Geekplus Technology Co., Ltd. (hereinafter referred to as “Geek+” or “we”) fully understands the importance of personal data to you and will make every effort to protect the security and reliability of your personal data. This Privacy Policy describes how we collect and process your personal data through Geek+ websites, devices, products, services, online and physical stores that reference this Privacy Policy.

We hope to clearly introduce to you how we process your information through this Privacy Policy (hereinafter referred to as “this Policy”), please be sure to read carefully and thoroughly understand this Policy, especially the bold terms which you should pay more attention to, and then start using it after confirming that you fully understand and agree to it. If you have any questions, comments or suggestions about the content of this Policy, you can contact us through the contact methods provided in [IⅩ. How to contact us].

This Policy will help you understand the following information:

I. Scope of application of this Policy

Ⅱ. How we collect and use your personal data

Ⅲ. How we transfer or disclose your personal data

Ⅳ. How we protect your personal data

V. Your rights

Ⅵ. How we use cookies and similar technologies

Ⅶ. How we protect personal data of minors

Ⅷ. How to update this Policy

Ⅸ. How to contact us

Ⅹ. Appendix: Provisions specific to EU users

This Policy applies to all services of Geek + Website (http://www.geekplus.com , hereinafter referred to as “Geek + Website”). Services include:

• Provide you with page browsing, whitepaper downloading, and “online message” services, provide you with instant chat services through the Geek + Website, and provide a Geek + phone service hotline, etc.
• This Policy does not apply to services provided to you by other third parties.
• If you have any questions, comments or suggestions, please contact us through the following contact methods:
• E-mail: dpo@geekplus.com
• Phone: 4000 450 010

(I) The circumstances under which we collect your personal data

When you “leave messages online” or apply to download whitepaper or live chat on the Geek + Website, you must provide us with your basic information, including (1) your name, the name of your organization (business duration, enterprise scale, main business, major products), your position, the industry you are engaged in, your specific ideas and needs; (2) contact information (e-mail, contact phone number), etc.

The e-mail address you submitted is used as one of the contact methods specified between you and the Geek + Website to receive relevant business notifications (such as new products launch, service changes, sending regular email direct marketing advertisements, etc.).

The information you provide in category (1) of this article will help us better understand your service requirements for the Geek + Website, so that the Geek + Website can promote and introduce products to you in a targeted manner; Geek + Website may use the above methods you provide in category (2) of this article, to promote to you, advertise products, conduct business communications with you or follow up.

If you only need using basic services such as page browsing on the Geek + Website, you do not need to provide the above information.

(Ⅱ) What kind of personal data we collect

During your use of Geek + Website services, we will collect the following information:

• Device information: Based on your use of the Geek + Website, we will receive and record information about the device you are using (such as device model, operating system version, device settings, unique device identifiers and other software and hardware characteristics information) and relevant information about the location of the device (such as IP address, GPS location, and sensor information like Wi-Fi access points, Bluetooth, and base stations that can provide relevant information);
• Log information: When you use the services provided by the Geek + Website or live chat, we will automatically collect your detailed usage information of our services and save them as relevant web logs. For example, your search query content, IP address, browser type, telecom operator, language used, date and time of access, and records of web pages you visit;
• When we provide you with specific services, we will collect, use, store, externally provide and protect your personal data in accordance with the provisions of this Policy; if we exceed the provisions of this Policy and the corresponding product service agreement to collect your personal data, we will separately explain to you the scope and purpose of the information collection and obtain your consent before collecting your information necessary to provide the corresponding services; if you choose not to provide the foregoing information, it will affect your use of the corresponding services/products, but it will not affect your use of the basic functions of the Geek + Website.

(Ⅲ) How we use your personal data

We use the personal data you submit and we collect for the following purposes:

• We use your personal data to provide functionality, analyze performance, fix errors, and improve usability and effectiveness of Geek + services;
  In order to provide you with our services, we will send you information, notifications or conduct business communications with you, including but not limited to push notifications necessary to use the services;
• In order to maintain and improve services and provide you with information display that better meets your personalized needs, we may use the personal data collected from certain services on the Geek + Website, to make feature models and draw user portraits, and then present, push information and potential commercials, including but not limited to, news about Geek + products, market events and promotional offers, or other contents that may interest you to you. If you do not want to receive commercials from us, you can send an email with your unsubscribe request to dpo@geekplus.com and/or by clicking on the unsubscribe link which is contained in every direct marketing email;
• We may design, develop, and promote brand-new products and services based on personal data statistics; we will make statistics on our service usage and may share these statistics with the public or third parties, but these statistics do not contain any of your identification information or organization name;
• In certain cases, we collect and process your personal data to comply with legal obligations;
• We will inform you again and obtain your explicit consent before using the personal data beyond the stated purpose when collecting the personal data, or before using the personal data beyond the scope that are directly or reasonably related. When you consent to our processing your personal data for a specified purpose, you may withdraw your consent at any time via sending an email to dpo@geekplus.com, and we will stop processing of your personal data for that purpose.

Your personal data may be transferred or disclosed in the following situations:

• Sharing with explicit consent: After obtaining your explicit consent, we will share your personal data with other parties;
• Sharing with other companies within Geek + group (which means, within the scope of a group-internal), collaborative process: Such data processing, where applicable, is necessary for the purpose of our legitimate interest to run our administration activities efficiently and collaboratively, and to improve our products and services;
• Sharing with authorized partners: We may entrust trusted partners to provide services, so we may share some of your personal data with partners to provide better customer service and optimize your user experience. We will only share your personal data for legitimate, proper, necessary, specific, and clear purposes, and we will only share personal data necessary to provide the service. Our partners are not authorized to use shared personal data for any other purpose.
• Currently, our authorized partners include the following types: customers, suppliers, service providers, and other partners. We will send information to suppliers, service providers, and other partners who provide support for our business. Such support includes providing basic technical services, providing consultations, analyses and other professional services. For companies, organizations and individuals with whom we share personal data, we will sign strict confidentiality agreements and information protection agreements with them, requiring them to process personal data in accordance with our instructions, this Policy and any other relevant confidentiality and security measures.
• Law-based disclosure: We may disclose your personal data in accordance with mandatory requirements of laws, legal procedures, litigation or government authorities;
• In order to facilitate transactions or assist in dispute resolutions, in some cases, only by sharing your personal data, can we facilitate transactions or handle your disputes or disputes with others.

• We attach much significance to your information security. We strive to take all reasonable and feasible measures to protect your personal data. We have used industry-standard security measures to protect the personal data you provide to prevent data from unauthorized access, public disclosure, use, modification, damage or loss;
• We will take reasonable and feasible measures to try to avoid collecting irrelevant personal data. We will only retain your personal data for the time period as long as necessary to achieve the purpose stated in this Policy, unless an extension of the retention period is required or permitted by law;
• The Internet environment is not 100% secured, and we will do our best to ensure the security of any information you send us;
• A personal data breach is “a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed”. If a personal data breach happens, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security event, the measures we have taken or will take, recommendations to prevent and mitigate risks by yourself and remedies for you, etc. We will promptly inform you about the event by email, letter, phone, push notification, etc. When it is difficult to inform users of the information one by one, we will make an announcement in a reasonable and effective way;
• At the same time, we will proactively report the disposition of the personal data breach in accordance with the requirements of regulatory authorities.

You have certain rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances as set out in more detail below. We set out how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights.

(I) Access your personal data

You have the right to access your personal data, with the exception of situations specified in laws and regulations. If you want to exercise the right of data access, you can access it by using our web form, or sending an email to dpo@geekplus.com, and we will respond to your access request within 30 days.

We will provide you with other personal data generated when you use the Geek + Website or service, as long as we do not need to put too much investment. If you want to exercise data access rights, please send an email to dpo@geekplus.com.

(II) Correct your personal data

You have the right to ask us to make a correction when you find an error in your personal data we process. You can apply for a correction through the methods listed in “[(I) Access your personal data]”. If you are unable to correct this personal data through the above methods, you can contact us at any time by using our web form or send an email to dpo@geekplus.com, and we will respond to your correction request within 30 days.

(III) Erase your personal data

You can request us to delete personal data in the following situations:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw consent on which the processing is based (and we have no other grounds for processing the personal data);
• you exercised right to object to processing of your personal data;
• the personal data have been unlawfully processed;
• the erasure is compliant with a legal obligation;
• the personal data have been collected in relation to the offer of information society services to a minor.

Please note, however, that we may retain the personal data when processing is necessary, but we will let you know if that is the case. Exceptions are the followings:

• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• for reasons of public interest in the area of public;
• for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in so far as the right is likely to render impossible or seriously impair the achievement of the objectives of that processing;
• for the establishment, exercise or defense of legal claims.

Where you have requested that we erase your personal data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the personal data or providing links to the personal data to erase it too.

(Ⅳ) Change the scope of your authorized consent

Each business function requires some basic personal data to be provided. For the collection and use of additional collected personal data, you can give or withdraw your authorized consent at any time.

You can do it by sending an email to dpo@geekplus.com, and we will respond to your request of changing the scope of your authorized consent within 30 days.

When you withdraw your consent, we will no longer process the corresponding personal data. However, your decision to withdraw your consent will not affect the processing of personal data previously performed based on your authorization. If you do not want to receive the commercial advertisements we send you, you can cancel at any time by sending an email to dpo@geekplus.com.

(V) Constrain the automatic decision of the information system

In some business functions, we may only make decisions based on non-manual automatic decision-making mechanisms including information systems, algorithms, etc. If these decisions significantly affect your legal rights, you can ask us to explain.

(VI) Respond to your above request

For security reasons, you may need to provide a written request or prove your identity otherwise. We may ask you to verify your identity before processing your request. We will reply within 30 days. If you are not satisfied, you can also complain through the following channels: making a phone call to 4000 450 010.

For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed a reasonable limit, we will charge a certain cost depending on conditions. For those requests that are unreasonably repetitive, require excessive technical means (for example, need to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on backup tapes), those requests may be rejected by us.

We will not be able to respond to your request in the following situations:

• Related to the fulfillment of the obligations stipulated by laws and regulations by the personal data controller;
• Directly related to national security and national defense security;
• Directly related to public safety, public health, and significant public interests;
• Directly related to criminal investigation, prosecution, trial and enforcement of judgments;
• For the purpose of protecting your or other individuals ‘ significant legitimate rights and interests;

Responding to the request of the subject of the personal data will cause serious damage to the legitimate rights and interests of the subject of the personal data or other individuals and organizations.

In order to ensure the normal operation of the website, get easier access experience for you, and make recommendations that may interest you to you, we store small data files called Cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. We can only read Cookies provided on the Geek + Website.

With Cookies, data such as your preferences can be stored. When you visit again, we will display the information you need; or the Geek + Website will use Cookies to identify your source website so that we can track the advertising effectiveness of Geek + website.

You can manage Cookies according to your preferences, or you can clear all Cookies saved on your computer. Most web browsers have a function that blocks Cookies. But if you do this, you need to change user settings every time you visit our website. To learn more about changing your browser settings, visit the settings page for your browser.

In addition to Cookies, we use other similar technologies such as web beacons and pixel tags on our websites. For example, the email we send you may contain an address link to the content of our website. If you click on the link, we will track the click to help us understand your product or service preferences so that we can proactively improve customer service experience. A web beacon is usually a transparent image embedded in a website or email. With the help of the pixel tags in the email, we can know whether the email is opened. If you do not want your activity to be tracked in this way, you can unsubscribe from our mailing list at any time.

Our products, websites and services are primarily for adults. (The definition of adults shall subject to relevant laws where the user resides in.) If you are a minor, we require you to ask your parents or guardians to read this Policy carefully and use our services or provide us with information with the consent of your parents or guardians.

In the situations where minor personal data is collected with parental consent, we will only use or disclose this information if it is permitted by law, with the parent or guardian’s explicit consent, or it is necessary to protect the minor.

Our Privacy Policy is subject to change.

We reserve the right to supplement and modify the content of this Policy. The updated Privacy Policy applies from the time, in which it was published on our websites.

For significant changes, we will also provide more prominent notifications (including for certain services, we will send notifications via email explaining the specific changes to the Privacy Policy).

Significant changes referred to in this Policy include, but are not limited to:

• Our service model has undergone significant changes, such as the purpose of processing personal data, the type of personal data processed, and the manner in which personal data is used;
• We have undergone significant changes in terms of ownership structure and organizational structure, such as business adjustments, bankruptcy mergers and acquisitions, etc.;
• The main objects of sharing, transferring or publicly disclosing personal data have changed;
• Your right to participate in the processing of personal data and its exercise methods have changed significantly;

When our responsible department, contact method and complaint channel for processing the security of personal data have changed.

If you have any questions, comments or suggestions regarding this Policy, please contact us via sending an email to dpo@geekplus.com, or making a phone call to 4000 450 010.

If you are an individual in the European Union (EU) whose personal data we process in relation to either our offer of goods or services to you or our monitoring of your behavior in the EU (EU Users), the following additional provisions may also apply to you.

(I) Transfers of your personal data outside of the European Economic Area

Your personal data may be processed by us, and our trusted third party suppliers outside of the European Economic Area (EEA), including in countries where data protection and privacy laws or regulations may not be equivalent to, or as protective as, the data protection and privacy laws and regulations in the EEA.

In accordance with applicable data protection and privacy laws and regulations, we will implement appropriate measures to ensure that your personal data remains protected and secure when it is transferred outside of the EEA to a jurisdiction other than one that is recognized by the European Commission has having an adequate level of protection of personal data. These measures include (where applicable) transferring pursuant to data transfer agreements implementing Standard Contractual Clauses (SCC). If you would like further information, you can contact us by sending an email to dpo@geekplus.com.

We may also transfer your personal data outside of the EEA as permitted by applicable data protection and privacy laws and regulations. Examples include where we need to transfer your personal data: (a) to perform a contract with you (or to take steps before the contract at your request); (b) perform a contract in your interests; or (c) in relation to legal claims.

(Ⅱ) Your right of personal data portability besides the rights specified in [V. Your rights]

You have the right to receive a copy of certain personal data we collect from you. This comprises any personal data we process on the basis of your consent (e.g., your profile). You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal data to another party. You can exercise your right to export your data by using our web form or send an email to dpo@geekplus.com, stating at least your first and last name and your request.

If you wish for us to transfer the personal data to a third party, please ensure you detail that party. Note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the third party. We also may not provide you with certain personal data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person or our trade secrets or intellectual property).

Please note for other matters not covered in this Policy, we will protect your legitimate rights in regards to your personal data according to relevant provisions of applicable laws and regulations in EU, e.g. the General Data Protection Regulation for EEA.