the use of "cookies" or other similar technologies. To provide you with, and improve, our Platform and other services (e.g., discovering ways to make our Platform easier to use) To personalize your experience using the Platform (e.g., by displaying applications that we think will be useful to you) To promote and market products or features to you To prevent fraudulent use of our services

To provide us with government-issued identification information (such as a business license, business code, social security number, social information number, employer identification number or tax identification number, or your personal identification number if you are a self-employed business owner) To help us identify or verify your account when we need to verify your identity (for example, to prevent identity theft or fraud) To confirm that you are who you say you are when you contact us Ownership To fulfill a legal requirement

For details of goods and products you provide to us for sale through the Platform For you to provide services on our Platform To prevent fraudulent use of our services

Records of your communications with us for any reason (such as chats, phone calls or emails with our customer service department) To provide you with services on our Platform To provide you with, and improve, our Platform and other services

(ii) Consumer Information

What information we collect What information we collect

Information you provide about yourself, such as your name, billing address, shipping address, email address, phone number, and payment information. To provide our services to merchants and enable them to operate their businesses, for example, to enable them to complete transactions, screen orders for fraud and risk, ship orders, and contact you about new products or offers

Records of your communications with us for any reason (such as chats, phone calls or emails with our customer service department) To provide you with services on our platform To provide you with, and improve, our platform and other services

Information about how you access the XUNLU AI website, your account and our Platform, including information about the device and browser you are using, your Internet connection, IP address, and details about how you navigate our website and Platform. We collect some of this information directly from your device through the use of "cookies" or other similar technologies. To provide our services to merchants and enable them to operate their businesses, for example, by providing merchants with analytics on the number of visitors to their stores and helping them troubleshoot and improve their stores

(iii) Information about visitors to our website, inquiries from customers

What information we collect How we use it

Information you provide to us about yourself and your business, such as your name, the names of your employees or others associated with your business, company name, address, email address and phone number. To provide you with and improve the applications or other services you want to try (for example, to confirm your identity, to contact you about the Platform, to invoice you) To confirm that it is you who is contacting us To promote and market products or features to you To fulfill legal requirements

Payment information that you provide to us, such as your credit or debit card number or bank account number To enable you to make a successful payment

Records relating to your communications with us for any reason (such as chats, phone calls or emails with our customer service department) To provide you with services on our Platform To provide you with, and improve, our Platform and other services

Information about how you access and use XUNLU AI applications, websites and other services, including information about the device and browser you are using, your Internet connection, your IP address, and details about how you navigate our applications and sites (including the search terms you may enter). We collect some of this information directly from your device through the use of "cookies" or other similar technologies. To provide you with, and improve, our platform and other services (e.g., discovering ways to make our platform easier to use and navigate) To personalize your website browsing experience (e.g., changing and optimizing the layout of our web pages) To promote and market products or features to you To provide app developers with comprehensive analytics related to their apps on the XUNLU AI App Store.

IV. How we use cookies and similar technologies

We will collect some of your non-personalized information through your IP address, such as the nature of your browser, the type of operating system, the domain name of the ISP that provides you with access, etc., in order to optimize the pages displayed on your computer screen. By collecting this information, we will perform traffic statistics in order to improve the administration and service of our website.

Cookies are a technology that automatically sends cookies to your browser and stores them on your computer's hard drive when you visit our website with a cookie device, which is responsible for recording your activities, personal information, browsing habits, spending habits and even credit history when you visit our website in the future.

Using Cookies technology, this website can provide you with more thoughtful and personalized services. This website will use Cookies to track your shopping preferences and provide you with information of interest or store your password so that you do not have to repeatedly enter your password each time you visit this website.

V. How we will share, transfer and publicly disclose your personal information

(I) Sharing

XUNLU AI will not provide your personal information to a third party without your consent or authorization. However, with your confirmed consent, XUNLU AI may share your personal information under the following circumstances:

1. Sharing with consent: XUNLU AI will share your personal information with other parties after obtaining your explicit consent.

2. Shared to XUNLU AI's affiliates: Your personal information may be shared with XUNLU AI's affiliates within the scope of the purposes of use stated in this policy. As a policy, we will only share the necessary information. If an affiliated company wishes to change the purpose of processing personal information, your authorized consent will be sought again. 3.

3. Sharing to authorized partners: Subject to relevant laws, XUNLU AI may share some of your personal information with the following entities (which may include both domestic and overseas) in order to provide better customer service and user experience. We will only process your personal information for specific, explicit and legal purposes and will only share information that is necessary to provide the service. At the same time, we will enter into strict confidentiality agreements with them, requiring them to handle personal information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures.

(1) Vendors: These include, but are not limited to, suppliers, software vendors, clearing and receiving, warehousing and logistics, event and trade show services, agents, etc. who are working to meet your website needs. These suppliers may contact you as needed to complete related product services;

(2) Financial institutions and third-party payment providers: We may share certain order information with financial institutions or third-party payment providers when you book an order, request a refund, purchase insurance, and we will further share other necessary information, such as IP addresses, with the relevant financial institutions when we believe it is necessary for fraud detection and prevention purposes;

(3) Business partners: We may work with partners to provide products or services to you, including courier services, communication services, customer service, marketing, advertising, etc.

(4) Sharing under legal circumstances: We may share your personal information to the public in accordance with laws and regulations, the need for litigation dispute resolution, or as requested by administrative or judicial authorities in accordance with the law.

(ii) Transfer

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

1. transferring with obtaining explicit consent: after obtaining your explicit consent, we will transfer your personal information to other parties;

2. in the event of a merger, acquisition or bankruptcy and liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this privacy policy, or we will require that company or organization to seek your authorized consent again.

(iii) Public Disclosure

We will only publicly disclose your personal information if we take security measures that are consistent with the law and industry standards, and only if we

1. with your express consent;

2. based on laws, regulations, legal proceedings, litigation or mandatory requests from government authorities. However, we guarantee that, subject to laws and regulations, when we receive a request for disclosure of information as described above, we will require that the corresponding legal documents must be produced.

VI. How we store your personal information

We will store the relevant personal information collected in the following forms: structured data storage. The server where personal information is stored is located in the People's Republic of China. Meanwhile, we will only retain your personal information for the shortest period of time necessary to achieve the purpose stated in this policy, unless there are mandatory retention requirements by law. We will anonymize the logs of user behavior involved in XUNLU AI platform services. Our criteria for judging the aforementioned period include:

(i) Completing the transaction purposes related to you, maintaining the corresponding transaction and business records, and responding to your possible inquiries or complaints;

(ii) Ensuring the security and quality of the services we provide to you;

(iii) Whether you agree to a longer retention period;

(d) Whether there is any other special agreement on the retention period.

If your personal information is retained beyond the retention period, we will delete or anonymize your personal information in accordance with the requirements of applicable law (if you are a minor, we will handle your personal information accordingly after the retention period has expired, in accordance with the requirements of relevant laws and regulations). If deletion in accordance with the relevant requirements is not possible due to special circumstances (e.g. technical conditions), we will stop processing other than storing and taking the necessary safety protection measures, and will explain this part of the matter to you.

VII. How we protect your personal information

(a) We collect, use, store and share your personal information in strict accordance with this policy agreement and the provisions of the Law of the People's Republic of China on the Protection of Personal Information, the Law of the People's Republic of China on Network Security, the Law of the People's Republic of China on Data Security, the Law of the People's Republic of China on the Protection of Minors, the Code of Personal Information Security of Information Security Technology, the Regulations on the Protection of Children's Personal Information Network, and other relevant laws and regulations. share your personal information. If there is no clear agreement on the contents related to personal information protection in this policy, the provisions of relevant laws and regulations shall prevail.

(b) We have used security measures in accordance with industry standards to protect the personal information you provide against unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonably practicable steps to protect your personal information. For example, the exchange of data (such as credit card information) between your browser and the Service is protected by SSL encryption; we also provide https secure browsing of our website; we use encryption technology to ensure the confidentiality of data; 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; we have established a comprehensive internal management system and operational procedures, and a detailed contingency plan for personal information security incidents; and we will hold regular training on personal information security to enhance our employees' awareness of the importance of protecting personal information.

(iii) We will take all reasonable and feasible measures to avoid collecting irrelevant personal information as far as possible. We will only retain your personal information for the shortest period necessary to achieve the purposes described in this policy, unless an extended retention period is required or permitted by law.

(d) The Internet is not an absolutely secure environment, and since e-mail, instant messaging and your communications with our other users are not encrypted, we strongly recommend that you do not send personal information through such means and ask that you take proactive measures to protect the security of your personal information, including, but not limited to, using complex passwords, changing your password regularly, and not disclosing your account password and other personal information to others.

(e) Please understand that the Internet environment is not 100% secure and we will do our best to ensure the security of any information you send to us. However, due to the limitations of technology and the possible existence of various malicious means, it is not always possible to guarantee 100% security of information, even if every effort is made to strengthen security measures. In the unfortunate event of a personal information security incident, we will immediately take remedial measures and notify the department responsible for personal information protection and you personally in accordance with the requirements of laws and regulations of the following matters: the basic situation of the security incident (including the type of personal information involved in the security incident and the cause) and the possible harm, the measures we have taken or will take to deal with it, the suggestions you can independently prevent and reduce the risk, the remedial measures for you remedial measures, our contact information, etc. XUNLU AI will inform you by email, letter, telephone, push notification, etc. If it is difficult to inform you one by one, we will take reasonable and effective ways to publish the announcement.

VIII. Your rights

In accordance with the relevant Chinese laws, regulations and standards, as well as the common practices of other countries and regions, we protect your rights to exercise the following rights to your own personal information:

(A) the right to inquire

You have the right to access your personal information, except for the exceptions provided by laws and regulations. If you want to check your account information, you can log in XUNLU AI platform to check it.

(B) Right to Correction

When you have the need to correct your information, you can modify your information on XUNLU AI platform according to the prompt on the page, or contact XUNLU AI customer service for correction. For security and identification reasons or according to laws, regulations and supervision, you need to pass the verification for the modification of key information, such as your authenticated name or bound cell phone number.

(iii) Right to delete

In the following cases, you can request us to delete personal information:

1. if the purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose of processing

2. if we cease to provide the product or service, or the retention period has expired

3. if we process your personal information without your consent or if you withdraw your consent;

4. if we process your personal information in violation of laws, administrative regulations or in breach of an agreement;

5. in other cases stipulated by laws and administrative regulations.

You can contact us by calling the customer service number, we will help you to delete the relevant information after verifying your identity. If the platform ceases operation or stops providing relevant services, we will promptly stop the activities of continuing to collect your personal information, notify you of the cessation of operation in the form of one-by-one delivery or announcement, and delete or anonymize the personal information held.

(iv) Right of revocation

Each business function requires some basic personal information in order to be completed (see "III. How we collect and use your personal information" section of this policy). You may give or withdraw your authorized consent to the collection and use of additional personal information collected at any time. You can do this on your own in the following ways:

You can withdraw some of your authorization by unbinding, modifying your cell phone permission settings, deleting relevant information, etc., or you can revoke your authorization by closing the function. In addition, you can also revoke authorization by contacting us at the customer service number.

After you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawal of consent or authorization, and will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the processing of personal information previously carried out based on your consent or authorization.

(v) Right of cancellation

You can apply for cancellation of the account registered for the use of this product and/or service at any time, you can log in XUNLU AI official website for cancellation operation. You can also call our customer service number to request cancellation. Before you cancel your account, we will ask you to perform the necessary identity verification, including personal identity, security status, device information, etc. You know and understand that the act of account cancellation is irreversible, and after account cancellation, we will stop providing products and/or services to you, and delete your personal information or anonymize the relevant information according to your request, but if there is relevant personal information in accordance with the laws and regulations of the retention period has not expired or there are other circumstances that are not suitable for deletion according to the law, we will stop except for the storage and We will stop processing other than storing and taking the necessary safety protection measures.

(vi) Obtaining a copy of personal information

You have the right to obtain a copy of your personal information, you can request us to send you a copy of your personal information by calling our customer service number, and after verifying your identity, we will send you a copy of your personal information.

(vii) Binding information system automatic decision making

In some business functions, we may make decisions based solely on non-human automated decision-making mechanisms, including information systems and algorithms. We will ensure transparency in decision making and fair and equitable results, and will not treat you unreasonably differently in terms of transaction conditions such as transaction prices. If a decision made through automated decision-making significantly affects your legitimate rights and interests, you have the right to request an explanation or reject a decision made solely through automated decision-making.

(viii) Responding to your requests as described above

For security purposes, you may be required to provide a written request or otherwise prove your identity. We will process your request after verifying and verifying your identity and respond within 15 business days or within the time period specified by law or regulation.

For your reasonable requests, we do not charge a fee in principle, but for requests that are repeated several times and exceed reasonable limits, we will charge a cost fee depending on the circumstances. We may refuse requests that are unnecessarily repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical (for example, involving the backup of information stored on tapes).

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

1. in connection with the performance of our obligations under laws and regulations

2. directly related to national security or national defense security

3. directly related to public safety, public health, and significant public interests

4. directly related to criminal investigation, prosecution, trial and execution of judgments, etc;

5. where we have sufficient evidence to show that you have subjective malice or abuse of rights

6. for the purpose of safeguarding your or other individuals' life, property and other significant legitimate rights and interests

7. where responding to your request would result in serious damage to the legitimate rights and interests of you or other individuals or organizations

8. involving commercial secrets.

IX. Protection of minors

(a) We attach great importance to the protection of minors' information. If you are a minor under the age of 18, please read this policy carefully under the guidance of your parents or guardians and submit your personal information and use our products and/or services with the consent of your parents or guardians. In the event that personal information of minors is collected with the consent of their parents or guardians to use the products and/or services of the Platform, we will only use, share, transfer or disclose this information as permitted by law or regulation, with the express consent of the parents or guardians or as necessary to protect the minors.

(b) In order to strengthen the protection of personal information of minors, in addition to following other provisions under this policy, we will follow the principles of legitimate necessity, informed consent, clear purpose, safety and security, and use in accordance with the law to protect the personal information of minors in accordance with relevant national laws and regulations and the provisions of this policy, as follows:

1. We will store separately the information collected from minors and personal information of users other than minors, and we will adopt encryption measures no lower than those of industry peers to store minors' information and ensure the security of minors' information.

2. We will designate a person responsible for the protection of minors' information, and any staff accessing minors' human information must be approved in writing by the minors' information protection personnel (including email, SMS, WeChat and other electronic information interaction methods) and form a written record of the access; at the same time, we will adopt technical measures no lower than those of industry peers to avoid illegal copying and downloading of minors' personal information.

3. If we transfer personal information of minors to a third party, we will conduct a security assessment by ourselves or entrust a third party organization and form a written assessment report, in addition to obtaining the consent of the parents or guardians of the minors again and meeting the above principles.

4. If we find that we have collected personal information of minors without prior verifiable parental or guardian consent, we will seek to delete the relevant data as soon as possible.

X. How your personal information is transferred globally

In principle, personal information collected and generated by us in the People's Republic of China will be stored in the People's Republic of China. If it is necessary to transfer your personal information outside of China, we will obtain your authorized consent separately, in which case we will adequately protect your personal information in accordance with this policy.

XI. Third Party Platforms

Some of our applications may use the services of third-party platforms, and we are not responsible for the content or privacy policies of any third-party services. We encourage you to carefully review the privacy policies of any third-party services you visit before using them.

XII. Revisions and Updates to this Policy

We have the right to revise and update this policy from time to time, and we will publish the revised and updated policy on our official website and XUNLU AI mobile terminal, if you do not agree with the revised and updated policy, you should stop using XUNLU AI products and/or services; if you continue to use XUNLU AI products and/or services after we revise and update this policy and publish it, you are deemed to agree with the revised and updated policy. If you continue to use XUNLU AI products and/or services after we have revised and updated this policy and published it, you are deemed to agree to the revised and updated policy.

We will also provide more prominent notice (including, but not limited to, the pop-up window on the website, phone call, SMS, etc.) for any significant changes that may result in substantial impairment of your rights and interests under this policy.

Such material changes include, but are not limited to:

(i) Changes in our basic situation, e.g., change of ownership due to mergers, acquisitions, reorganizations;

(ii) Changes in the scope, purpose, and rules of collecting, storing, and using personal information;

(iii) Changes in the object, scope, and purpose of providing personal information to the public;

(d) Changes in the way you access and manage personal information;

(e) Changes in data security capabilities and information security risks;

(6) Changes in the channels and mechanisms for user inquiries and complaints, as well as external dispute resolution agencies and contact information

(7) Other changes that may have a significant impact on the rights and interests of your personal information.

XIII. Legal application and dispute resolution

(a) The laws of the People's Republic of China shall apply to the conclusion, entry into force, interpretation, amendment, supplement, termination, implementation and dispute resolution of this policy in any respect. If there is no relevant provision in the law, refer to the commercial practice and / or industry practice.

(2) We will negotiate with you to resolve any disputes arising from your use of XUNLU AI products and/or services. If the negotiation fails, either party shall file a lawsuit to the people's court with jurisdiction in the location of the website owner company or website owner.

XIV. How you can contact us

If you have any questions, comments, complaints, reports and suggestions related to this policy and personal information protection, or intend to correct, delete, revoke authorization, cancel the account, obtain a copy of personal information, please contact us through the following ways, we will give feedback within 15 working days:

Name of the platform operator: Shenzhen Xunhai Technology Co.

Company name: Beijing Reindeer AI Technology

Official website: xunlu.ai

Customer Service: 400-600-2010

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