This is the Privacy Notice (the “Privacy Notice”) of Beijing Jinnuo Hengtong Technology Co., Ltd (Jinnuo). This Privacy Notice is for public disclosure and to inform customers, website visitors and other third-parties how Jinnuo may use data obtained from them.

1. Important Notice

Jinnuo is is a professional company engaged in Uninterruptible Power Supply (UPS), Power Distribution Unit (PDU), Security and Environmental Monitoring, KVM Switches, Cooling, Cabinets, Batteries, Computer Server, ATS, Cables, Computer Exchange, related service and so on. It was established in 2001 and is located in Beijing, enjoying convenient transportation and beautiful environment. Our company covers an area of 1,100 square meters and has over 80 employees. Jinnuo respects your privacy. This Privacy Notice sets out how Jinnuo collects and processes your personal data when you access and use our Services, including the site www.jinnuoglobal.com (“Site”). This Privacy Notice also provides certain information that is legally required and lists certain of your rights in relation to your personal data under applicable law. We may amend this Privacy Notice from time to time. We encourage you to check our Privacy Notice regularly to understand how we may process your Personal Data.

2. Information About Personal Data Processing
   • Personal Data

This Privacy Notice relates to data about you and your interaction with our Services. “Personal Data” is information that can be used to identify you, directly or indirectly, alone, or together with other information. Jinnuo collects Personal Data including, but not limited to, the following information: full name, email address, phone number, precise location, device IDs, and certain cookie and network identifiers, etc. Jinnuo collects, uses, and discloses Personal Data as outlined in this Privacy Policy, including to operate the company; to perform and improve the Services and our business; for advertising and marketing; and to provide you products and the Services. 2.2 How and When We Collect Personal Data When you register for an account or interact with or utilize our Products or Services. We collect Personal Data when you use or interact with our Site and Services, including when you register with us, browse our products online, or make purchases from us. We will store the Personal Data that we collect from you in the course of these interactions, including, but not limited to, name, address, phone number, username and password, email address, etc. When you communicate with us or sign up for promotional materials. We collect Personal Data when you communicate with us or sign up to receive promotional materials or information, including email address and phone number. When we collect data from third parties or publicly-available sources. We may obtain certain data about you from third-party sources to help us provide and improve the Services and for marketing and advertising. We may combine your Personal Data with data we obtain from our Services, other users, or third parties to enhance your experience and improve the Services. When we leverage and/or collect cookies, device IDs, Location, data from the environment, and other tracking technologies. We may collect certain Personal Data using cookies and other technologies, such as web beacons, device IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising. Our Cookie Policy section contains more information and options to control or opt-out of certain data collection or uses. Users Under Age of Majority We do not knowingly collect Personal Data online from individuals under the age of majority without parental consent. If you become aware that an individual under the age of majority has provided us with Personal Data without parental consent, please contact us. If we become aware that an individual under the age of majority has provided us with Personal Data without parental consent, we will take steps to remove the data as permitted by law. 2.3 How We Disclose Personal Data We may disclose your Personal Data as described in this Privacy Notice, including: To Affiliates and Collaborators. With companies or ventures that are owned or controlled by Jinnuo, and internally within Jinnuo, in order to provide and improve Services, for marketing purposes, for advertising, and for analytics. To Service Providers and Vendors. With business collaborators, marketing collaborators, and vendors to provide, improve, and personalize the Services. We may also disclose Personal Data to your medical or healthcare provider, at their direction, in order to provide the Services. For Advertising and Marketing. With advertising and marketing collaborators for advertising and marketing purposes on Jinnuo’s behalf. For Certain Analytics and Improvement. With certain companies for purposes of analytics and improvement of the Services. For Interest-Based Advertising. With companies involved in interest-based advertising. This advertising consists of Jinnuo advertisements that are personalized for you and displayed on our sites and through other channels. For Legal Compliance, Law Enforcement, and Public Safety Purposes. As permitted by law, with law enforcement, government or regulatory bodies, lawful authorities, or other authorized third parties in order to comply with laws, regulators, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Notice, or agreements with third parties, or for crime-prevention purposes. Actual or Contemplated Sale, Acquisition, or Reorganization. In connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, acquisition or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.

3. Data Protection Officer

If you have questions or concerns regarding our Personal Data processing practices or this Privacy Notice, you can contact our Data Protection Officer at christy@apc.com.cn

4. Legal Basis For Processing

We collect and process your personal data for a variety of different purposes set out in further detail below. In some cases, we will ask for your consent so that we may process your Personal Data. However, in certain circumstances, applicable data protection laws allow us to process your Personal Data without needing to obtain your consent. 4.1 Processing personal data where consent not obtained In certain cases, separate consent is not required, including: For the performance of a contract. To perform our contractual obligations to you, including our fulfilling orders or purchases you have made, contacting you in relation to any issues with your order, in relation to the provision of the services, or where we need to provide your Personal Data to our service providers. To comply with legal obligations. To comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process. Legitimate Interests. To operate our business and provide the services, other than in performing our contractual obligations to you for Jinnuo’s “legitimate interests” for the purposes of applicable law, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Legitimate interests may include: To communicate with you regarding the Services, including to provide you important notices regarding changes to our Terms and Conditions of use of the website and to address and respond to your requests, inquiries, and complaints. To send you surveys in connection with our Services. To assist in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights and property, or the rights or safety of third parties. To develop, provide, and improve our Services. To enforce our Terms of Use or this Privacy Notice, or agreements with third parties. 4.2 Matters that may require consent In cases where we are not already authorized to process the Personal Data under applicable law, we may ask for your consent to process your Personal Data, including: Marketing We may ask for your consent to contact you by telephone, SMS, post and/ or email about other offers, products, promotions, developments or services which we think may be of interest to you and for other marketing purposes. Sensitive Personal Data Certain of our Services may involve the processing of Sensitive Personal Data. If we collect Sensitive Personal Data directly from you, we will obtain your consent where required. Research We may ask for your consent to use your Personal Data for research purposes, including for clinical studies. Cookies We may also request consent for some cookies in accordance with our Cookie Policy. 4.3 Withdrawing Your Consent You may at any time withdraw the consent you provide for the processing of your Personal Data for the purposes set forth in this Jinnuo Privacy Notice, provided that we are not required by applicable law or professional standards to retain such information. For individuals who wish to withdraw consent, please contact us. If you want to stop receiving future marketing messages and materials, you can do so by clicking the “unsubscribe” link included in our email marketing messages or by contacting us.

5. De-identified or anonymized data

We may create de-identified or anonymous data from Personal Data by excluding data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means. Our use of anonymized data is not restricted by this Privacy Notice.

6. Data retention

We will retain your Personal Data for as long as you maintain an account, as otherwise necessary to provide you the Services, or as required by applicable law, regulation or industry standard. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where we no longer need to process your Personal Data for the purposes set out in this Privacy Notice, we will delete your Personal Data from our systems. Where permissible, we will also delete your Personal Data upon your request, as further described in the Data Subject Access, Modification, and Deletion Rights section of this Privacy Notice.

7. Advertising and analytics

Interest-based advertising is advertising that is targeted to you based on your web browsing and app usage over time. We disclose various types of de-identified information to enable interest-based advertising. You have the option to restrict the use of information for interest-based advertising and to opt-out of receiving interest-based ads.

8. Social network widgets

Our Site may include social network sharing widgets that may provide information to their associated social networks or third-parties about your interactions with our web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where widget appears. If you use social network tools or visit social networking sites, you should read their privacy disclosures, to learn what information they collect, use, and share.

9. Why we collect and process your personal data

In most cases, we need to process certain of your Personal Data in order to fulfil our contractual obligations to you and to provide you with the Services. Where we ask for your consent to process your Personal Data, you have the right to withdraw such consent as described in this Privacy Notice. Please note, however, that if you do not provide consent or if you withdraw your consent, we may be unable to provide you certain Services that require the use of Personal Data. Please note that even where your consent would otherwise be required, we may nevertheless process your Personal Data in accordance with our legitimate interests under applicable law, as described in this Privacy Notice.

10. Transfer and storage of personal data

Jinnuo and associated Services and systems may be stored on servers in the United States. If you are located outside of the United States, please be aware that Personal Data we collect will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside or are a citizen.

11. Data subject access, modification, and deletion rights

You have the right in certain circumstances to request confirmation from us as to whether or not we are processing your Personal Data. Where we are processing your Personal Data, you also have the right to request access to, modification of, or deletion of such Personal Data. You have the right in certain circumstances to receive the personal data concerning you, which you provided to us and have the right in certain circumstances to transmit such data to another controller. To exercise your rights with respect to your Personal Data, please contact us. As permitted by law, we may charge for this service and will respond to reasonable requests as soon as practicable and as required by law.

12. Right to lodge a complaint with a supervisory authority

You may have a right to lodge a complaint with a supervisory authority.

13. Security safeguards and links to other websites

We implement appropriate technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against the accidental loss, destruction, or damage of Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data. This Privacy Notice only applies to Jinnuo. Our Site or Services may provide a link or otherwise provide access to another website, mobile application, or Internet location (collectively “Third-Party Sites”). We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites, and any data you provide to Third-Party Sites, you provide at your own risk. We encourage you to review the privacy policies of any Third-Party Sites with which you choose to interact.

14. Contact us

For questions regarding your personal data, please email christy@apc.com.cn.