Beijing Hoyinn Technologies CO.,LTD.(collectively "Hoyinn")understands the importance of personal information to you, and we are committed to protecting the personal information you provide to us in strict compliance with China's personal information protection laws and regulations. We hope that this privacy policy (hereinafter referred to as "this policy") will provide you with a clear picture of how we handle your personal information, so please read this policy carefully before submitting your personal information to us and make sure you fully understand and agree to them before you start using our before you start using the services we provide. 

This policy describes how we process your personal information, but it may not address all possible data processing scenarios. Information about the collection of product- or service-specific data may be set out in a specific privacy notice we publish for a particular product or service, or in a notice provided at the time of data collection.

We have created this policy to help you understand the following.

I. how we collect and use your personal information

II. How we use cookies or similar technologies

III. How we protect your personal information

IV. How we store your personal information

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

VI. Third Party Links and Related Policies

VII. Updates to this policy

VIII. How to contact us

I. How we collect and use your personal information

1、How we collect your personal information

"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. We collect your personal information strictly in accordance with the principles of legality, legitimacy, necessity and transparency and for the purposes described in this policy. You are not required to provide us with personal information, but in some cases, if you choose not to do so, we may not be able to provide you with relevant products or services, or respond to or resolve problems you encounter. If we use your personal information for other purposes not set out in this policy, or collect your personal information for other specific purposes, we will inform you in a reasonable manner and again obtain your consent. The personal information we may collect includes.

1.1 Visiting our official website or social media accounts

When you visit our website or interact with us through social media, we may obtain your name, web identifiable information (account name, account nickname, password and password protection questions and answers related to your personal account), email address, friends list, photo, age, gender, location from that social media platform. In order to optimize our Site and to provide you with personalized service in a timely manner, we may automatically collect log information about you, including browsing, click-throughs, search queries, and IP address, date and time of access.

1.2 Access to our offices or data centers (including data centers under construction)

When you access our offices or data centers (including data centers under construction), to protect you and other users, services and property, we may collect your name, telephone number, ID number, passport number or other identification number, mailing address, email address, fax number, personal photograph, company name, job title, and your biometric information and personal images, such as access to Facial recognition, fingerprint scanning, personal images or other biometric eva1uation techniques that may be used by Hoyinn .

1.3 Information provided to us by third parties

We may obtain personal information about you from third parties to whom you have authorized your consent. For example, if you use our products or services through a third party (such as our service providers, partners or social media platforms), that third party may provide us with personal information about you.

We will use and process your personal information in accordance with our agreement with the third party, after confirming the legitimacy of the source of the personal information, and subject to applicable laws and regulations.

In addition, if you share personal information with us that is not your own personal information, you are required to ensure that the information you share is collected for a lawful purpose and in a lawful manner. If you share personal information with us that is not your own, you are required to notify the individual for whom you are acting, an employee or any person subject to authorization (such as a contractor, partner or authorized third party) and obtain consent to

- the personal information you collect and submit will be processed by Hoyinn.

- Hoyinn will process such personal information in accordance with this Policy and laws and regulations.

1.4 Your personal information collected and processed for reasonable and other necessary purposes

We may collect and process your personal information without obtaining your authorized consent in the following circumstances.

- Necessary for the purpose of entering into, or performing, a contract with you.

- Necessary to perform a legal duty or legal obligation.

- Necessary to respond to a public health emergency, or in an emergency to protect your life, health or property or the safety of others.

- Necessary to carry out news reporting, public opinion monitoring and other actions in the public interest, and to handle personal information within a reasonable range.

- Handling personal information that you have disclosed or have legally disclosed within a reasonable range.

- Other circumstances as stipulated by laws and administrative regulations.

Please understand that some of the information in the above service features cannot identify you when they exist independently and are not part of your personal information. If we use such non-personal information in combination with other information that can identify you, we will treat such information as personal information and protect it during the period of combined use, unless we obtain your authorization or unless otherwise provided by laws and regulations.

Please understand that the services we provide to you are constantly being updated and developed. If a service is not described above and requires the collection of your information, we will explain to you the content, scope, processing purposes and processing methods of personal information collection through page prompts, push notifications or separate agreements, etc., in order to obtain your authorized consent.

2、 How we use your personal information

We may use your personal information for the following purposes.

To respond to your requests for interaction. When you visit our website, participate in online or offline activities, request changes or request information you have requested (such as marketing materials for products or services), and contact us about any issues or product information (such as providing us with comments, suggestions, inquiries, etc.), we collect the following information from you: the name, email address, phone number, address, company name, position, etc. that you provide.

II. How we use cookies or similar technologies 

Cookies are small data folders that are written to your hard drive when you visit our website. A cookie cannot read data outside of your hard drive or read cookie files created by other websites. Website cookies stored on your computer will remain in effect indefinitely after your first visit to the site. We do this to determine the usefulness of our information to users and to see how effective our navigation structure is in helping users access information. We will not associate this information with your personal information, share it or sell it to any third party.

You may modify your browser settings to refuse our cookies if you wish; alternatively, you may clear all cookies stored within the software, but please note that if you choose to delete or block cookies, you will be required to re-enter your original user ID and password when you access certain parts of the site. Tracking technologies can record information such as web domain and host name, Internet Portal (IP) address, browser software and operating system type, number of hits, and the date and number of visits to our site. The use of cookies and other tracking technologies allows us to improve our website and your online experience, and we may analyze your personal information that does not contain trends and statistics.

III. How we protect your personal information

We have taken reasonable and practicable security measures in accordance with industry standards to protect your information from unauthorized access, public disclosure, use, modification, damage or loss.

1. Security Measures

To ensure that your personal information is properly safeguarded, Hoyinn is committed to using appropriate hardware, technical and organizational measures to protect the personal information we collect in accordance with applicable laws and regulations. We attach great importance to personal information security compliance and maintain a sound information security management system. We reasonably determine the operating authority of personal information handling in accordance with the law, and regularly provide safety education and training to our employees to enhance their awareness of the importance of protecting personal information.

2. Security incident handling

In order to deal with the possible risks of personal information leakage, tampering, loss, etc., Hopewell Data will implement classification management of personal information and provide internal management system and operating procedures for the disposal of personal information security incidents. In response to security incidents, we will take appropriate encryption, de-identification and other security technology measures. In addition, in order to properly handle personal information security incidents, we will arrange dedicated personnel to respond to and handle security incidents, adopt effective security plans for different security incidents, formulate and take timely stop-loss and remedial measures, and actively cooperate with relevant government departments.

In case of personal information leakage and other security incidents, we will activate the emergency plan according to the law and inform you in a timely manner by email, letter, telephone, push notification, etc. of the basic situation of the security incident, the possible impact, the measures we have taken or will take in response, the preventive and remedial measures you can consider taking and our contact information. If it is not possible to inform individuals in a timely manner to protect the life, health and property of natural persons in an emergency, we will do so in a timely manner after the emergency is eliminated. At the same time, we will also take the initiative to report the disposition of personal information security incidents in accordance with the requirements of relevant government departments.

The Internet is not an absolutely secure environment, and email, instant messaging, social software and other forms of communication with other users cannot be determined whether they are fully encrypted, we recommend that you use such tools please use complex passwords and pay attention to protect the security of your personal information.

IV. How we store your personal information

We will only store and protect your personal information for as long as necessary to achieve the purposes described in this policy, unless compelled by law.

1. Storage Location

All personal information collected and generated in the People's Republic of China will be stored in China, and we will not transfer your personal information outside of China.

If we do need to transfer your personal information out of China, we will obtain your individual consent in advance. In such cases, we will require the recipient to handle your personal information in accordance with our agreement, this Policy and any other relevant confidentiality and security measures, and to ensure that your personal information will be protected at least as adequately as it would be in the People's Republic of China.

2. Storage Period

We will only retain your personal information for the minimum period necessary to fulfill the purposes of this Policy, except where longer retention periods are required or permitted by applicable laws and regulations. After your personal information has been retained beyond the retention period, or after you have requested deletion of your personal information, we will delete or anonymize your personal information as required by applicable laws and regulations.

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

1. Sharing

We will not share your personal information with any company, organization or individual without your individual consent. If we do need to share your personal information with our affiliates, service providers and/or other third parties to provide services to you, we will strictly follow the principles of lawfulness, propriety and necessity, and obtain your individual consent.

2. Transfer

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

- We will transfer your personal information to other third parties after obtaining your express consent or authorization.

- In the event that the transfer of personal information is required in connection with a merger, separation, dissolution, being declared bankrupt, etc., we will require the new recipient holding your personal information to continue to be bound by this policy, or we will require that recipient to seek your authorized consent again.

3. Public Disclosure

We will only disclose your personal information publicly if we

- obtain your separate consent, we may disclose your personal information publicly.

- where we are required to provide your personal information by law, regulation, mandatory administrative enforcement or judicial request, we may disclose your personal information publicly based on the type of personal information requested and the manner of disclosure.

4. Exceptions with your consent

Your authorized consent is not required for the sharing, transfer, or public disclosure of your personal information in the following cases, which comply with laws, regulations, and national standards, or for the purpose of fulfilling administrative or judicial authorities' requirements.

- It is necessary for the conclusion or performance of a contract with you.

- Necessary for the performance of legal duties or legal obligations.

- Necessary to respond to a public health emergency, or in an emergency to protect your life, health or property or the safety of others.

- Necessary to carry out news reporting, public opinion monitoring and other acts in the public interest, and to process your personal information within a reasonable range.

- To deal with your personal information that you have disclosed or have legally disclosed within a reasonable range.

- Other circumstances as stipulated by laws and administrative regulations.

Please be aware that if we take technical measures and other necessary measures to anonymize your personal information in accordance with applicable laws and regulations, the sharing, transfer, and public disclosure of such processed information will not require separate notification to you and your consent.

VI. Third Party Links and Related Policies

This website may contain links to other websites, which may be owned or operated by third parties and/or their affiliates, and these third parties and/or their affiliates may collect your personal information, and they and their servers may be located in the People's Republic of China or other countries/regions. We have no control over and are not responsible for the privacy policies and data protection policies of any such third parties and their affiliates. We strongly recommend that you review the privacy policies and data protection policies of all such third parties and their affiliates to understand how they handle the personal information they may collect from you.

VII. Updates to this policy

The privacy policy of this website may be updated periodically and will be marked with the date of the update. We strongly recommend that you visit the Site from time to time to check for updates or changes to the Privacy Policy. If you do not agree with the changes, you may stop using our website. If you continue to use this website, you accept the updated content of our privacy policy.

VIII. How to Contact Us

If you have any questions, comments, suggestions about this policy, or if you wish to exercise any of your rights as described above, please contact us at info@hoyinn.com. Normally, we will respond within [10] business days.

This policy was last published on [February], [14], [2023] and is effective from the date of publication.