Privacy Policy

Innovation Group website, Innovation Group and its affiliated businesses (hereinafter collectively referred to as "we" or "Innovation") attach great importance to protecting the personal information and privacy security of users (hereinafter collectively referred to as "users" or "you") who use our Internet products and services (hereinafter collectively referred to as "Innovation Internet Services"). When you use Innovation Internet Services, we may collect and use your relevant personal information. We hope to explain to you through the "Innovation Internet Service Privacy Policy" (hereinafter referred to as "this Policy") the corresponding processing rules and other related matters when we collect and use your relevant personal information, so as to better protect your rights and interests.

This Privacy Policy is formulated with full consideration of your needs, so that you have a comprehensive understanding of our personal information collection and use practices, and ensure that you can ultimately control the personal information provided to us. If you disagree with the content of this policy, it may cause our Internet products and services to not operate normally, and you should immediately stop accessing/using our products and or services. When you use or continue to use Innovation Internet Services, you agree that we collect, use, store and share your personal information in accordance with this policy (including updated versions).

If you have any questions, please contact us.

1. Acquisition and Use of Personal Information

In this Privacy Policy, "personal information" refers to data that can identify a specific individual through the information itself or by linking it to other information. We collect your personal data for different purposes during your interaction with us, which may include: contacting us when dealing with problems, browsing our website, and configuring our website settings or your account settings. We collect users' personal information mainly to optimize and innovate Internet services and provide users with personalized services in order to improve user satisfaction.

(I) Personal information collected and obtained and how they are collected

1. Information provided by users: including information provided by users when registering or using the innovative Internet service platform and system, and information that users agree to keep; shared information provided to other parties through the innovative Internet service platform and system, including but not limited to information uploaded or published in public areas visible to other users;

2. Information agreed to be shared: information shared with us by other parties with the authorization of the user;

3. Information we obtain: information we collect, summarize, and record when you use innovative Internet services, such as login logs, location information, IP information, device information, etc.;

(II) Use of personal information

1. Improving our products and services

In order to maintain and improve the quality of our products or services and provide you with personalized services, we may collect and use your information in accordance with legal provisions and based on your specific authorization. For example, based on your browsing and search history, construction machinery and equipment information, location information, etc., we recommend or display product/service information that you may be interested in, or display personalized goods and services to you through the system.

In addition, we may collect information you provide to us when you participate in product/service surveys, comments, and activities, as well as relevant information you provide when you interact with our affiliates and partners, so that you can initiate user suggestions and complaints, and we can optimize the quality and process of customer service.

2. Contact you

Send you information about products and services that may be of interest to you; invite you to participate in innovative Internet service activities (including promotional activities), market surveys or satisfaction surveys; or send you marketing information and other important notifications. If you do not want to receive such information, you can contact us to unsubscribe at any time.

3. Provide you with security

In order to improve the security of your use of our services, protect the personal and property safety of you or other users or the public from infringement, better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions and other security risks, and more accurately identify violations of laws and regulations or innovative Internet service-related agreement rules, we may collect, use or integrate your account information, device information, log information and information that our affiliates and partners have obtained your authorization or shared in accordance with the law to protect the legitimate rights and interests of you, other users, us or affiliates, and record some links that we believe are risky.

4. Other Uses

You understand and agree that after collecting your personal information, we may de-identify the data through technical means. The de-identified information will not be able to identify you. In this case, we have the right to use the de-identified information to analyze the user database and make commercial use of it without obtaining your consent.

Please note that if we want to use your personal information for other purposes not specified in this policy or collect other personal information not mentioned, we will obtain your consent through page prompts, interactive processes, website announcements or other means. Once you agree, such additional uses will be considered part of this policy, and such additional information will also be subject to this policy.

2. Use of Cookies

To ensure the normal operation of the website, we sometimes store small data files of Cookies on computers or mobile devices. Cookies are plain text files stored on computers or mobile devices by a web server. The content of a cookie can only be retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile application. Cookies usually contain identifiers, site names, and some numbers and characters. With cookies, websites can store data such as user preferences. By using Cookie technology, we can provide you with more thoughtful and personalized services and allow you to set your specific service options.

The purpose of enabling Cookies is the same as that of most websites or Internet service providers, that is, to improve user experience. Other third parties will set Cookies on our website, such as Google and Baidu. They use Cookies to receive IP addresses, information related to your browser configuration and access information, but do not collect your personal identity information. They use Cookies to understand your interaction with the website. You can visit their websites to learn how these third parties use Cookies.

You can manage or delete Cookies according to your preferences. For more information, please see AboutCookies.org. You can clear all Cookies saved on your computer, and most web browsers have the function of blocking Cookies. But if you do this, you need to change the user settings yourself every time you visit our website.

III. Sharing, transfer or disclosure of personal information

(I) Sharing

We will not share your personal information with any third party other than Innovation, except in the following circumstances:

1. Obtain your explicit consent or authorization in advance;

2. We may share your personal information externally in accordance with laws and regulations, or in accordance with mandatory requirements of government authorities or judicial decisions;

3. Share your information with partners to realize the functions of our products and/or services and allow you to use the services you need normally, for example: Innovation Internet Service Platform has access to a wealth of third-party services. When you choose to use the third-party service, you authorize us to provide the information to the third-party service platform or service provider so that it can provide you with services based on the relevant information;

4. Necessary sharing with related parties. In order to facilitate us to provide you with consistent services based on a unified account system and to facilitate your unified management, personalized recommendations, and system and account security, your personal information may be shared between us and our affiliates as necessary;

5. To achieve the purpose of "Acquisition and Use of Personal Information" in Article 1 of this Policy;

6. To perform our obligations and exercise our rights in this Policy or other agreements we have reached with you;

7. To the extent permitted by laws and regulations, in order to comply with the law, protect the interests, property or safety of us and our affiliates or partners, you or other users or the public from damage, such as to prevent illegal activities such as fraud and reduce credit risks, we may exchange information with other companies and organizations. However, this does not include information sold, rented, shared or otherwise disclosed for profit in violation of the commitments made in this Policy;

8. Provided in accordance with the individual service agreement signed with you (including the online electronic agreement and the corresponding platform rules) or other legal documents;

We will only share your personal information for legal, legitimate, necessary, specific and clear purposes. We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, requiring them to handle information in accordance with our instructions, this policy and any other relevant confidentiality and security measures.

(II) Transfer

We will not transfer your personal information to any company, organization or individual other than Innovation, except in the following circumstances:

1. Obtain your explicit authorization or consent in advance;

2. Meet the requirements of laws, regulations, legal procedures or mandatory government requirements or judicial decisions;

3. If we or our affiliates are involved in mergers, divisions, liquidations, acquisitions or sales of assets or businesses, your personal information may be transferred as part of such transactions. We will ensure the confidentiality of such information during the transfer and require the new company or organization holding your personal information to continue to be bound by this privacy policy, otherwise we will require the company or organization to re-ask your authorization and consent.

(III) Public Disclosure

We will only publicly disclose your personal information in the following circumstances:

1. Obtain your explicit consent;

2. Based on laws, regulations, legal procedures, litigation or mandatory requirements of government authorities.

(IV) Exceptions

According to relevant laws and regulations, your authorization and consent are not required for collecting your information in the following circumstances:

1. Directly related to national security and national defense security;

2. Directly related to public security, public health, and major public interests;

3. Directly related to criminal investigation, prosecution, trial, and execution of judgments;

4. For the purpose of safeguarding your or other individuals’ major legitimate rights and interests such as life and property, but it is difficult to obtain their consent;

5. Personal information that you disclose to the public on your own;

6. Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels;

7. Necessary for signing and performing contracts at the request of the subject of personal information;

8. Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and handling product or service failures;

9. Other circumstances stipulated by laws and regulations.

10. According to the law, sharing and transferring personal information that has been de-identified and ensuring that the data recipient cannot restore and re-identify the subject of the personal information does not constitute external sharing, transfer and public disclosure of personal information. The preservation and processing of such data will not require further notification to you and your consent.

IV. Preservation and protection of personal information

(I) Preservation period

We will only retain your personal information during the period necessary for the purposes stated in this policy and within the time limit required by laws and regulations. If you cancel your account or actively delete the above information, we will preserve your information in accordance with the provisions of laws and regulations such as the Cybersecurity Law. After you cancel your account or actively delete the above information, we will no longer use your personal information for commercial purposes, but we may use your personal information after anonymization.

(II) Storage area

Your personal information is stored in the territory of the People's Republic of China. If some products or services involve cross-border, we need to transfer your personal information abroad. We will strictly comply with the provisions of laws and regulations and ensure the security of your personal information.

(III) Security measures

1. We will collect, use, store and transmit user information in accordance with the industry's mature security standards and specifications, and inform you of the purpose and scope of use of relevant information through the user agreement and privacy policy.

2. We attach great importance to information security and will adopt reasonable and feasible security measures and technical means that meet industry standards to store and protect your personal information to prevent your information from being lost, unauthorized access, public disclosure, use, modification, damage, loss or leakage. We will take all reasonable and feasible measures to protect your personal information. We will use encryption technology to ensure the confidentiality of data; we will use trusted protection mechanisms to prevent data from being maliciously attacked.

3. We will cultivate employees' awareness of data security and train and assess their security capabilities to enhance their awareness of the importance of protecting personal information. We deploy access control mechanisms to authenticate and control the identity of employees who handle personal information, and sign confidentiality agreements with employees and partners who have access to your personal information to clarify job responsibilities and codes of conduct to ensure that only authorized personnel can access personal information. If there is any violation of the confidentiality agreement, relevant responsibilities will be pursued.

4. We remind you that the Internet is not an absolutely safe environment. When you exchange information with other users through e-mail, text messages, etc., you are not sure whether the third-party software is completely encrypted for the transmission of information. Please ensure the security of your personal information. We recommend that you do not send personal information through such means to avoid personal information leakage. Please use a complex password to help us ensure the security of your account and personal information.

(IV) Security incident notification

1. In order to deal with the possible risks of personal information leakage, damage and loss, we have formulated corresponding security systems to clarify the classification and grading standards of security incidents and security vulnerabilities and the corresponding processing procedures. We have also established a special emergency response team for security incidents. In accordance with the requirements of the security incident handling specifications, we have launched security plans for different security incidents, carried out loss prevention, analysis, positioning, formulation of remedial measures, and jointly traced and cracked down with relevant departments.

2. After an information security incident unfortunately occurs, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, your suggestions for self-prevention and risk reduction, and remedial measures for you. We will also promptly inform you of the relevant circumstances of the incident by email, letter, phone, push notification, etc. When it is difficult to inform the information subject one by one, we will take reasonable and effective measures to issue an announcement. At the same time, we will also proactively report the handling of information security incidents in accordance with the requirements of the regulatory authorities.

Please be sure to keep your account, password and other identity elements properly. When you use the innovative Internet network services, we will identify your identity through your account, password and other identity elements. Once you leak the above information, you may suffer losses and it may be disadvantageous to you. If you find that your account, password and/or other identity elements may or have been leaked, please contact us immediately so that we can take appropriate measures in time to avoid or reduce related losses.

V. User 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 to your personal information:

(I) Access,Update and delete

We encourage you to update and modify your personal information to make it more accurate and effective. You can access your personal information through innovative Internet services and complete or request us to modify, supplement and delete it according to the management method of the corresponding information. We will take appropriate technical means or provide contact channels for submitting applications to ensure that you can access, update and correct your personal information or other information provided when using innovative Internet services as much as possible.

When accessing, updating, correcting and deleting the above information, we may ask you to authenticate your identity to ensure information security. If you want to query, modify or delete some of your information, please send an email to web@sanygroup.cn and we will respond to your request within 30 days.

(II) Publicity and sharing

Many of our services allow you to publicly share your relevant information not only with your social network, but also with all users of the service, such as the information you upload or publish when using innovative Internet services, as well as location data and log information related to such information. As long as you do not delete the information you have made public or shared, the relevant information may remain in the public domain; even if you delete the shared information, the relevant information may still be cached, copied or stored independently by other users or third parties not under our control, or saved in the public domain by other users or such third parties. If you make your information public or shared through the above channels, we will not be responsible for the leakage of your information. Therefore, we remind you and ask you to carefully consider whether to make your information public or share it through the above channels.

(III) Change the scope of your authorization

You can choose whether to disclose information. Some information is necessary for innovative Internet services, but the provision of most other information is determined by you. You can change the scope of your authorization for us to continue to collect information or withdraw your authorization by deleting information, turning off device

functions, etc.

After you withdraw your authorization, we will no longer be able to provide you with the services corresponding to the withdrawal of authorization, and will no longer process your corresponding information. However, your decision to withdraw your authorization will not affect the information processing previously carried out based on your authorization.

VI. Personal data of minors

Any minor participating in online activities should obtain the consent of their parents or their legal guardians (hereinafter referred to as "guardians") in advance. We will protect the relevant information of minors in accordance with the provisions of relevant national laws and regulations. If you are a minor, please inform your parents or guardians to read this policy and seek the consent and guidance of your parents or guardians before you submit personal information.

VII. Third-party service providers and their services

To improve your service experience, you may receive content or web links from third parties outside of Innovation. We have no control over such third parties. You can choose whether to access or use the links, content, products and services provided by third parties. We cannot control the privacy and data protection policies of third parties, and such third parties are not subject to this statement. Before submitting personal data to a third party, please refer to the privacy protection policy of the third party.

VIII. Policy Updates

We may update or modify this policy from time to time based on changes in our services or data processing. If updated, we will post the latest version of the privacy statement on the Innovation website, and it will take effect immediately upon publication. It is recommended that you check this statement regularly to understand any changes. If we make any major changes to this statement (changes in the scope of personal data collected and the purpose of use), we will notify you through appropriate channels and obtain your consent.

IX. Contact Us

If you want to contact us, please contact us through the following methods:

Contact: zqb@innovationmetal.com

Last updated: January 2025