DataCyber Privacy Policy

Effective Date: [3] [April], [2025]

Welcome to our products and services! Your trust is very important to us. We fully understand the importance of user information security and will, in accordance with legal and regulatory requirements, take security protection measures to keep your user information secure and controllable. In view of this, ZhejiangDataCyber Intelligence Co., Ltd. (hereinafter referred to as 'We' or 'DataCyber') has formulated the 'DataCyber Privacy Policy' and reminds you:

Before using any of DataCyber's products or services, you must carefully read and thoroughly understand this Policy. Use our related products or services only after you confirm your full understanding and agreement. Once you start using our products or services or actively provide us with personal information, it means that you have fully understood and agreed to this Policy, fully understand our products or services, and the necessary personal information or sensitive personal information required for the operation of the aforementioned product or service functions, and correspondingly authorize us to collect and use it in accordance with the law.

This Policy will help you understand the following:
1. Scope of Application of This Policy
2. How We Collect and Use Your Personal Information
3. How We Use Cookies and Similar Technologies
4. How We Disclose Your Personal Information
5. How We Store and Protect Your Personal Information
6. Your Rights
7. How We Handle Minors' Personal Information
8. How Your Personal Information is Transferred Globally
9. How This Policy is Updated
10. How to Contact Us

1. Scope of Application of This Policy

1. This Policy applies to all services on the DataCyber official website, including providing you with page browsing, website login services, and the products, services, or solutions provided to you through the DataCyber official website.
2、This Policy does not apply to services provided by other third parties to you. Matters concerning the processing and protection of your information shall be governed by such third party's privacy policy or similar document. We assume no legal liability for any improper use or disclosure of information provided by you by any third party.
3、As a user of DataCyber, if you use DataCyber's technical services to provide services to your own users, since your business data belongs to you, you should separately agree on a privacy policy with your users.
4. The following terms mentioned in this Policy have the following meanings:
Personal Information: Refers to various information recorded electronically or by other means related to an identified or identifiable natural person, excluding information after anonymization.
Sensitive Personal Information: Refers to personal information that, once leaked or illegally used, may easily lead to the infringement of the personal dignity of a natural person or harm to personal or property safety, including information such as biometrics, religious beliefs, specific identity, medical health, financial accounts, whereabouts and tracks, as well as personal information of minors under the age of fourteen.
De-identification: Refers to the process of technically processing personal information so that it cannot be used to identify you without the use of additional information.
Anonymization: Refers to the process of technically processing personal information so that the subject cannot be identified and the processed information cannot be restored.

2. How We Collect and Use Your Personal Information

In accordance with the requirements of laws and regulations, we adhere to the principles of legality, legitimacy, necessity, and good faith, and only collect personal information necessary or relevant for realizing product functions. You or your end users, in the process of using the products or services we provide, we will collect user personal information actively provided by you when using the official website and related services in the following scenarios and business activities:

(1) Registering/Logging into Official Website Account

To register as a DataCyber official website user, you can apply for an account registration on the official website. During the registration process, you need to provide the following information: Name, Company Name, Mobile Number. After submitting the application, our staff will contact you to assist in creating your official website account and activating relevant product trial services, and will inform you of your username and initial password.

(2) Submitting Inquiries and Service Requests

You can submit requests for information inquiries, product trials, technical support, or cooperation on the DataCyber official website. When submitting, you need to provide the following information: Name, Company Name, Mobile Number. Our staff will contact you as soon as possible after receiving your request to further understand your needs and provide corresponding support.

(3) Information Collection During Use of Products/Services

When you use DataCyber's official website, products, or services, in order to provide you with services that better suit your needs, interactive displays, identify abnormal account status, maintain normal operation of the services, improve and optimize the service experience, and protect your account security, we need to collect information about your use of the services and how you use them, and associate this information:

（1）Usage Information: We will collect information you submit or generate when using the services as a user.

（2）Device Information: We will, based on the specific permissions you grant during software installation and use, receive and record information about the device you use (e.g., operating system version).

（3）Log Information: When you use the services provided by our website, we automatically collect detailed information about your use of our services, which is saved as network logs. For example, your search query content, IP address, browser type, telecom operator, language used, date and time of access, and the web pages you visited, etc.

（4）User Business Data:：

1. The data that you process, store, upload, download, distribute, or otherwise handle through the services provided by DataCyber is your User Business Data, and you fully own your User Business Data. As a service provider, we will only strictly execute your instructions to process your business data. Except as agreed with you or to comply with clear legal and regulatory requirements, we will not make any unauthorized use or disclosure of your business data.
2. You are responsible for the source and content of your User Business Data. We remind you to carefully judge the legality of the data source and content. You shall bear all consequences and responsibilities arising from your User Business Data content violating laws, regulations, departmental rules, or national policies.
3. If you are an enterprise/organization user, before uploading the enterprise's/organization's personal information, you should obtain the explicit consent of the individual users in advance, and only collect the personal user information necessary for achieving the enterprise's/organization's operation and management purposes, and ensure that the individual users have been fully informed of the purpose, scope, and method of such data collection, etc. You understand and agree that you are the controller of the data controlled by the aforementioned enterprise, and we only process personal information according to the instructions of the enterprise/organization user administrator. The results of the processing shall be borne by the data controller. At the same time, we have the right to refuse unreasonable requests you make based on personal information protection and compliance requirements.

(4) Information You Provide to Us

During the use of the services, you can provide feedback on your experience with products, functions, applications, and services, helping us better understand your experience and needs when using the products or services, and improve the products or services. For this purpose, we will record your contact information, the problems or suggestions you feedback, in order to further contact you and provide our feedback on the handling.

(5) Information Provided to Us by Third Parties

We may collect information about you when other users perform operations related to you, and may also obtain your personal data information from affiliated companies, cooperative third parties, or through other legal channels.

(6) Exceptions Where Collection and Use of Personal Information Does Not Require Your Authorization and Consent

You are fully aware that, according to applicable law, in the following circumstances, we may collect and use your personal information without obtaining your authorization and consent:
1. Where it is related to national security and national interests, or social public interests;
2. Where it is necessary for the performance of our statutory duties or legal obligations, or necessary to respond to instructions from government authorities;
3. Where it is necessary for the conclusion and performance of a contract to which you are a party, or other written documents;
4. Where it is necessary to respond to public health emergencies, or necessary to protect the life, health, and property safety of you and others in emergency situations;
5. Where the processing is within a reasonable scope of your personal information that you have disclosed to the public on your own;
6. Where the processing is within a reasonable scope of your personal information collected from legally publicly disclosed information (such as through legitimate news reports, government information disclosure, etc.);
7. Other circumstances stipulated by laws and regulations.

(7) Situations Where Other Entities Collect Your Information

Third-party entities may provide services to you through our official website or other channels. When you enter a service page operated by a third-party entity, please note that the relevant service is provided to you by the third-party entity. If it involves the collection of your information by a third-party entity, it is recommended that you carefully review the privacy policy or user service agreement of that third party.

Please understand that the functions and services we provide to you are constantly updated and developed. If a certain function or service is not included in the above description and collects your information, we will separately explain the content, scope, and purpose of the information collection to you through page prompts, interactive processes, website announcements, or separate agreements, etc., to obtain your consent.

3. How We Use Cookies and Similar Technologies

When you use our official website, products, or services, we may use Cookies and similar technologies to collect some of your access information, including: your browsing history, login information, authorization information, etc. The collection of such information by Cookies and similar technologies helps us provide you with a more personalized and secure service experience, such as simplifying repetitive operation steps, protecting your information and account security, remembering your preference settings, etc.

You can refuse or manage Cookies through your browser settings. However, please note that if you disable Cookies, you may not be able to enjoy the best service experience, and the availability of some functions may be affected.

We promise not to use the personal information collected through Cookies or similar technologies for any other purposes beyond those described in this Privacy Policy.

4. How We Disclose Your Personal Information

(1) Sharing

Without your prior explicit authorization or consent, we will not share your personal information with any third party. If in the future, part of the business functions of DataCyber's products and services need to be provided by third-party suppliers, or if DataCyber needs to achieve specific services through its affiliates, or if DataCyber needs third parties to help us achieve the above purposes, provide products or services to you or your company, or handle your requests. In such cases, we may entrust DataCyber's affiliates, service providers, and business partners to process your personal information. We will sign strict confidentiality agreements with these third parties, requiring them to process personal information in accordance with our requirements, this Privacy Policy, and any other relevant confidentiality and security measures.

(2) Transfer

In the event of our merger, division, dissolution, acquisition, asset transfer, asset reorganization, or bankruptcy liquidation, etc., if it is necessary to transfer your personal information to a third party, we will require the third party to continue to be bound by this Statement in accordance with laws, regulations, and regulatory requirements.

(3) Public Disclosure

We will not publicly disclose your personal information. If public disclosure is necessary, we will inform you of the purpose of this public disclosure, the type of information to be disclosed, and any sensitive information that may be involved, and obtain your separate consent, unless otherwise stipulated by laws and regulations or otherwise agreed between us and you.

(4) Exceptions Where Prior Authorization and Consent are Not Required for Sharing, Transferring, or Publicly Disclosing Personal Information

In the following circumstances, sharing, transferring, or publicly disclosing your personal information does not require prior authorization and consent from you:
1. Where it is directly related to national security or national defense security;
2. Where it is directly related to public security, public health, or significant public interests;
3. Where it is directly related to criminal investigation, prosecution, trial, and execution of judgments, etc.;
4. Where it is necessary to protect the major legitimate rights and interests such as the life and property of you or other individuals, but it is difficult to obtain the consent of the individual;
5. Where the information collected is personal information that you have disclosed to the public on your own;
6. Where personal information is collected from legally publicly disclosed information, such as through legitimate news reports, government information disclosure, etc.;
7. Where it is necessary for the conclusion and performance of a contract according to your requirements;
8. Where it is necessary for maintaining the safe and stable operation of the provided services, such as discovering and handling service failures;
9. Other circumstances stipulated by laws and regulations.

5. How We Store and Protect Your Personal Information

(1) How We Store Your Personal Information

(1) We will store your information in a secure manner that meets the requirements of national laws, regulations, and regulatory authorities.

（2）We will retain the personal information of you or your end users for the period necessary to provide the services, unless the retention period is extended with your authorization and consent or as otherwise required by laws and regulations. After the expiration of the above user information retention period, we will delete or anonymize the personal information of you or your end users in accordance with legal provisions.If we or our affiliated companies are involved in division, dissolution, bankruptcy liquidation, deregistration, or revocation, etc., we will delete or anonymize the personal information of you or your end users.

（3）In accordance with laws and regulations, we will store the personal information collected within China within the territory of China.With business development, we may in the future, transfer part of the collected personal information overseas as permitted by laws and regulations, in order to provide you and your end users with better global services. Before transferring the personal information we collect overseas, we will separately obtain the consent of you and your end users again, and complete necessary procedures such as security assessments and personal information protection certification in accordance with the law. You or your end users may refuse our transfer of your or your end users' personal information overseas, but this may result in our inability to provide you with some services.

(2) How We Protect Your Personal Information

DataCyber values the security of personal information. We have used security protection measures that comply with industry standards to protect the personal information you provide, preventing data from unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonably feasible measures to protect your personal information. For example, using encryption technology to ensure data confidentiality; using protection mechanisms to prevent data from malicious tampering or attacks; deploying access control mechanisms to ensure that only authorized personnel can access personal data; and conducting data security and privacy protection training to enhance employees' awareness of the importance of protecting personal data, etc.
However, please note that the internet environment is not 100% secure. Therefore, although we will take various measures to protect your personal information, we cannot determine or guarantee the absolute security of the information you provide to us or obtain from our website. In the unfortunate event of a personal information security incident, we will, in accordance with legal and regulatory requirements, promptly inform you of the relevant situation of the incident via email, letter, phone, push notification, announcement, etc., including: the basic situation of the security incident and its possible impact, the measures we have taken or will take to address it, suggestions for you to independently prevent and reduce risks, and remedial measures for you, etc.
At the same time, we will also proactively report the handling of personal information security incidents to regulatory authorities as required.

6. Your Rights

In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we guarantee that you can exercise the following rights regarding your personal information:

(1) Access, Copy, Change (Modify) Your Personal Information

You have the right to access, copy, change (modify) your personal information at any time, except as otherwise provided by laws and regulations. If you wish to exercise the above rights, you can do so through the following channels:
1. Log in to the DataCyber official website, enter the corresponding product, you can view, copy, change (modify) personal information through the ["Account" - "User Information"] page, and modify your password through the ["Account" - "Change Password"] page;
2. If you have other needs regarding access, copying, or changing (modifying) your personal information, you can contact customer service through the contact information provided in Part 10 "How to Contact Us", and we will assist you in completing the relevant operations.

(2) Delete Your Personal Information

In the following circumstances, you can request us to delete user personal information:
1. Where we process your personal information in violation of laws, administrative regulations, or our agreement with you;
2. Where the purpose of our processing of your personal information has been achieved, cannot be achieved, or is no longer necessary for achieving the processing purpose;
3. Where we collect and use your personal information without obtaining your consent or you have withdrawn your consent;
4. Where we stop providing the services, or the retention period has expired;
5. Other circumstances where personal information should be deleted as stipulated by laws and administrative regulations.

(3) Change the Scope of Your Authorization and Consent

Each business function requires some basic personal information to be completed. For the collection and use of additional personal information, you can choose to withdraw your authorization or change the scope of your authorization. We will explain this on the specific function page. After you withdraw your consent or authorization, we will no longer process the corresponding personal information. However, your decision to withdraw consent or authorization will not affect the personal information processing previously conducted based on your authorization.

(4) Deactivate Your Account

If you need to deactivate your account, you can contact customer service through the contact information provided in Part 10 "How to Contact Us", and we will assist you in deactivating the account. After you actively deactivate your account, we will stop providing you with the corresponding products and services, and delete your personal information or anonymize it as required by applicable law.

(5) Responding to Your Above Requests

Please note that when you exercise the above rights:

● For security reasons, you may need to provide a written request or otherwise prove your identity; we may require you to verify your identity before processing your request; generally, we will respond within fifteen days of receiving the request.

● For your reasonable requests, we generally do not charge a fee, but for repeated requests that are multiple or exceed reasonable limits, we may charge a certain cost fee depending on the circumstances. We may refuse requests that are repetitive without reason, require excessive technical means (e.g., require developing new systems or fundamentally changing current practices), for which we have reasonable grounds to believe are deceptive or unenforceable, and that may pose a risk to the legitimate rights and interests of others or are very impractical (e.g., involve information stored on backup tapes).

● In the following circumstances, in accordance with applicable laws and regulations, we will be unable to respond to your request:

1. Where it is directly related to national security or national defense security;
2. Where it is directly related to public security, public health, or significant public interests;
3. Where it is directly related to criminal investigation, prosecution, trial, and execution of judgments, etc.;
4. Where there is sufficient evidence showing that you have subjective malice or are abusing your rights;
5. Where responding to your request will seriously damage the legitimate rights and interests of you or other individuals or organizations;
6. Where it involves trade secrets.

7. How We Handle Minors' Personal Information

Our website, products, and services are intended for adults. However, we attach great importance to the protection of minors' personal information. If you are a minor, we require that you ask your parents or other guardians to carefully read all the contents of this Policy, and use our products or services and provide us with information under the premise of obtaining the consent and accompaniment of your parents or other guardians.
Children under the age of 14 should not create any account or use the official website and its services. Under the current model, we cannot proactively identify minors' personal information during account registration. If you are the guardian of a minor and find that we have obtained the minor's personal information without your authorization, you can notify us as soon as possible. After receiving the notification, we will promptly verify it and delete or anonymize the relevant information after verification. If we discover the aforementioned situation through other channels, we will also proactively delete or anonymize the relevant minor's personal information.

8. How Your Personal Information is Transferred Globally

In principle, the personal information collected and generated during our operations within China is stored within China, except for the following circumstances:
1. Where laws and regulations explicitly stipulate otherwise;
2. Where we have obtained your explicit authorization and have completed necessary procedures such as security assessments and personal information protection certification in accordance with the law.
For the above circumstances, we will rely on this Policy to ensure that your personal information receives adequate protection.

9. How This Policy is Updated

We may revise this Privacy Policy from time to time and will post all changes and their effective dates on this page. Without your explicit consent, we will not reduce the rights you enjoy under this Privacy Policy. If the law requires re-obtaining your consent, we will seek your consent again.
Please read the updated Privacy Policy carefully. If you continue to use the DataCyber official website and related services after the policy update, it means that you agree to accept the revised Privacy Policy. If you do not agree with the changed Privacy Policy or have objections to it, you can choose to stop using or deactivate your account. Please note that your actions and activities before stopping the use of the service or deactivating the account are still bound by the current Privacy Policy.

10. How to Contact Us

If you have any questions, comments, or suggestions regarding this Privacy Policy, please contact us through the following methods:
(1) Corporate Email: marketing@datacyber.com
(2) Customer Service Phone: 0571-85153720 (Monday to Friday 9:00-18:00)
Generally, we will reply within fifteen days. Under special circumstances, the maximum response time will not exceed thirty days or the period stipulated by laws and regulations.