SZhongya Corporation and its affiliates and subsidiaries (collectively, "we," "us," or "our") take your privacy seriously. This policy describes how we collect, use, disclose, transfer and otherwise process the personal information of website visitors, consumer customers and other individuals who interact with us ("you," "yourself," or "your"). It also tells you your rights regarding your personal information and how you can contact us to update it or get answers to questions you may have about our privacy practices.

1. Scope

This policy applies to SZhongya processing of personal information, which is any information that identifies, relates to, describes, references, is capable of being directly or indirectly associated with, or could reasonably be associated with, an identified or identifiable natural person such as you. Personal information does not include information in de-identified or non-personally identifiable form.

This policy covers:

• SZhongya hardware products (including our fiber optic transceivers, POE power injectors, optical modules, POE extenders, routers, gateways, bridges, wireless APs, AC controllers, etc.)
• Software that can be downloaded to your smartphone or tablet to access the Services (the "Mobile Application")
• Subscription Services, including services that you can access using the Web Application and the Mobile Application (the "Subscription Services"), (collectively, the "Services")

Third parties may also integrate SZhongya products and services into their products and services, and we are not responsible for this integration. Please keep in mind that the manner in which these third parties use, store, and disclose your information is governed by the policies applicable to the third-party products and services. Because SZhongya does not control the privacy policies of third parties, we encourage you to review the policies of any third party with which you choose to directly share your personal information.

Additional information about our privacy practices may be provided in other documents, such as descriptions provided, supplemental privacy statements, or notices provided prior to or at the time of data collection.

2. Read the Privacy Policy

We recommend that you read this Privacy Policy in its entirety to ensure that you fully understand it.

3. What does SZhongya do?

SZhongya is a national high-tech enterprise specializing in the research and development, production, sales and service of intelligent network communication products and equipment such as PoE switches, industrial switches, SFP switches, and media converters. It is headquartered in China.

4. What data does SZhongya collect?

The information we collect depends on the SZhongya product or service you use. We have collected the following categories of personal information in the past twelve (12) months:

Identifiers:

This includes contact details, such as your name, alias, mailing address, phone number or email, as well as your user ID, password hint and similar security information required for authentication and access to our platforms, such as the SZhongya App. We collect this information directly from you. For example, we ask you to provide your contact details in order to register an account with us, subscribe to our marketing communications, apply for a giveaway or promotion or become a beta tester, or submit an inquiry to us.

We collect information when you interact with us online or by phone or mail with our help desk, online store and customer support channels, respond to our customer surveys or contests or provide us with additional information, facilitate the delivery of our products and services, and respond to your inquiries.

When you visit our websites or use our products and services, we may also automatically collect certain information from your device, web application or mobile application, such as your IP address, online identifiers, unique device identifiers, advertising identifiers, broad geographic location (such as country or city location) and other technical information. In some countries, including those in the European Economic Area, this type of information may be considered personal information under applicable data protection laws.

We may also collect information (such as business contact details) from our stores, dealers or distribution partners, or people you may know, and recommend your work and other marketing materials. Please note that in these cases, we will check with the third party to ensure that they have obtained your prior consent or are otherwise legally permitted or required to disclose your personal information to us.

Customer Record Information:

This includes your name, signature, address, telephone number, employment, employment history, bank account number, credit card number, debit card number, or any other information that constitutes a customer record under applicable law. We collect this information directly from you.

For example, we collect your debit or credit card number when you purchase a product or subscription to use our products or services, or shipping services related to warranty replacements, or when you purchase/authorize an application from the SZhongya app store.

Characteristics of protected classifications in certain jurisdictions (e.g., under California or federal law): This includes demographic information, which may include sex (such as gender and gender identity), age, race, ethnicity.

Commercial Information:

This includes information such as records of SZhongya products or services you have purchased, obtained, or considered. We collect this information directly from you.

Internet or other network activity information:

This includes information such as network speed, error rates, application downloads and use, firmware versions, configuration settings, WiFi settings, network speed, voltage information, storage information, error rates, application downloads and use, service and feature use, crash diagnostics, and other performance information. We may collect this information directly from your device.

Collecting this information allows us to better understand the visitors and the customers who use our products and services (and what content or features are relevant and interesting to them). We also collect this information to provide you with appropriate upgrades and support and to improve our products and services.

Geolocation data:

This includes broad geolocation (e.g., country or city-level location). We may collect this information directly from your device.

Audio, electronic, visual or similar information:

This includes chats, images, and audio, video or call recordings created when you contact us, such as when you contact our customer service team for support or assistance. We collect this information directly from you.

Professional or employment-related information:

This includes your business contact details to provide information such as business-level services. We may also collect your contact details and information about your professional qualifications, including your resume and references when you apply for a job at SZhongya. We collect this information directly from you or when it is provided by job applicants.

Inferences:

This includes information inferred from any of the personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics.

Electronic and Usage Information:

This includes information about how your device interacts with our websites, including pages visited and links clicked, or our products. Specifically, the information we automatically collect may include your IP address, device type, unique device identifier, firmware and software version, registration and configuration settings, service and feature usage, crash diagnostics and performance information, advertising identifiers, browser type, broad geographic location (such as country or city level location), and other technical information.

If you use our SZhongya APP products, we also collect functional data, including product type, device type, controller operating system, software version, WiFi antenna information, product orientation, the name of the SZhongya APP product you provide in different rooms, and error messages. We collect this information to help ensure the proper functioning of your SZhongya APP products and devices, provide you with customer support, and respect your visual art preferences. We may also collect this information to guide product and device improvements and customer support decisions.

We may also collect additional personal information beyond these categories when you:

• receive assistance through our help desk or other customer support channels
• participate in customer surveys or contests
• assist in providing our services and respond to your inquiries

In these cases, we collect this information directly from you.

Third-party personal information:

If you choose to provide us with personal information (such as name, email, and phone number) of a third party, you must ensure that you have permission from the third party. For example, providing us with your name and image associated with an account user, forwarding testimonials or marketing materials to a friend, or sending a job recommendation. We only collect personal information from third parties if those third parties have your consent or are otherwise permitted or required by law to disclose your personal information to us.

5. How we use your personal information:

At SZhongya, we only use your personal information for legitimate business purposes. Such purposes include:

a. To provide you with the services you have requested or subscribed to and to communicate with you about those services.

We will use your personal information to provide our services and to interact directly with you.

b. Maintain, improve, and develop our products and services.

We will use your personal information to ensure that our products and services work as expected and to improve our products and services. We will also use the information we collect in existing services to help us develop new services or customize services for you.

c. Internal Data Analysis.

We use personal information for internal analysis to understand how our services are used.

d. Marketing.

We may send you marketing information about products, services, offers, programs and promotions (including contests, sweepstakes and any other marketing activities) directly from us or from our partners. These may be our own offers or products, or offers for third-party products that we think you may find interesting, but we do not share the information for third parties' independent marketing or promotional purposes.

e. To protect our company, prevent fraud, and protect our products.

We may use your personal information to protect our company, our customers, or our website.

f. Comply with laws and other standards.

We may use your personal information as required by applicable laws and regulations or as requested by any judicial process or governmental agency claiming jurisdiction over SZhongya or its affiliates.

g. To fulfill or satisfy the reason you provided the information.

For example, if you share your name and contact information to ask a question about our products or services, we will use that information to respond to your inquiry. If you contact us regarding support for a product or service, we will use your personal information to provide you with support and respond to your inquiry, including to investigate, address your concerns, and monitor and improve our responses.

h. Other Activities.

We may use your personal information for other purposes for which we provide specific notice at the time of collection.

6. How we share your personal information

On SZhongya APP, we will only share your personal information when we have a legitimate business reason to do so. In the past 12 months, we have shared and shared the following categories of personal information (in each case, the categories of personal information are described in Section 4 above, "What data does SZhongya collect?"):

• Identifiers;
• Customer record information;
• Characteristics of protected classifications in certain jurisdictions (e.g., under California or federal law);
• Commercial information;
• Internet or other electronic network activity information;
• Geolocation data;
• Audio, electronic, visual or similar information;
• Professional or employment-related information;
• Reference materials;
• Electronic information and usage information.

We share these categories of personal information (listed in Section 5 above, entitled "How We Use Your Personal Information") or as otherwise disclosed to you at the time of collection in the following ways:

a. Within the SZhongya family of companies around the world.

We may share the personal information we collect with our head office and affiliated companies.

b. With our suppliers, service providers, agents, and representatives.

We may share personal information with our suppliers, service providers, agents, representatives, dealers, distributors, referral partners, and integrators who, based on our instructions and subject to appropriate confidentiality and security measures, support our business and perform services on our behalf. Examples of services include: processing orders and credit card transactions, detecting and preventing fraud, providing customer support, creating marketing content, and assisting us with sales-related tasks or post-sales support. This also includes our service partners with whom we provide co-branded services, such as security software, or participate in joint marketing activities.

c. We may share information with any successor to all or part of our business.

We may sell, transfer or otherwise share some or all of its assets, including personal information, in connection with a merger, acquisition, reorganization, sale of assets, spin-off of assets into a separate business or similar transaction, or in the event of bankruptcy. If such an event occurs, we will use reasonable efforts to direct the assignee to use the personal information you provided to us in a manner consistent with this Privacy Policy.

d. We may share information for legal reasons.

We will share personal information with companies, organizations or individuals outside of SZhongya if we believe in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:

• Satisfy any applicable law, regulation, legal process or enforceable governmental request;
• Enforce applicable Terms of Use, including investigation of potential violations;
• Detect, prevent or otherwise address fraud, security or technical issues;
• Protect our rights, or for our operational business purposes;
• Protect against harm to the rights, property or safety of SZhongya, its employees, users or the public as required or permitted by law.

e. Others.

If we notify you otherwise and you consent to sharing.

7. Your Rights and Choices

Depending on your country or state of residence, you have certain rights regarding the personal information we maintain about you, as well as certain choices about the personal information we collect from you, how we use it, and how we communicate with you.

The right of access means you have the right to ask us to disclose the personal information we have collected, used and disclosed about you.

The right to erasure means you have the right to ask us to delete personal information collected or maintained by us, subject to certain exceptions.

The right to non-discrimination means you will not receive any discriminatory treatment when you exercise your privacy rights.

You may also ask us to correct or update your personal information; object to the processing of your personal information; ask us to restrict the processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the headings "How to Contact Us and How to Exercise Your Privacy Rights" below.

You have the right to opt-out of marketing communications we send you at any time. We do not share information with third parties for their independent marketing or promotional purposes.

Again, if we have collected and processed your personal information with your consent, then you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to lodge a complaint with a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

8. Notice to California Residents

As described above, SZhongya may provide certain personal information to third parties to provide or improve our products and services, such as to provide products or services at your request. In such cases, we require these third parties to handle such information in accordance with applicable laws and regulations.

SZhongya does not sell personal information to third parties (pursuant to California Civil Code Sec. 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018) nor does it share personal information with third parties for their direct marketing purposes (pursuant to California Civil Code Sec. 1798.83).

9. Data Transfer

SZhongya is a global business. We may transfer your personal information to recipients outside of your country, including China where our headquarters are located. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect the information as described in this Privacy Policy or as disclosed to you at the time your data was collected. By using our website, products and services or providing any personal information, you consent to the transfer, processing and storage of your personal information outside of your country of residence, as permitted by applicable law.

If you are located in the European Economic Area ("EEA"), we will comply with applicable legal requirements to provide adequate safeguards for the transfer of personal information outside of your country. In particular, we use contractual safeguards for the transfer of personal information to third parties, such as the European Commission's Standard Contractual Clauses.

10. Privacy Shield Notice

SZhongya complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks ("Privacy Shield") as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom, and Switzerland. SZhongya certifies that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability, Security of Onward Transfer, Data Integrity, Purpose Limitation, Access, Recourse, Enforcement, and Liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

SZhongya's responsibilities for data it receives pursuant to the Privacy Shield and for subsequent transfers to third parties are detailed in the Privacy Shield Principles. SZhongya complies with the Privacy Shield Principles for all onward transfers from the EU and Switzerland, including the onward transfer liability provisions. Third-party agents process personal data on its behalf in accordance with the Privacy Shield Principles.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

SZhongya commits to resolve complaints regarding your privacy and our collection and use of your personal information within 45 days of receiving your complaint. Individuals with questions or complaints regarding this Privacy Policy should first submit inquiries via email to 344628262@qq.com. In limited circumstances, if your complaint is not resolved through these channels, binding arbitration may be a dispute resolution mechanism.

11. Legal Basis for Processing

If you are located in the European Economic Area, we will process your personal information for the purposes set out in Section 5 above on "How we use your personal information" based on the following legal bases:

a. You have consented to the use of your personal information.

For example, when you visit our website, we may seek your consent to our use of cookies or to send you marketing information.

b. We need your personal information to provide you with the products and services you request, or to respond to your inquiries.

c. We have a legal obligation to use or disclose your personal information, for example, if we are responding to legal process or an enforceable government request.

d. We (or a third party) have a legitimate interest in using your personal information.

In particular, we use your personal information to:

• Provide, maintain and improve our Services to meet the needs of you and other users;
• Develop new products and features that are useful to you and our other users;
• Understand how people use our Services to ensure and improve the performance of our Services;
• Customize our Services to provide you with a better user experience;
• Marketing to inform existing customers about our Services;
• Detect, prevent or otherwise address fraud, abuse, security or technical issues in our Services;
• Protect against harm to the rights, property or safety of SZhongya, our users or the public as required or permitted by law;
• Conduct research to improve our Services for users and for the benefit of the public;
• Fulfill obligations to partners such as developers and rights holders; and enforce legal claims, including investigations of potential violations of applicable terms of use.

In addition, if we rely on your consent to process your personal information, you have the right to withdraw it at any time, free of charge. When you do so, this will not affect the lawfulness of the processing before your consent was withdrawn.

12. Alternative Privacy Policy Formats

If you are unable to access this Policy due to disability or any physical or mental impairment, please contact us and we will arrange to provide the information you require in an alternative format that is accessible to you.

13. How to contact us and exercise your privacy rights

You may exercise your rights yourself or, depending on your country or state, you may designate an authorized agent to exercise these rights on your behalf. Please note that to protect your personal information, we will verify your identity through methods appropriate to the type of request you are making. For example, this may include sending an email to the account on record or asking you to identify recent transactions or communications. We may also require your authorized agent to obtain your written permission to make a request on your behalf, and we may also need to verify the identity of your authorized agent to protect your personal information.

If you prefer, you can use the contact details below to:

• Access this Privacy Policy in an alternative format;
• Exercise your rights;
• Learn more about your rights or our privacy practices;
• Or designate an authorized agent to make a request on your behalf.

14. Children's Privacy

Our Products and Services are meant for adults. We do not knowingly allow children under 18 to set up SZhongya accounts. If you are under 18, do not use the Sites or Services. If we learn that we have collected or received personal information from a child under 18 without parental consent, we will delete that information. If you believe that we may have collected Personal Information from someone under 18, please let us know using the methods described in the Contact Us section and we will take appropriate measures to investigate and address the issue promptly.

15. How We Protect Your Personal Information

We intend to protect the personal information entrusted to us and to treat it securely and in accordance with this Privacy Policy. We maintain administrative, technical and physical safeguards to protect personal information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of personal information in our possession. We also contractually require our suppliers to protect this information against unauthorized access, use and disclosure. The security of your information also depends on you. If we have given you (or where you have chosen) a password to access certain parts of our Website or Services, you are responsible for keeping this password confidential and not sharing it with anyone. We also encourage you to exercise caution when using the Internet because it is not 100% secure. Therefore, we cannot guarantee the security of your personal information transmitted electronically, nor can we guarantee that your use of our Website and Services will be completely secure. Any transmission of personal information is always at your own risk.

If you participate in a forum, local community, or chat room on an SZhongya website, you should be aware that the information you provide there (i.e., your public profile) will be made widely available to others and could be used to contact you, to send you unsolicited messages, or for purposes neither SZhongya nor you control. In addition, please recognize that individual forums and chat rooms may have additional rules and conditions. SZhongya is not responsible for the Personal Information or any other information you choose to submit in these forums. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we cannot do so and why.

16. Retention of Personal Information

We will also take steps to delete your personal information or store it in a form that does not allow you to be identified when it is no longer necessary for the purposes for which we process it or when you request its deletion, unless we are permitted or required by law to retain it for a longer period of time. We review our databases regularly and set time limits for the deletion of certain data based on the types of services provided in our products and services, the length of our relationship with you, mandatory retention periods, and statutory limitations.

17. Third-Party Services

Our Services may contain features or links to websites and services provided by third parties. If you click on a link to a third-party website, you will be taken to a website controlled by us. These links are provided for your information and convenience only and are not an endorsement of such linked websites or third-party content. Any information you provide on a third-party website or service may be provided directly to the operators of that service and is subject to the policies of those operators, if any, even if accessed through us. This Policy does not apply to the privacy practices of that website. We encourage you to carefully read the privacy policy of that website. We are not responsible for third-party websites or services that are linked or accessible through our Services, and we are not responsible for their content or availability.

18. Updates to this Privacy Policy

We may update this Privacy Policy from time to time. If we modify our Privacy Policy, we will post the revised version here with an updated revision date. We recommend that you visit these pages periodically to be aware of and review any such revisions.