Thank you for visiting the official website of SpacemiT (Hangzhou) Technology Co. Ltd www.spacemit.com. This website is operated by SpacemiT (Hangzhou) Technology Co. Ltd. (hereinafter referred to as “we”). We understand the importance of personal information and will do our best to protect your security. We will protect your personal information in accordance with the requirements of all national laws and regulations and abide by the principles of consistent rights and responsibilities, clear purpose, opt-in consent, minimum sufficiency, openness and transparency, ensuring security and subject participation. To help you understand what personal information we collect about you through this website and how we use, store, share and transfer this information when you use this website, we have developed a Privacy Policy (hereinafter referred to as “this Policy”). Please read this policy carefully, especially the content in bold type. If you have any questions, comments or suggestions, please contact us through the contact information in Section XI of this policy.

1. Scope of this policy

This policy applies to the services we provide to you through this website. It should be noted that this policy does not apply to services provided to you by other third parties. For example, third-party services or websites you link to through this website. You understand that these services are provided to you independently by third parties, and the third parties will be solely responsible for the processing of your personal information in accordance with their policies or user agreements.

2. How we collect and use your personal information

“Personal information” refers to various information related to identified or identifiable natural persons recorded electronically or otherwise, excluding anonymized information.

When you use this website, we will collect and use the personal information necessary to provide related services in the following ways:

1. Browse this website

When you browse the website through a computer or mobile device, we will collect the following information from you:

1. Technical information such as Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, access time, IP geography, link origin, entry page, search terms, Visit identification code, visit duration, number of pages visited, last page, last visit time, visit type (whether it was the first visit), visit frequency, operating system, network service provider, locale, screen resolution, screen color (bits), Flash version, whether to support cookies, whether to support JAVA, opening time, stay time, stay page address and other technologies you use on your device to access this website.

• Usage information, such as information about how you use our website and services.

• Contact us

When you contact us through this website, including but not limited to wanting to requesting product information and applying to our job vacancies, we will collect your name, phone number, email address, mailing address, and other information that can allow others to identify you and the information you proactively send us. You know and agree that we may contact you by email, phone number and other contact methods after reading your information.

In order to ensure the realization and safe and stable operation of the relevant functions of this website, we will access software development kits (SDKs) provided by third parties to achieve this purpose. When meeting new service requirements and business function changes, we may adjust the third-party SDKs we access, and disclose the latest information on access to third-party SDKs to you in this policy in a timely manner. Please note that there may be some changes in the data type of the third-party SDK due to version upgrades, policy adjustments, etc., and the relevant privacy protection instructions are attached for reference. For details, please refer to the official instructions published.

Product/Type	Use purpose	Scenes to be used	Types of personal information collection	Collection method	Third party company name	Privacy statement
Baidu statistics	[Used to help developers understand how users use web pages and optimize user experience]	【When the user browses the web page】	[Device information, log information, application list information, passwords in the clipboard, links, etc.]	[SDK local collection, no data sharing involved]	【Beijing Baidu Netcom Technology Co., Ltd.】	https://tongji.baidu.com/web/help/article?id=330&type=0

Please note that we also collect, use and share aggregated data such as statistical or structural data. Aggregated data may come from your information, but it is not personal information as it does not directly or indirectly identify you. We have the right to use it for any lawful purpose (for example: we may aggregate your usage information to find out how many users are accessing specific website features, improving existing products and services). If we combine or associate aggregated data with your personal information so that it can directly or indirectly identify you, we will treat the combined information as personal information and will process it as set out in this statement.

3. Exceptions to authorized consent

According to relevant laws and regulations, the collection and use of your personal information does not require your authorization and consent in the following situations:

1. Necessary to enter into and perform a contract to which you are a party;
2. In connection with our performance of our obligations under laws and regulations;
3. Necessary to respond to public health emergencies, or to protect the life, health and property safety of natural persons in emergencies;
4. Related to national security and national defense security;
5. Related to criminal investigation, prosecution, trial and execution of judgments;
6. In order to protect the personal information subject or other individual’s lives, property and other important legitimate rights and interests, but it is difficult to obtain your consent;
7. The collected personal information is disclosed to the public by you;
8. Collect personal information from legal publicly disclosed information, such as legal news reports, government information disclosure and other channels;
9. Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and disposing of faults in the products or services;
10. Carry out news reports, public opinion supervision and other acts for the public interest, and process personal information within a reasonable range;
11. When it is necessary for an academic research institution to carry out statistical or academic research based on public interests, and when it provides the results of academic research or description, it de-identifies the personal information contained in the results;
12. Other situations stipulated by laws, regulations or national standards.

4. How we use cookies

To ensure the proper functioning of our products, we store small data files called Cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of Cookies, this website can store data such as your preferences. We will not use Cookies for any purpose other than those described in this policy. You can manage or delete Cookies according to your preferences. See About Cookies.org for details. You can clear all Cookies saved on your computer, and most web browsers have a Cookie-blocking feature. However, if you do this, you will need to personally change your user settings each time you visit this website.

5. How we store your personal information

1. Storage location

Personal information we collect and generate in the People’s Republic of China will be stored in the People’s Republic of China. If the laws and regulations clearly stipulate, or we have obtained your express authorization, we will provide your personal information to overseas entities after fulfilling the obligations stipulated by the laws and regulations. We will ensure that your personal information is protected to a level not lower than that specified in this policy through contracts and other forms.

• Storage period

We will only retain your personal information for as long as is necessary to achieve the purposes described in this policy, unless there is a mandatory retention requirement by law. We judge the storage period of personal information mainly by referring to the following standards and whichever is longer:

1. To complete the business functions you agree to use;
2. To ensure the safety and quality of our services to you;
3. A longer retention period that you agree to;
4. Whether there are other special arrangements for retention periods.

After the retention period has expired, we will delete or anonymize your personal information as required by applicable law.

If we stop operating this website and related services, we will stop collecting your personal information in a timely manner and will notify you of the cessation of operation in the form of an announcement. At the same time, delete or anonymize the personal information we store.

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

1. Share

We will not share your personal information with any companies, organizations and individuals with the following exceptions:

1. We will share your personal information with other parties with your express consent.
2. We may share your personal information externally in accordance with laws and regulations, litigation and dispute resolution needs, or as required by administrative and judicial authorities.
3. To the extent permitted by laws and regulations, it is necessary to share your personal information in order to protect us, our group or partners, you or our other users, or the public interest and property from harm.
4. Shared within our group. To facilitate our provision of services to you, we may share your personal information within our group, with any of our existing or future subsidiaries, affiliates (whether through equity control, agreement control or through Subsidiaries and branches that can be controlled by other means) which are collectively referred to as the “Group”. However, we will only share necessary personal information, and the Group’s use of your personal information is governed by this policy, or a group policy that provides your personal information with substantially the same level of protection as this policy with your authorization and consent. We and our group will strictly abide by our personal information and data security protection systems and policies.

• Transfer

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

• With your express prior consent or authorization;
• Provided as necessary in accordance with applicable laws and regulations, legal process requirements, mandatory administrative or judicial requirements;
• Provided in accordance with the relevant agreements signed with you (including electronic agreements signed online and the corresponding rules of this website) or other legal documents;
• As our business develops, we and our group may enter mergers, acquisitions, asset transfers or other similar transactions. If the relevant transaction involves the transfer of your personal information, we will require the new company, organization and individual holding your personal information to continue to be bound by this policy, otherwise we will require the company, organization and individual to obtain your authorization and consent again.

• Public disclosure

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

• With your express consent;
• Legal-Based Disclosures: We may publicly disclose your personal information when required by law, legal process, litigation or government authorities.

7. How we protect your personal information

We take the security of your personal information very seriously, and have taken industry-standard security measures to protect the personal information you provide to prevent unauthorized access, public disclosure, use, modification, damage or loss of the data:

• We have set up a dedicated person in charge of personal information security, who is responsible for handling all matters related to our products and services that may involve users’ personal information, as well as planning and formulating company policies, reviewing the user agreement of each product, and supervising the work of each product, and the principles and information processing mechanisms, etc. We ensure the security of information by establishing special management systems, processes, organizations and other management measures.
• We deploy an access control mechanism on the server side and adopt the principle of least sufficient authorization for staff who may have access to your personal information.
• We will perform account auditing and monitoring of server operations. If we find a server operating system with security problems announced externally, we will upgrade the server security as soon as possible to ensure the security of all server systems and applications.
• We have formulated a contingency plan for cyber security incidents and allocated sufficient resources to ensure the implementation of the contingency plan. If our physical, technical or management protection measures are unfortunately damaged, we will launch emergency plans in a timely manner to prevent the expansion of security incidents, report them to the competent national authorities in accordance with the requirements of laws and regulations, and promptly take reasonable and effective means such as push notifications and announcements to the public. We will inform you of the basic situation of the security incident, the possible impact, the measures that have been taken or the measures to be taken, etc.

8. Your rights

During your use of this website, you can access and manage your personal information in the following ways:

1. Inquiry and correction of your personal information

You can contact us to inquire and correct your personal information through the contact information in Article 11 below.

• Delete your personal information

You have the right to ask us to delete your personal information when:

• We have illegally collected your personal information without your consent.
• Our processing of your personal information violates legal and regulatory requirements.
• We use and process your personal information in breach of our agreement with you.
• You are no longer using our website, products or services.
• We stop serving you.

You can contact us to request deletion of your personal information through the methods provided in Section 11 of this policy, and we will reply within 15 working days. When we delete your personal information from the server, we may not delete the corresponding data from the backup system immediately but will delete the information when the backup is updated.

Please note that we may not be able to delete your personal information if the storage period stipulated by laws and administrative regulations has not expired, or if it is technically difficult to delete your personal information, but we will stop processing your personal information in a timely manner.

• Withdraw your consent

Each business function requires some basic personal information to be completed. For the collection and use of additionally collected personal information, you may give or withdraw your consent at any time. Your withdrawal of permission will not affect our previous processing activities of your personal information, but we will not continue to process your personal information. You can contact us to change the scope of your authorization and consent through the contact information in Article 11 below.

• Get a copy of your personal information

You can contact us to obtain a copy of your personal information through the contact information in Article 11 below. Under the premise that the relevant technology is feasible, we can also directly transmit a copy of your personal information to a third party designated by you according to your request.

9. Personal Information protection of minors

Our website and services are primarily intended for adults. Children under the age of 14 may not use our website or services without the consent of a parent or guardian.

For the collection of children’s personal information with parental consent, we will only use or publicly disclose this information as permitted by law, expressly consented by a parent or guardian, or necessary to protect the child.

If we discover that we have collected personal information from a child without first obtaining verifiable parental consent, we will try to delete the relevant data as soon as possible.

10. Changes and amendments to this policy

Our personal information protection policy is subject to change. We will not limit your rights under this Policy without your express consent.  

We will provide prominent notices of material changes to this policy. You can also browse this website to view the latest policy at any time.

Material changes referred to in this policy include, but are not limited to:

• Where there has been a major change in our service model, such as the purpose of processing personal information, the type of processing personal information, the way of using personal information, etc.;
• We have significant changes in control such as changes in owners caused by mergers and acquisitions, etc.;
• Changes to the main objects of personal information sharing, transfer or public disclosure;
• Material changes in your rights to participate in the processing of personal information and the way they are exercised;
• When our department responsible for handling personal information security, contact information and complaint channels changes;
• When the personal information security impact assessment report indicates that there is a high risk;

Your continued use of our website after such changes and revisions will be deemed your agreement to the changes and revisions to this policy.

11. How to contact us

SpacemiT (Hangzhou) Technology Co., Ltd. is the operator of this website and the processor of your personal information. The address is Room 3901, Building 2, European and American Financial City, Cangqian Street, Yuhang District, Hangzhou City, Zhejiang Province. If you have any questions, comments, suggestions or complaints about our policies and the handling of your personal information, please send an email to [hr@space-t.cn]  to contact us.

In general, we will respond to your request within 15 working days. You understand that due to material review, business verification, operational procedures, etc., the processing time for your request may be longer than the above time limit.

12. Effectiveness of this policy

This policy was formulated on [ 31 August 2022] and will take effect on [31 August 2022].