Privacy Policy

Last updated: November 1, 2021

Your trust is very essential to us. We are well aware of the importance of personal information to you. We will take appropriate security measures as required by laws and regulations and do our utmost to ensure that your personal information is secure and controllable. In view of this, YUNDING (hereinafter referred to as "we" or "us") has formulated this Privacy Policy (hereinafter referred to as the "Policy" or the "Privacy Policy") and reminds you: Before using the products and services on YUNDING Website, please be sure to carefully read and thoroughly understand the Policy. Use of any YUNDING service will be deemed that you have full understanding and agreement to the Policy. You are not obligated to provide us with your personal information. But if you refuse to provide the personal information necessary for a particular service, we may not be able to provide you with the goods and services you request.

If you have any questions, comments, or suggestions about the content of the Policy, contact us at:

YUNDING Privacy Office: privacy@Lockin.com.

Definitions

"YUNDING Website": refers to YUNDING's official website (the domain name is: www.Lockin.com).

Affiliated company: refers to a company directly or indirectly controlled by YUNDING; or directly or indirectly controlling YUNDING; or jointly controlling the same company with YUNDING or being able to jointly exert significant influence on the same company with YUNDING; or being directly or indirectly controlled by the same company as YUNDING is, which include but are not limited to YUNDING's parent company, subsidiaries, or subsidiaries controlled by YUNDING's parent company.

Personal information: refers to all kinds of information related to an identified or identifiable natural person recorded electronically or in other ways, excluding anonymized information.

User information: refers to your membership information such as names, contact information, etc. submitted by you or collected by YUNDING when you register a YUNDING website account, use YUNDING's products or services, and when YUNDING provides you with services. For details, refer to the information specified in Article 3 of the Privacy Policy.

Business information: Different from user information, it refers to the information processed by Yunding's users through YUNDING's technical services, such as the information uploaded, downloaded, and distributed through YUNDING's technical services.

Smart devices: refer to non-standard computing devices produced by hardware manufacturers that have human-machine interfaces and can transmit information through wireless networks, such as smart home appliances, smart wearable devices, and smart air purification devices.

Scope

YUNDING INTERNATIONAL PTE.LTD and its affiliated companies and subsidiaries (hereinafter collectively referred to as "we", "us" or "YUNDING") deem that your personal privacy is very important to you, and therefore take your privacy rights seriously. The Policy describes how we collect, receive, use, store, share, transfer and process your information, and the rights to determine how we process the information about you that we collected or held in the following circumstances: your visiting or using our website and network resources (www.Lockin.com) and any services we provide to you, collectively referred to as "services".

The services may contain links to other websites or online services that are operated and maintained by third parties instead of us. The Policy does not apply to how third parties collect, use, disclose, or retain any information. We recommend that you read the privacy policies regarding these third-party websites or services.

Information We Collect

1.Information We Collect Automatically

When you use our website and services, we may collect certain information about your use of the website and our services, including your personal information:

• Device access information: When you interact with our website and services through hardware, we will automatically collect your devices' information, such as your devices' unique identifiers, serial numbers, IP addresses, wireless connection information, operating system types and versions, browser types and versions, push notification identifiers, and mobile network information.

• Usage information: During your interaction with our website and services, we will automatically collect the usage information related to visiting, clicking, downloading, sending/receiving messages, and other usage related to the use of our website and services.

Our purpose in collecting and using such information is to improve the products or services we provide to you and to provide you with different information due to different categories or functions of our products or services.

• Log information: When you use YUNDING's website or services, system logs, abnormal logs, or operation logs deemed risky may be uploaded. Such logs include your IP addresses, languages used, operating system versions, and access time.

Please note that it is not possible to identify a specific natural person with separate device information and service log information. If we use this type of non-personal information together with other information to identify a specific natural person, or use this type of non-personal information together with personal information, during such use period, this type of non-personal information will be treated as personal information, and we will de-identify this type of information unless we have obtained your authorization or otherwise stipulated for by laws and regulations.

2.Information from Third Parties

We may obtain your personal information from third parties in some cases permitted by law. For example,

• You have authorized a third party to transfer your information to us;

• We may obtain certain information from third-party partners, such as corporate names, corporate contacts, corporate emails, and other public information;

Cookies and Other Similar Tracking Technologies

When you visit our website and use our services, we, and our service providers on our behalf, may send one or more small data files -- "cookies" to your device for unique identification of your browser and for us to help you speed up your login and facilitate our website navigation. Cookies help us collect data such as the total number of visitors to the website, the number of visitors to each page, how our users use and interact with our services, and the domain names of visitors' Internet service providers. You can reset your web browsers to reject all cookies or specify when to send a cookie. If you do not want to install cookies on your device, you can reject cookies through simple settings, which is allowed by most browsers. Please note that if you have disabled cookies on your device, some functions of the website and services will not work properly.

We may also use web beacons to track the usage patterns of service users. We may also use HTML emails sent to users to track which emails a recipient has opened. Such information is used to ensure that the reports are more accurate and we provide you with better services.

We respect the "Do Not Track" signals or similar technologies detected and recognized by systems. When such a "Do Not Track (DNT)" browser mechanism is in place on your device, we will not track relevant information, implant cookies, or place any ads.

Purposes and Legal Basis for Processing Personal Information

When you use YUNDING's products or services, make sure you have understood our Terms of Service. When you agree to our terms of use and require us to fulfill our contract with you, the purposes or legal basis for processing your personal information are as follows:

• To provide you with our products or services: We process the information about your account, device, and usage to provide the services you request or purchase. The legal basis for such processing is that we fulfill the contracts with you according to the terms of use.

• To maintain and improve our services: We analyze trends by processing the information about your device and usage, and if necessary, track your use of our website and services, so as to develop and improve our website and provide content that is more relevant and useful to our users. The legal basis for such processing is that we fulfill the contracts with you according to the terms of use.

• To handle contact and support requests: When you use any of YUNDING's online or offline products or services, we will process your personal information in order to contact you, such as providing you assistance based on the diagnosis on your smart device to meet your requests, reply to your inquiries and to offer you support. Especially, when you encounter problems when using YUNDING's products or services, please contact YUNDING's customer service team (service@Lockin.com) as soon as possible so that we may locate the problem more promptly and provide you with a solution. The legal basis for such processing is that we fulfill the contracts with you according to the terms of use.

• Research: We process your personal information for our internal business purposes, such as statistics and analysis, auditing, new product or service development, service improvement, and usage trend confirmation. The legal basis for such processing is that we fulfill the contracts with you according to the terms of use.

• Compliance: We only disclose your personal information when the law requires us to do so, or when we deem it necessary or appropriate to process such information:

(a) To comply with applicable laws and regulations, legal procedures or requests from public agencies and government authorities;

(b) To fulfill our terms of use and other agreements, policies, or standards, including investigating any potential violations in use;

(c) To protect the rights, privacy, safety, or property of us and/or other users including you; and

(d) To seek applicable detection, prevention, or remedial measures, limit the compensation for damages we may need to provide, or address security, fraud, or technical issues.

If there are any changes in any purposes of processing your personal information, we will notify you of such changes via email and/or a noticeable announcement on our website, and inform you of the choices about your personal information.

How We Share Your Personal Information

YUNDING shares/discloses your personal information with related parties only in the ways known to you and only under the circumstances outlined below:

• Sharing information with your explicit prior consent: We will transfer your user information to other parties after obtaining your explicit consent;

• Disclosing your personal information to third-party service providers who provide us with certain business-related services, such as web hosting, data analysis, payment and credit card processing, infrastructure supply, IT services, customer support, email delivery, and other similar services, to ensure that they can provide relevant services to us.

• Disclosing your personal information to customers and other business partners who directly or indirectly provide you with smart devices and/or the networks and systems that you use to access and use our website and services.

• Disclosing your personal information to our subsidiaries or affiliates, so that they can carry out business activities on a regular basis in line with relevant laws and regulations, our instructions, this Privacy Policy, or other appropriate confidentiality and security measures.

• Disclosing your personal information to our affiliated companies and other third parties when there is a reorganization, merger, sale, joint venture, transfer, or other ways of disposing of all or part of our business, assets, or stocks (including but not limited to the above circumstances related to any bankruptcy or similar proceedings). In such cases, you will receive a clear notification via email and/or our website regarding the change of ownership, the incompatibility of new ways to use personal information, and the choices about personal information.

• We will reasonably and legally share your personal information under the following circumstances when necessary or appropriate:

(a) Complying with applicable laws and regulations, legal procedures, policies and/or standards, or requirements of corresponding public institutions and government authorities;

(b) Fulfilling our terms of use and other agreements, policies, and standards, including investigating any potential violations;

(c) Protecting our operations, business, and systems;

(d) Protecting the rights, privacy, safety, or property of us and/or other users including you; and

(e) Managing, detecting, and identifying risks related to illegal, fraudulent, deceptive, or malicious activities.

Transmission of Collected Information

YUNDING carries out its business around the globe, so the personal information we collect in accordance with the Policy may be transferred, stored, and processed in different countries or regions. We will strictly abide by the laws, regulations, and requirements related to the protection of personal information, though applicable laws and regulations of the country or region where we operate may be different from those of the country/region where you live. Therefore, in order to promote our operations, under the framework of personal information protection we may transfer your personal information to other countries or regions where we conduct business. Our privacy and security practices are designed to provide global protection for your personal information, no matter where your information is stored.

In particular, when the personal information of users in the European Economic Area (EEA), Switzerland, or the United Kingdom is transferred to a recipient outside the EEA, Switzerland, or the United Kingdom and the recipient is not considered to have sufficient information protection capabilities, we will ensure compliance with the EU Standard Contractual Clauses in the information transmission.

Click the link below to view the agreement reached on the EU Standard Contractual Clauses approved by Article 46 of the EU General Data Protection Regulation (GDPR).

https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

The personal information collected and generated within the mainland of the People's Republic of China during our operations will be stored in data centers in the Chinese mainland unless cross-border transmission is permitted in accordance with applicable laws.

Protection Measures

We take commercially reasonable physical, managerial, and technical protection methods to ensure the integrity and security of your personal information. YUNDING provides multiple protection strategies to effectively ensure the security of user and device information.

In terms of device access, we apply YUNDING's proprietary algorithms to ensure data isolation, access authentication, and authorization applications.

In terms of data communication, we adopt security algorithms and encryption protocols for transmission as well as commercial-level information encryption transmission based on dynamic keys.

For data processing, we adopt strict data filtering and verification, as well as complete data review processes.

In terms of data storage, all confidential information of users will be securely encrypted for storage.

If you think that your interaction with us is no longer secure for any reason (e.g., if you believe that the security of your YUNDING account has been compromised), please send an email to privacy@lockin.com to inform us immediately.

If any security incident occurs that affects your personal information security, we will notify you as soon as possible via the email address or phone number you provided, or via push notifications, etc., to inform you of suggestions on how to reduce and prevent related risks. When necessary, we will take corresponding remedial actions promptly and in line with our internal security event emergency plans, and report to relevant competent authorities in accordance with regulations.

How to Exercise Your Privacy Rights

We respect your rights and will hold tight your personal information. You can contact us via email at privacy@lockin.com.

No payment is required in the exercising of your personal rights. According to local data protection laws, if your account service is provided in the Chinese mainland, we will respond to your requests within 15 working days; if your account service is provided outside of the Chinese mainland, we will respond to your requests within 30 calendar days.

In your requests, please specify what information you wish to modify, whether you wish to delete your personal information from our database, or what restrictions you wish us to be subject to when we use your personal information. Please note that, for security reasons, we may need to verify your identity before processing your requests further.

You can:

• Request access to your personal information that we process;

• Request us to rectify your personal information that is inaccurate or incomplete;

• Request us to delete your personal information;

• Request temporary or permanent restrictions on our processing of part of or all of your personal information;

• Request us to process your information based on your consent or a contract signed with you, and to transfer your personal information to you or a third party when we automatically process your information.

Withdraw Consent

You can send an email to privacy@Lockin.com to submit a request to withdraw your consent to us collecting, using and/or disclosing your personal information for which we keep or control. We will process your request within a reasonable time after you have sent the request, and we will, as you have required, no longer collect, use and/or disclose your personal information after that.

Please note that withdrawing your consent will lead to certain legal consequences. According to the scope of your personal information for which you have withdrawn consent to allow us to process, this may result in you being unable to enjoy our services.

Cancelation of Services or Accounts

You can cancel services or your accounts by sending an email to privacy@Lockin.com. You will not be able to use our services when you have canceled your accounts. Please be careful with your operation.

Data Retention Period

We will process your personal information within the shortest period of time required to achieve the purpose stated in the Policy unless we are ​required to retain it for a longer period of time according to specific legal requirements We will determine an appropriate retention period based on the quantity, nature, and sensitivity of your personal information, and we will destroy your personal information when the retention period ends.

1) We will retain your information in accordance with the Terms of Service and the Policy to meet your requests of products and services;

2) When you explicitly request to delete your personal information, we will set your request as a task and no longer keep your personal information. We will take appropriate methods to prevent further use of your personal information if we are unable to destroy the data for technical reasons.

Privacy Protection for Minors

YUNDING's services are mainly for adults. Minors under the age of 14 (hereinafter referred to as "children") are not allowed to create their own user accounts without the consent of their parents or guardians. Our Policy does not require children's personal information or the sending any promotional materials to children.

YUNDING will not seek or attempt to seek any personal information from children. We hold that it is the responsibility of parents to supervise children's use of our products and services. For children's personal information collected with the consent of their parents, we will use or disclose such information only when it is permitted by law, when we have obtained their parents' or guardians' explicit consent, or when it is necessary to protect the child. If any parents or guardians have reason to believe that their children have submitted personal information to YUNDING without their prior consent, they can contact us to make sure such personal information is deleted.

Changes to the Privacy Policy

We may update the Policy based on the changes in information practices. If there are any major modifications, we will notify you through our platform news or emails (via the email address you provided), or make an announcement on this website before the modifications take effect.

We recommend that you regularly browse the news on the platform or this page to keep up with the latest privacy practices.

Contact Us

If you have any questions about our practices or this Policy, contact us in the following ways:

YUNDING INTERNATIONAL PTE.LTD

Mailing address: 2 VENTURE DRIVE #11-31 VISION EXCHANGE SINGAPORE 608526

Email: privacy@lockin.com.