Xiaoya Privacy Statement                

Shandong Xiaoya Holding Group Co., Ltd., and its affiliates (hereinafter referred to as "XIAOYA Group", "We" and "our") understand the importance of your private information and will respect your privacy. Please carefully read this Privacy Statement (" This Statement ") before submitting your personal data to XIAOYA Group. This statement applies to display this privacy statement, or link to this privacy statement the XIAOYA group sites and products, equipment or application (collectively referred to as our "services"), including but not limited to the XIAOYA group website (http://www.xiaoyagroup.com.cn/) service. All text, pictures, user interfaces, visual interfaces, photographs, trademarks, logos, sounds, music, works of art and computer code (collectively "Content") contained in the Services provided by XIAOYA Group, including but not limited to the design, structure, selection, collocation, expression, appearance, style and arrangement of such content, are owned, controlled or licensed by XIAOYA Group. Or it is licensed to XIAOYA Group and is protected under the Trade Appearance, copyright, patent and Trademark laws and various other intellectual property and anti-unfair competition laws.

This statement sets out how XIAOYA Group will handle your data (whether personal or not), but may not cover all possible data processing scenarios. XIAOYA Group may explain to you the purpose, scope and use of the information related to the collection of specific data of products or services in the

supplementary statement or in the notice provided at the time of data collection, and provide you with a method of your own choice and consent, and collect and use after obtaining your express consent.

XIAOYA Group reserves the right to change, modify, add or delete portions of this Privacy Statement at any time, at its discretion. You may periodically review this Privacy Statement to see if changes have been made. In the course of reading this Statement, if you do not agree with this Statement or any content thereof, you should immediately stop using the relevant services provided by XIAOYA Group. If you use the services provided by XIAOYA Group, you endorse the entire content of this Statement. [1]

We have prepared this statement to help you understand the following:

1. How does XIAOYA Group collect and use your personal data

2. How does XIAOYA Group use Cookie and similar technologies

3, XIAOYA Group how to disclose your personal data

4. How to access or modify your personal Data

5. Protection of minors' personal information

6. How does XIAOYA Group retain and protect your personal data

7. Third-party providers and their Services

8. How to update this Statement

I.How does XIAOYA Group collect and use your personal data

Personal data refers to information that, when used alone or in combination with other information, can identify an individual. Such data will be submitted to us directly by you when you use our website, products or services and interact with us, such as:

1. Information filled in and submitted when you register as a member and use the relevant services provided by XIAOYA Group official website or other platforms, such as your name, gender, birth date, ID number, telephone number, email, address, picture, nickname, location and other relevant information.

2. When you select purchase, delivery and installation services, we may ask for your name, contact information, shipping and billing addresses, and bank card information to process your order.

3. When you download or use client software, XIAOYA Group may read information related to your device, including but not limited to hardware model, IMEI number and other unique device identifiers, MAC address, IP address, operating system version, and Settings of the device used to access the services.

4. When you use the official website of XIAOYA Group and third-party platforms outside its partners (hereinafter referred to as the "third party"), XIAOYA Group may, without prior notice, read your usage information, including but not limited to device model, device operating status, device function usage frequency, device log information, device upload measurement data or other usage information. Some devices may have built-in cameras that take pictures of how the device is being used, etc.

5. When you use the services of XIAOYA Group or the website of XIAOYA Group, XIAOYA Group automatically receives and records the information on your browser and computer, including but not limited to your IP address, the type of browser, the language used, the date and time of access, software and hardware characteristics information and the web page records you require. [2]

6. Location Information (for specific services/functions only) : When you download or use client software or access web pages, or use certain XIAOYA Group services and devices, XIAOYA Group may read various information related to your location, such as the device's GPS signal access point and cell tower information, country code, city code, mobile network code, cell ID, latitude and longitude information and language Settings. This information may be sent to us when you use certain services.

Where permitted by law, we also obtain relevant data from public and commercial third party sources, such as purchasing statistical data from other companies, obtaining order data from third party e-commerce platforms to support our services, The information you send us when you participate in the survey, the information we collect when you participate in the user experience program, and the information we collect when you interact with us and your partners at XIAOYA Group. The data we collect depends on how you interact with XIAOYA Group, including the websites you visit or the products and services you use, such as name, gender, business name, job title, address, email, phone number, login information (account number and password), photo, ID information, etc. In some cases, you may choose not to provide personal data to XIAOYA Group, but if you choose not to provide personal data, XIAOYA Group may not be able to provide you with relevant products or services or respond to or resolve the issues you encounter.

We may use your personal data for the following purposes:

1. Create an account. Use the personal information collected when creating an account through a website or mobile device to create a user's personal account and profile page.

2. Fulfill your transaction or service request, e.g., fulfill the order, information related to e-commerce orders can be used to process purchase orders and related after-sales services, including customer support and reshipments.

Recipient information, including name, address, phone number, and zip code will be used for delivery. The email address is used to send package tracking information to the user. The list of items purchased is used to print invoices and allows the customer to determine the items in the package. When you use the customer service phone number of XIAOYA Group, wechat official account and other service platforms to request XIAOYA Group to provide you with product installation, maintenance and consulting services, you are required to provide us with your name, address, contact information, products to be installed or maintained and other information according to your different demands, so that XIAOYA Group can provide you with the required services in a timely manner.

3. Activate or verify products or services, control and use equipment. To control some of your devices, you need to use APP to log in to the account, and complete the network distribution and binding process of the devices normally. After completing these procedures, you can control the device remotely or within the LAN through the APP. Some devices must be activated before they can be used. The activation process requires device information, including the MAC address and machine code. If activation fails, we may read related device information and log information to evaluate the cause of the activation failure. At the same time, you may need to use information such as username/password to control your networked device.

4. Provide location-based services. When using certain services, we or third party service providers may use location information to provide you with the correct version of the service and provide the exact location so as to enable you to obtain the best user experience possible. For example, by reading your location to know the nearest warehouse and estimating the delivery time, Or use different procedures at different altitudes and regions to ensure the normal realization of equipment functions.

5. Send you important notifications, such as notifications of operating system or application updates and installations.

6. Allow you to use third-party functions. Some of the functions in our products are operated by third party service providers. Therefore, we need to share your information with the third party so that you can experience the full function.

7. Collect user feedback. Your feedback can help improve our services, equipment features, etc. In order to track the feedback you choose to provide, you may be contacted using the personal information you have provided and records retained.

8. Conduct internal audits, data analysis and research to improve our products and services.

9. Analyze business operational efficiency and measure market share.

10. Synchronize, share, and store the data you upload or download and the data needed to perform the uploads and downloads.

11. Comply with and enforce applicable legal requirements, relevant industry standards or our agreements.

XIAOYA may also collect and use non-identifying data. Non-identifiable data is data that cannot be used to determine the identity of an individual. XIAOYA, for example, collects aggregated statistics, such as website visits and how often device features are used. XIAOYA Group collects this data in order to understand how users are using their sites, products and services. By doing so, XIAOYA Group can improve its service and better meet customer needs. XIAOYA Group may, in its sole discretion, collect, use, process, transfer or disclose non-identifying data for other purposes. We do our best to separate your personal data from non-identifiable data and use both separately. If personal data is mixed with non-identifiable data, it will still be treated as personal data.

When XIAOYA Group processes your personal data, we will comply with applicable legal requirements and do so on an appropriate legal basis, including:

1. Processing your personal data for the performance of the Contract when responding to your transaction or service request;

2. Processing your personal data based on your consent;

3. When contacting you, conducting marketing or market research, processing your personal data for the purpose of improving our products and services, implementing and improving our loss prevention and anti-fraud programs, we will do so on the basis of our legitimate interests or those of third parties.

4. We may also process your personal data based on compliance and enforcement of legal obligations.

II. How does XIAOYA Group use Cookie and similar technologies

1.Cookie (Whether products and apps are involved)

To keep our websites functioning, we sometimes store small data files called cookies on our computers or mobile devices. A Cookie is a

plain text file that a web server stores on a computer or mobile device. The contents 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 typically contain an identifier, a site name, and some numbers and characters. With cookies, websites can store data such as user preferences or items in their shopping basket.

XIAOYA started cookies for the same reason that most websites or Internet service providers started cookies: to improve the user experience. With cookies, a website can remember a single visit by a user (using a session Cookie) or multiple visits (using a permanent Cookie). With cookies, websites can save Settings, such as the language, font size and other browsing preferences of a computer or mobile device. This means that users do not need to reconfigure user preferences on each visit.

2. Website beacons and pixel tags (whether products and apps are involved)

We use site beacons and pixel tags and other similar technologies on our website. For example, an E-mail sent to you by the XIAOYA Group might contain a click URL that links to content on the XIAOYA Group website. If you click on the link, XIAOYA Group tracks the click to help us understand your product and service preferences and improve customer service. If you do not want your activities to be tracked in this way, you can unsubscribe from the XIAOYA Group mailing list at any time.

3. Mobile Analytics Software (reserved)

Within the APP, we use mobile analytics software to better understand what our APP does on your phone. The software may record information such as how often you use the application, events that occur within the application, cumulative usage, performance data, and where the application crashes occur.

4. Third-party SDKS list

We will carry out strict security checks on SDK and other similar applications, and require partners to take strict measures to protect your personal data. When meeting new service requirements and business function changes, we may adjust the third-party SDKS we access, and disclose the latest situation of accessing third-party SDKS to you in a timely manner in this note. Note that the data types

of third-party SDKS may change due to version upgrade or policy adjustment. Please refer to the official instructions published by the third-party SDKS. Currently, the third-party SDKS that this application accesses are as follows:

Huawei Device Management Service SDK

Purpose of collecting personal information: Complete the end cloud authorization verification with Huawei Cloud to ensure that your products always meet the requirements of the HarmonyOS Connect certification

Type of personal data collected: device hardware identifier, device hardware parameter, system version information related to the device

Statement on Huawei equipment management service and privacy.

III. How does XIAOYA Group disclose and share your personal data

Your personal information will be kept strictly confidential and will only be shared with data recipients in the categories listed below. In addition, we will only share your information with third parties other than those listed below with your consent, and you will have the option to allow us to share your information or not.

1.. Empower partners. We may share your information with trusted authorized partners. We may share your account information, device information and location information with authorized partners to ensure the smooth completion of services provided for you. However, we will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and only share personal information necessary for the provision of services. Our partners have no right to use shared personal information for any other purpose. Currently, our licensing partners include the following types:

Authorized partner for advertising and analytics services.Resellers, suppliers, service providers and other partners. Our distributors, suppliers and service providers include institutions providing technical services, telecommunication services, customer services, risk control services, audit services, legal services, financial institutions, e-commerce companies and platforms, offline stores, etc.

We will sign confidentiality agreements with companies, organizations and individuals with whom we share personal information and will require them, in an appropriate manner, to handle personal information in accordance with our Agreement, this Privacy Agreement and any other relevant confidentiality and security measures. For the use of sensitive personal data, we require third parties to adopt encryption technology to better protect user data. If it is found to be in violation of the agreement, effective measures will be taken and even the cooperation will be terminated.

To comply with the mandatory requirements of laws and regulations, court orders or requirements of competent government authorities, to maintain the public interest, or to protect the personal and property safety or legitimate rights and interests of our customers, XIAOYA Group or XIAOYA Group employees.

Other parties with your consent separately. In addition to the sharing situations described in this Privacy Agreement, we may also share your information with third parties when you agree to share it or request to share it.

2. Information that does not require consent

We may share anonymous information with third parties in aggregate form for commercial purposes; We may share with them general usage trends of our services, such as the number of customers among specific groups of people who purchase certain products or engage in certain transactions.

According to relevant laws and regulations, we may share, transfer and publicly disclose your personal information without your authorization and consent under the following circumstances:

Those related to state security or national defense security;

Those related to public security, public health or major public interests;

Those related to the investigation, prosecution, trial and execution of judgments of crimes;

In order to protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to get the consent of the person;

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

Personal information collected from legally publicly disclosed information, such as legitimate news reports, government information disclosure, etc.

It is necessary to maintain the safe and stable operation of the provided products or services, for example, to find and troubleshoot faults.

Other circumstances stipulated by laws and regulations.

According to the law, the sharing and transfer of de-identified personal information and ensuring that the data receiver cannot recover and re-identify the subject of personal information does not constitute the sharing, transfer and public disclosure of personal information, and the preservation and processing of such data will not require further notice to you and your consent.

If you do not agree that we provide your personal information to third parties in accordance with the above terms, please immediately stop using our services.

IV. How to access or modify your personal Data

You should ensure that all personal data submitted is accurate. XIAOYA Group will do its best to maintain the accuracy and integrity of personal data, and update these data in a timely manner. Where required by applicable law, you may:

1. The right to access your specific personal data held by us;

2. Request us to update or correct your inaccurate personal data;

3. Refuse or restrict our use of your personal data;

4. Ask us to delete your personal data or actively cancel your account.

If you would like to exercise your rights, please contact us online at yanchengkai@xiaoyagroup.com.cn. For security purposes, we may ask you to verify your identity (for example, to provide a written request or otherwise) before processing your request. We will refuse to process requests if we have reasonable grounds to believe that they are deceptive, unenforceable, or infringe upon the privacy of others.

After you or we assist you in deleting the information, we may not be able to immediately remove the information from the backup system due to applicable legal and security technical restrictions. We will securely store your personal information and limit any further processing of it until the backup can be erased or anonymized.

Before deleting your personal data or account cancellation, please back up and properly keep your account information and other relevant data, and keep the transaction vouchers, bills and other information of products and services in order to avoid being unable to enjoy relevant after-sales services or having to pay extra fees. After you delete your personal data or cancel your account, you may not be able to continue to use our services, and you will not be able to retrieve any content or information in or related to your account.

You also have the right to revoke your consent at any time, as required by applicable law, when XIAOYA Group processes your personal data based on your consent. However, the revocation of consent will not affect the validity and validity of the processing of your personal data by us based on your consent prior to revocation, nor will it affect the processing of your personal data by us based on other appropriate justification basis.

V. Protection of minors' personal information

XIAOYA Group provides products and services mainly for adults. If you are a minor under the age of 14, you should read these Guidelines with your guardian before using our products and/or services, and you should ensure that you have obtained the consent of your guardian to use our services and provide us with your information. We will focus on protecting minors' personal information in accordance with relevant national laws and regulations.

If your guardian does not approve of your use of our Services or provide us with information in accordance with these Guidelines, please immediately terminate your use of our Services and notify us in a timely manner.

In cases where personal information of minors is collected with the consent of parents or legal guardians, we will only use or publicly disclose this information if it is permitted by law, with the express consent of parents or guardians or if it is necessary to protect minors.

If you are the guardian of a minor, please contact us in a timely manner if you have any questions regarding the use of our services by a minor under your custody or the user information provided to us by such minor. We will protect the confidentiality and security of juvenile user information in accordance with relevant national laws and regulations and the provisions of this Guideline. If we find that we have collected personal information about minors without prior verifiable parental or legal guardian consent, we will seek to delete the data as soon as possible.

VI. How does XIAOYA Group retain and protect your personal data

In principle, personal information collected and generated by us within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. In principle, personal information collected and generated by us within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China.

XIAOYA Group values the security of personal data. We will retain your personal data for the period necessary for the purposes set forth in this Statement, unless required or permitted by law to extend the retention period. Depending on different scenarios and products and services, the duration of data storage may vary.

XIAOYA Group shall not be liable for security lapses caused by third parties accessing your personal information due to your failure to maintain the privacy of your personal information. Notwithstanding the above, you should notify us immediately of any unauthorized use of your account by any other user of the Internet or any other security breach. Your assistance will help us to protect the privacy of your personal information.

VII. Third-party providers and their Services

To ensure a smooth browsing experience, you may receive content or web links from third parties (" third parties ") outside of XIAOYA Group and its partners. XIAOYA Group has no control over such third

parties. You can choose whether to access links, content, products, and services provided by third parties.

XIAOYA Group has no control over the privacy and data protection statements of third parties and such third parties are not bound by this Statement. Before submitting personal information to third parties, please refer to these third parties' privacy protection statements.

Viii. How to update this Statement

In order to provide you with better service and better user experience, this Statement is subject to change based on business adjustment, laws, regulations or policy changes. If you continue to use any of our services or visit our websites after the adjustment or change of the Privacy policy, we believe that this represents that you have fully read, understood and accepted the revised Privacy Agreement and are bound by it.

When we want to use the information for other purposes not specified in this statement, we will seek your consent again in the form of signing agreements, pop-up prompts, announcements on the site, updating this Statement, etc.

Updated effective date: April 1, 2022