Zhejiang Huayou Cobalt Co., Ltd. (hereinafter referred to as "Huayou Cobalt", "We", "US", or "Our") deeply understands the significance of privacy to you, and respects your privacy. Before submitting any personal data to Huayou Cobalt, please read and understand this Privacy Policy (hereinafter referred to as the "Policy"). This Policy is applicable to the websites owned and operated by Huayou Cobalt. This Policy introduces the information practices adopted by Huayou Cobalt for the websites, including, what kind of information is collected, how the information is used, who is the object sharing the information, and how the information is protected.

This Policy describes how We will process your personal data. However, This Policy may not contain all possible data processing scenarios. The websites of Huayou Cobalt may contain the links to other websites. Huayou Cobalt disclaims any liability for the privacy practices or information of such other websites.

We formulate This Policy to help you understand the following aspects:

1. How does Huayou Cobalt collect and use your personal data

2. How does Huayou Cobalt use Cookie and similar techniques

3. How does Huayou Cobalt disclose your personal data

4. How to access or change your personal data

5. How does Huayou Cobalt protect your personal data

6. How does Huayou Cobalt process the personal data of children

7. Third-party providers and their services

8. How is your personal data transferred worldwide

9. How is this Policy is updated

10. How to contact Huayou Cobalt

1. How does Huayou Cobalt collect and use your personal data

Personal data refers to any information which can be used independently or in combination with other information to identify personal identity. Such personal data will be directly submitted to Us when you visit our websites, products or services and/or when you interact with Us, e.g., when you create an account with Huayou Cobalt or contact Us for support; alternatively, we may acquire your personal data by recording how you interact with our websites, products or services, e.g., using techniques such as Cookie, or receiving usage data from the software operating on your devices. We may also acquire relevant data through public sources or third-party commercial sources, to the extent permitted by law. The information We acquire is determined by the way you interact with Huayou Cobalt, including the websites you access, and the products and services you use, e.g., name, gender, company name, title, address, email, phone number, login information (account and password), picture and ID. We also collect the information you submit to Us and the messages you send to Us, e.g., inquiry information you input, or questions or other information you provide for customer support. You may have to provide your personal data in order to use the products or services of Huayou Cobalt. Under certain circumstances, you may choose not to provide your personal data to Huayou Cobalt. In that case, Huayou Cobalt may neither be able to provide relevant products or services, nor respond to or solve any problems you confront.

We may use your personal data for the following purposes:

(a) Create an account.

(b) Complete your transaction or service request, including order performance; Deliver, activate or verify product or service; Provide training and certification, and manage and handle the training and certification outcome; Participate in online or offline events; Make changes or provide any information as you require (e.g., marketing data and white paper of products or services); And provide technical support.

(c) Contact you with your consent: Send you information for any products and services that you may have interest; Invite you to attend any events, market investigations and satisfaction surveys organized by Huayou Cobalt; or Send you marketing information. If you would rather not receive such information, you may unsubscribe it at any time.

(d) Send you important notices, e.g., notifications for installation and update of operating system or applications.

(e) Provide you with individualized user experience and contents.

(f) Authenticate and manage suppliers and business partners, and communicate with or conduct business with suppliers and business partners.

(g) Carry out internal audit, data analysis and research to improve our products and services.

(h) Analyze business operating efficiency and measure market share.

(i) Carry out troubleshooting, provided that you choose to send the details of errors to Us.

(j) Synchronize, share and store the data you upload and download and the data used to execute the upload and download.

(k) Protect the safety of Our products, services and customers or users, and execute and improve Our loss prevention and anti-fraud plans.

(l) Comply with and observe applicable legal requirements, relevant industry standards and Our policies.

Huayou Cobalt may also collect and use non-identifiable information. Non-identifiable information refers to any information that cannot be used to identify a particular individual. For instance, Huayou Cobalt collects summary statistical data, e.g., website traffic. Huayou Cobalt collects this type of data in order to understand how users use Our websites, products, and services. In doing so, Huayou Cobalt can effectively improve its services and better satisfy customer demands. Huayou Cobalt may also collect, use, process, transfer, or disclose non-identifiable data at its sole discretion. We will endeavor to isolate your personal data from non-identifiable information, and use the two types of information separately. Any personal data doped with non-identifiable information is still considered as personal data.

• Huayou Cobalt processes your personal data on appropriate legal grounds in accordance with applicable legal requirements, which includes:

• Process your personal data to perform the contract when responding to your transaction or service request.

• Process your personal data with your consent.

• Process your personal data based on Our or third-parties' legitimate interests when We contact you, conduct marketing or market investigations, improve our products and services, and implements and improves Our loss prevention and anti-fraud plans, etc. The said legitimate interests include more effective management and operation of Our businesses and provision of Our products and services; safety protection of our businesses, systems, products, services and customers; internal management, and compliance with the internal policies and procedures; and other legitimate interests We set forth in This Policy;

• We may also process your personal data as required to comply with and fulfill legal obligations.

2. How does Huayou Cobalt use Cookie and similar techniques

2.1 Cookie

2.1 Cookie

To ensure the normal operation of Our websites, we may occasionally retain small data files, which are referred to as Cookies, on computers or mobile devices. A Cookie is a plain text file stored on computers or mobile devices by network servers. The contents of a Cookie can only be retrieved or read by the server that created it. Each Cookie is unique to your web browser or mobile application. A Cookie typically contains identifiers, site names, and certain numbers and characters. Based on Cookie, websites can store user preference data and other data to better serve the users. The purpose that Huayou Cobalt enables Cookie is similar to that of most websites or Internet service providers, i.e., improving user satisfaction. With Cookie, websites can remember a single visit (using session Cookie) or multiple visits (using permanent Cookie). Cookies also allow websites to save settings such as the language, font size, and other browsing preferences for your computers or mobile devices. This means that users do not need to re-configure their preferences each time they visit a website. If a website doesn't support Cookie, a user will be considered as a new visitor each time when the user opens the webpages of the website. For instance, if you log into a website and opens a new webpage of the website, the website will not recognize you, and your identification will be cancelled. Huayou Cobalt will not use Cookie for any purposes other than those stated in This Policy. You can manage or delete Cookie in accordance with your preferences. See AboutCookies.org for more details about Cookie.

Additionally, We may also use the Local Storage Object (LSO) approaches such as Flash Cookie or HTML 5 to store content information and preferences. Based on your web browsing activities, the suppliers and partners which provide certain functions or display advertising on Our website may also use HTML5 or other LSO approaches to collect and store information. The browsers of varied types may provide their respective management tools to delete HTML5 and other LSO approaches.

You can clear all Cookies saved on your computer, and most web browsers are developed with the functions of blocking Cookie. However, in that case, you may need to manually change the user settings every time visiting Our website. For more information on how to change browser settings, please visit the following link: Internet Explorer Google Chrome Mozilla Firefox Safari Opera

3. How does Huayou Cobalt disclose your personal data

Under the circumstance where certain services are offered by the authorized partners of Huayou Cobalt, Huayou Cobalt will share your personal data with the partners as set forth in This Policy. For example, when you buy a product of Huayou Cobalt online, Huayou Cobalt will have to share your personal data with the logistics service provider in order to arrange delivery or arrange partners to provide services. Moreover, as an multinational company, We may share personal data across the websites of Huayou Cobalt developed in different languages.

To the extent of appropriate legal requirements or responding to legal procedures, Huayou Cobalt may disclose your personal data to relevant law enforcement agencies or other government authorities. Huayou Cobalt may also disclose your personal data in presence of reasonable requirements, e.g., when it is necessary to disclose your personal data in order to perform the contract, or when We consider it necessary and appropriate to disclose your personal data in order to prevent personal injury or property loss or investigate on any potential or actual illegal acts.

4. How to access or change your personal data

You shall make sure that any personal data that you submit is accurate and complete. Huayou Cobalt will endeavor to maintain the accuracy and completeness of the personal data, and timely update the personal data.

To the extent of appropriate legal requirements, you may have the right to access and obtain any particular personal data of and about you that We hold; require Us to update or correct any incorrect personal data of and about you; reject or restrict Our access of your personal data; and require Us to delete your personal data. If you intend to exercise relevant rights, please click here to give us feedback online. In order to ensure security, you may have to submit a written request. If we have reasonable grounds to believe that these requests are deceptive, unenforceable, or compromise the privacy of others, we will refuse to proceed.

To the extent of applicable legal requirements, when Huayou Cobalt processes your personal data with your consent, you also have the right to revoke the consent at any time. However, your revocation of the consent will not affect the legality and effectiveness of Our processing of your personal data based on the consent you gave before the revocation, nor will it affect our processing of your personal data based on other appropriate and legitimate grounds.

If you believe that Our processing of your personal information does not comply with applicable data protection laws, you may contact the statutory data protection institution. For the contact details of data protection institutions in the region of the European Union, please visit: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

5. How does Huayou Cobalt protect and retain your personal data

Huayou Cobalt emphasizes on the security of personal data. We adopt appropriate physical, managerial and technical assurance measures to protect that your personal data will not be accessed, disclosed, used, modified, damaged or lost without authorization. For instance, We use encryption technologies to ensure data confidentiality; We use protection mechanisms to prevent malicious assaults on data; We deploy access control mechanisms to ensure that only authorized personnel can access personal data; and We organize training courses for security and privacy protection, and strengthen Our employees' awareness of the significance of protecting personal data. We endeavor to protect your personal data, however, please note that, 100% security can't be guaranteed as long as any data is transmitted through the Internet. Although we adopt appropriate measures to protect your personal information, Huayou Cobalt can't assure or guarantee the security of any information that you provide to Us or obtain from Our websites, and thus you shall be solely liable for any risks when visiting Our websites. For details about how to report security issues, matters or potential incidents to Huayou Cobalt and Huayou Cobalt Information Security Group, please feel free to contact us via zs@2sfcw.com. Upon occurrence of any personal information security incident, We will timely inform you and report to the supervising authority according to the requirements of relevant laws and regulations.

We will retain your personal data for the period necessary to achieve the purposes stated in This Policy, unless an extension of the retention period is required or permitted by legal requirements or legal permits. Due to different scenarios and varied products and services, the data retention period may also be varied, and the criteria We use to determine the retention period include: The period required to retain personal data before the business purpose is achieved, where the business purpose includes, without limitation to, provision of products and services, maintenance of corresponding transaction and business records, control and improvement of performance and quality of products and services, security assurance of systems, products and services, coping with potential user inquiries or complaints, problem locating, etc. whether the user agrees with the extended retention period; whether special requirements for data retention are stipulated in laws and contracts. We will retain your registration information if and when your account is indispensable for Our service to you. You may deregister your account, and We will no longer provide products and services for the account you deregistered, and, unless otherwise required by law, will delete your personal data.

6. How does Huayou Cobalt process the personal data of children

Our products, websites and services are mainly developed for adults. Children are disallowed to create user accounts without the consent of their parents or guardians. In case that we collect personal data of children with approval of parents or legal guardians, we will use or disclosure the data only in the condition permitted by the law, definitely approved by parents or guardians, or necessary condition of protecting children. If Huayou Cobalt identifies any personal data collected by Us from children without getting the provable approval of their parents in advance, We will manage to delete any related data as soon as practically possible.

7. Third-party providers and their services

To ensure smooth browsing service experience, you may receive contents or network links provided by third parties other than Huayou Cobalt and its partners (hereinafter referred to as "Third Parties"). Huayou Cobalt has not any control of such Third Parties. However, you can decide whether to access the links, contents, products and services made available by Third Parties.

Huayou Cobalt cannot control the privacy practices and data protection policies of Third Parties that are not subject to this Policy. When you submit any of your personal information to such Third Parties, please refer to the privacy protection policies of the Third Parties.

8. How is your personal data transferred worldwide

Huayou Cobalt is global company, and, to the extent permitted by law, We may share your personal information internally (including, with Our subsidiaries, affiliates and parent company) or with Our suppliers and business partners, and may transfer your personal information to other countries or regions in which We operate. In addition, since We may not have any data storage center in your country, your personal data may also be transferred to and stored in data centers in the regions other than your country. In such cases, Huayou Cobalt will take measures to ensure that the data collected from you is and will be processed in accordance with the requirements of this Policy and applicable laws. For example, when the personal data of any data subject in the European Union is transferred to a country or region with the equivalent level of data protection which is not recognized by the European Union, Huayou Cobalt will utilize a variety of legal mechanisms to ensure data security, e.g., conclusion of the standard contract terms approved by the European Commission, or requesting for your consent to cross-border transfer of personal data, or implementation of security measures including data anonymity before cross-border data transfer.

9. How is this Policy is updated

Huayou Cobalt reserves the right of updating or amending this Policy from time to time. If Our Privacy Policy changes, We will publish the latest Privacy Policy here. If We make any material changes to the Privacy Policy, We may also send a change notice to you through varied channels, e.g., informing you by publishing notices on Our website or sending emails (to the email address stated in your account). As required by applicable data protection laws, We will seek your consent to any material changes to the Privacy Policy which may affect how We use your personal information. We suggest that you regularly check and view this page to understand Our most recent privacy practices.

10. How to contact Huayou Cobalt

Should you have any doubts, opinions or suggestions, please feel free to contact Us. We will respond within 30 days. If you are not satisfied with the response, you can also complain by sending messages to the following email address: zs@2sfcw.com.

When Huayou Cobalt processes your personal data according to this Privacy Policy, the entities of Huayou Cobalt which respond to your request, contact you, provide you with products or services or enter into or will enter into contracts with you are the controllers of relevant personal data. Please click here to view the contact information of the various entities of Huayou Cobalt.