Updated and effective on November 23rd, 2024

Rendora Privacy Policy

Thank you for choosing Rendora 3D Virtual Human Video AIGC Platform software and services.

Rendora LLC. (“we”, “us” or “our”) is the provider of Rendora 3D Virtual Human Video AIGC Platform software and services, and attaches great importance to and is committed to the protection of your privacy and Personal Information (as defined below). We have formulated the Rendora Privacy Policy (“Policy”) to explain to you how we collect, use, store, share, transfer, disclose and protect your Personal Information during your use of our products and/or services and how you may access, update, delete and protect such information. This Policy applies to the official website, products and/or services of Rendora 3D Virtual Human Video AIGC Platform software (“Software”).

[Special Reminder] Prior to your use of the official website, products and/or services of the Software, please read carefully and make sure you fully understand and agree to this Policy, especially the clauses in capital letters. You may make any choice you deem appropriate following the guidance in this Policy. By agreeing to this Policy, you acknowledge that you have agreed to our processing of your information in accordance with this Policy. We have used our commercially reasonable efforts to present this Policy that is as clear and easily understandable as possible so that that it can truthfully communicate the information that we want to communicate to you. We expect you to have a clear understanding of the purposes for which the information provided by you to us (which may include your Personal Information or Sensitive Personal Information) is collected, how it may be used and other related information before you provide such information to us and allow us to process and share the same. If you are under the age of 18 (eighteen), please read this Policy together with your legal guardian and pay particular attention to the provisions regarding use by minors. Should you have any question, please feel free to contact us.

Please note that this Policy applies only to the official website, products and/or services of the Software, and not to any products and/or services provided by any third party to you, which shall be governed by their service terms and privacy policy as otherwise communicated to you (rather than this Policy). Please properly keep your Personal Information and provide it to third parties only when necessary.

Roles hereunder are as follows:

Customer means a legal entity that authorizes a natural person to register a Software account and exercise the administrative authority. A Customer may also invite or authorize individuals to use the Software and services hereunder as its Authorized Users.

Authorized User means a natural person who is authorized or invited by a Customer to use the Software and services hereunder or certain function modules of the Software, including but not limited to the Customer’s staff, employees, outsourced personnel and partners. The Authorized User designated by a Customer to configure and use the Software and services hereunder and to exercise back office administrative authority on behalf of the Customer is referred to as the “Administrator”.

Individual User means a natural person who registers his/her own account to access the Software and the services for his/her own use and exercises full authority in respect of such account (including but not limited to administer and use such account).

In this Policy, “you” may be an Authorized User or Individual User.

This Policy will help you understand the following:

1. What information we collect and how we use your information

2. How we collect your information

3. How we share, transfer or disclose your Personal Information

4. How we protect your Personal Information

5. Your rights

6. How we process Personal Information of minors

7. How we update this Policy

8. Disclaimer

9. How to contact us

1. What information we collect and how we use your information

1.1 Information We May Collect

In providing our products and services, we often receive sensitive information from and about our Customers, which may include Personal Information and Non-personal Information.

“Personal Information” means information of any kind that relates to an identified or identifiable individual, whether recorded electronically or otherwise, excluding anonymized information. The categories of Personal Information we may collect are as follows:

• Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name and password, telephone number.

• Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Biometric information. Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, faceprints, and voiceprints.

• Usage Data. Personal information that is included in the content and communications (including audio, video, photos, images, text) you provide to generate videos and other forms of output you input, upload, receive and create on our Software.

• Internet or other similar network activity. Browsing history, search history, download history, IP address, website crashes, system operations, URL information and information on a consumer's interaction with a website, application, or advertisement.

• Geolocation data. Physical location or movements.

• Inferences drawn from other Personal Information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

“Sensitive Personal Information” shall have the meaning ascribed to it under the applicable law and is presently defined to mean such Personal Information which consists of information relating to

state identification card, or passport number;

account log-in in combination with any required security or access code, password, or credentials allowing access to an account;

financial information such as bank accounts or credit card or debit card or other payment instrument details;

biometric information; and

the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.

“Non-personal Information” means any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual. For example, data regarding the number of times a particular link on a website is selected or regarding the number of visitors to a website are examples of Non-personal Information.

1.2. When you use the Software and/or services, we will collect the Personal Information or Non-personal Information that is provided or authorized to be provided by you when you register for, log in to or use the Software and services hereunder and that is generated during your use of the Software and services hereunder for such purposes and in such manners as set forth below, so as to provide you with the Software and services hereunder and maintain the normal and safe operation and optimize the function experience thereof. If we intend to use your Personal Information or Non-personal Information for any purpose other than those set forth herein or those for which it is collected, or collect any of your Personal Information or Non-personal Information beyond the scope set forth herein, we will notify you in a reasonable manner and obtain your separate consent before such use or collection. We will cease any use of and delete the above information when you close your account. Please note that if any personal information of another individual is provided by you, you shall make sure that you have obtained the consent of the personal information subject or that such information is from legal and proper sources. If we find that you have uploaded the Personal Information or Non-personal Information of a third party in violation of the law, we will take measures including but not limited to terminating the provision of services to you, deleting such information and freezing your user account.

1.3. Information that must be collected for provision of the core basic functions of the Software

Please understand that, in order for us to provide you with the Software and services hereunder and guarantee the normal operation of the Software, we need to collect, store and use the following Personal Information or Non-personal Information concerning you to make available the following functions to you. If you do not provide such information to us, you will not be able to use our products and services. Please note that if any Personal Information of third party is provided by you, you shall make sure that you have obtained the consent of such third party or that such information is from legal and proper sources.

1.3.1 Account registration, login and verification

To facilitate your account creation and use of our services as a registered user, we offer a variety of registration methods for you to choose from:

(1) If you choose to register with your email or mobile number, you are required to provide us with information such as e-mail account, the mobile number that you intend to use for the registration and the network operator, which will be used by us for sending an verification code to verify your identity information.

(2) If you choose to register and log in with your account with a third party (such as your Google account), we will collect the information under such third party account that you expressly authorize to be shared (including but not limited to your avatar, nickname, region and gender) from the third party, and will link such third party account to your account with us for the Software after you agree to this Policy. We collect from the third party your Personal Information which you authorize to be shared so as to remember your login status as Software user and to provide you with better products and/or services. If you refuse to provide the information under the third party account, you will not be able to register and log in with the third party account.

(3) After your registration with us, you may choose to further provide personalized information such as your nickname (including your real name) and avatar (including your real photo) at your sole discretion. Your use of the basic functions of the Software and services hereunder will not be affected if you do not provide such personalized information.

1.3.2 Virtual human video production

You understand and agree that when you use the Software to produce video works, we will collect your video production information, including but not limited to the texts and demands input and the pictures, PPTs, and audio and video materials uploaded by you into the Software, for the synthesis of your virtual human video works. Such information is necessary for video synthesis and production, and you will not be able to use the video production function of the Software if you do not provide it.

Please be aware that such texts, pictures, PPTs and audio and video materials may contain your or others’ Personal Information. We will take commercially reasonable measures to protect such information and will not provide the same to any third party without your consent. If you do not want your or others’ Personal Information to be collected, please refrain from inputting or uploading into the Software any texts or materials containing Personal Information.

1.3.3 Software Service improvement and optimization

You understand and agree that, in order for us to enhance your user experience and to improve the relevant functions of our products and/or services, we will collect your video production information (which may contain Personal Information), your Software usage records (including browsing, click and download history), and relevant web logs (including website crashes, system operations, IP address and URL information) for service optimization through data analysis and model training.

We undertake that the above information will not be collected for the purpose of identifying you personally, and that we will use commercially reasonable efforts to encrypt and protect such information in accordance with this Policy, and, in the case of Personal Information that is not necessary, may de-identify or otherwise desensitize such Personal Information. Meanwhile, you may withdraw your consent to our collection of such Personal Information at any time.

1.3.4 Security functions

In order to improve security of your use of our products and services, protect you or other users from personal and property damages, better prevent phishing website, fraud, network vulnerability, computer virus and other security risks, and identify more accurately violations of laws and regulations, we may collect, use or combine your account information, transaction information and device information, so as to comprehensively assess the risks of your account and in your transactions, carry out identity verification, monitor and prevent security incidents and take necessary recording, audit, analysis and handling measures in accordance with laws.

1.4 Information that may be collected for provision of extended functions of the Software

In order to make it easier or more fun for you to use our products and/or services, thus enhancing your experience, the Software can also make available to you the following extended functions, and we may collect and use your Personal Information for such functions as detailed below. If you do not provide such Personal Information, you may still be able to use the core functions of our products and/or services, but you may be unable to use the relevant extended functions.

1.4.1 Personalized push notification

In order to present and recommend to you information that is more relevant and provide services that better meet your requirements, we will collect and use your Personal Information such as account information and Software usage records for automatic calculation and prediction of your preferences through computer algorithmic models, so as to recommend products or services that may interest you. Please note that personalized recommendation algorithms will not identify you personally, and will only provide information that is more relevant and extensive based on your behaviors and characteristics. You may opt out of personalized push notification in the Software at any time, and once you do so, we will no longer process your Personal Information for such purpose.

1.4.2 Value-added services for the Software

You acknowledge and agree that if you use the value-added services (such as paid services and licensing subject authentication) for the Software, you may be required to provide us with your real name, ID card number, phone number, email address, mailing address and other information for us to comply with the requirements of relevant laws and regulations on real-name authentication. When purchasing any value-added function service for the Software, you may choose to make payment by:

Card Payments;

E-Wallet,such as Google Pay, PayPal, Alipay,WeChat Pay,or;

code scanning payment service of a third-party payment processor in cooperation with us.

We or the relevant third-party payment processor may collect your sensitive Personal Information including your order information, ID card number, account opening bank, account number and transaction sequence number in order to complete the payment and purchase process.The above information is necessary for making payment, and will be stored by us in the server securely and in encrypted form. If you do not agree to provide the above information, you will not be able to purchase or use the relevant value-added service, but your use of other services provided by us will not be affected.

1.4.3 Access to third-party applications

If you need to access a third-party application when using our products and/or services, we may collect from the developer and technical service provider of such third-party application your Personal Information necessary for us to provide technical support for such access, including device information and operation logs. If your sensitive Personal Information is involved, we will obtain your separate consent. If you refuse our collection of such Personal Information, all or part of the functions of the third-party application may be unavailable to you, but your use of other functions of the platform will not be affected. The developer and technical service provider of such third-party application may directly collect and use your Personal Information pursuant to their own privacy policies, but your Personal Information will not be accessed by us. You are advised to read and understand such privacy policies before receiving relevant services and providing your Personal Information.

1.4.4 Customer service and contact us

If you contact our customer service or click to get a service plan and other functions to communicate with us, we may request you to provide necessary Personal Information (including but not limited to name, cell phone number, e-mail address, company information, etc.) for identity verification and contact with you. Meanwhile, in order to provide services in response to your request, our customer service personnel may inquire or verify your relevant information within the scope of your authorization to keep your account secure. We will take technical and administrative measures as far as possible to protect your information, and will only use such information to the extent necessary. We may retain your name, mobile number, email address or other contact information, the company and career information provided by you, records and contents of communication between you and us and other necessary information in order to provide you with customer service.

1.5 Rules for use of your Personal Information

1.5.1 Overall, we use the Personal Information and Non-personal Information we collect from you to better provide you with our services. Additionally, we may use your Personal Information and Non-personal Information to further our business purposes. This may involve us using your Personal Information or Non-personal Information to increase the efficiency of our products and/or services and learn from past transactions; to increase the efficiency and interface of our website and Software; to enable you to create an online account on our website; to ensure that you receive the services, products, or newsletter, of other information you desired from us; to inform you of promotional events or happenings that may be of interest to you; to inform you of promotional offers, packages, or sales we are offering; to further develop and innovate our products and services; to personalize your experience on the website or Software and to improve the security, design, and functionality of our website or Software; to analyze product acceptance and your browsing behavior;to perform the services that you has requested; to provide updates to you about any changes to our policies, terms and conditions and any other matters which we may need to tell you; to combat fraudulent activities involving our services or products; and to survey customers regarding our services, products, and website, in addition to other uses. We may also disclose your Personal Information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request; (ii) to enforce or apply our terms of use and other agreements, including for billing and collection purpose; or (iii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. We may provide you with more specific notices for some of the processing described above and, if we require your consent, we will ask for it at the time we collect your Personal Information.

We may create aggregated, de-identified or anonymized data from the Personal Information we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the products and services and promote our business. We may also share de-identified information with public interest organizations, health care organizations and researchers. We will not share such data in a manner that could identify you and will prohibit these third parties from attempting to re-identify any such data.

1.5.2 After collecting your Personal Information, we will import it into our back-end database by technical means. We are entitled to analyze and exploit our customer database solely for purposes necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.

1.5.3 Please note that we are authorized to use all Personal Information you provide during your use of our products and/or services as long as you still use them, unless and until you delete such information or refuse our collection by means of your Software setup. We will cease any use of and delete or anonymize your Personal Information when you close your account.

1.5.4 Please be aware that we may adjust and change the functions of the Software and our services in light of our business development. In principle, when new functions or services are relevant to our existing functions or services, the Personal Information collected and used will be directly or reasonably related to the original purpose of processing; otherwise, we will inform you of the new purpose of collecting and using your Personal Information and obtain your separate consent in accordance with the requirements of laws, regulations and national standards by way of page prompts, interactive procedures, agreements and other reasonable methods.

1.6 Exceptions to the requirement of authorization and consent

You are fully aware that, pursuant to the relevant laws and regulations, we may collect your Personal Information without your authorization or consent if:

1.6.1 it is related to our performance of obligations under laws and regulations;

1.6.2 it is directly related to national security or national defense security;

1.6.3 it is directly related to public security, public health or major public interests;

1.6.4 it is directly related to criminal investigation, prosecution, trial or enforcement;

1.6.5 it is for the purpose of protecting your or other individual’s life, property and other major lawful rights and interests, where it is difficult to obtain your prior consent;

1.6.6 the Personal Information collected has been disclosed voluntarily by you to the public;

1.6.7 it is necessary for the execution and performance of contract upon your request;

1.6.8 the Personal Information is collected from information disclosed through lawful public channels, such as lawful news reports or information disclosure by government;

1.6.9 it is necessary for maintaining the safe and stable operation of our products and/or services, such as for identifying and handling defects in and failure of such products and/or services;

1.6.10 it is necessary for lawful news reports;

1.6.11 it is necessary for academic and research institutions to carry out statistical or academic research for public interests, provided that the Personal Information contained in the academic research results or descriptive results is de-identified when such results are made publicly available; or

1.6.12 any other circumstance provided by laws and regulations occurs.

If we cease our operation of the products or services in connection with the Software, we will promptly stop collecting your personal/corporate information and send you a notice thereof on a personal basis or in the form of announcement.

1.7 Circumstances under which we collect your Personal Information from third parties

We may collect from third parties your Personal Information that is authorized by you to be shared. In such case, we will use such Personal Information in accordance with our agreement with the relevant third party and in compliance with the relevant laws and regulations after confirming the legality of the sources of such information.

1.8 Scenario where the Customer is the Personal Information processor

1.8.1 If you are an Authorized User, in addition to the information we collect through the Software and the information submitted by you, the Customer may provide us with your Personal Information necessary for us to implement the functions of the Software and services hereunder, including but not limited to your account name, name, mobile number and work location, in the course of your use of the Software and services hereunder, so as to facilitate your such use. Such information may be updated by the Customer from time to time as appropriate. According to the representations and warranties of the Customer, before providing the above Personal Information to us, the Customer shall have obtained your express prior authorization and fully informed you of the purposes, scope and methods of the collection and use of your Personal Information. If you have any question about the above or would like to claim the relevant rights and interests in connection with your Personal Information, you are advised to immediately stop accessing or using the Software and services hereunder and contact the Customer or the Customer’s Administrator to deal with the same.

1.8.2 With respect to the Personal Information of Authorized Users provided by Customer to us, Customer is responsible for informing the Authorized Users of the purposes, methods and scope of the collection and use of Personal Information and having the Privacy Policy available to the Authorized Users, and each of the Authorized Users has read, understood and agreed to accept all provisions of the Privacy Policy then in force.

2. How we collect your information

2.1 Information you provide directly

We may collect information that you provide directly, such as when you access our website, establish a user account with us, register products, or otherwise give us your name, email address, etc. You may also choose to submit Personal Information to us via other methods, e.g., in response to marketing or other communications; through social media or online forums; through participation in an offer, program or promotion; in connection with an actual or potential business relationship with us; or by giving us your business card or contact details at tradeshows or other events. We may also keep a record of your communication with us to better support you in the future.

2.2 Information we collect automatically

We may automatically collect information about how you use and engage with our business (e.g., via our websites and/or applications), and/or services over time and some of this may be personal data. In addition, we may use cookies and other technologies(e.g., Sensors SDKs) to function effectively. We will store cookies, flash cookies or other local storage provided by your browser or associated applications which usually contains identifiers, site names and certain numbers and characters (collectively, “cookies”) in your computer or mobile device. Cookies will enable our website to store your preference or data. We will not use cookies for any purpose other than those set forth herein. You may manage or delete cookies as you prefer. Please refer to AboutCookies.org for details. You may clear all cookies stored in your computer. Most web browsers will automatically accept cookies, but you may alter the settings of your browser to reject cookies based on your needs. In addition, you may also clear all existing cookies, but if you do so, you will need to change your user settings each time you visit the Software website, and all of your corresponding information previously recorded will be deleted.

2.2.1 Cookies and anonymous identifiers. Cookies are a mechanism for the server side (or script) to store and retrieve data on the client side. When you use our Software or services, we will send one or more cookies or anonymous identifiers to your device. When you interact with the Software, we allow cookies or anonymous identifiers to be sent to the servers of the Software. Cookies usually contain identifiers, site name and certain numbers and characters. Cookies enable us to learn about your habits, remember your preferences, save you from repeated information input, provide you with customized services catering to your demands, or help assess your account security. They also help us obtain our traffic statistics and analyze the effectiveness of our webpage designs and advertisements.

2.2.2 We will not use cookies for any purpose other than those set forth herein. You shall have the right to accept or reject cookies at your option. You may change your browser settings to reject cookies, but such rejection may render you unable to log in to or use the web services or functions of the Software that rely on cookies. You may manage or delete cookies as you prefer. You may clear all cookies stored on your computer as most web browsers have the function of blocking cookies. If you do so, you will need to change your user settings each time you visit our website, and such change may render you unable to log in to or use the services or functions provided by the Software that rely on cookies, but your use of other services or functions of the Software will not be affected.

How we share, transfer or disclose your Personal Information

3.1We will NEVER sell Your Personal Data to Third Parties.

3.2 To provide you with better customer services and user experience, we use a select number of trusted external service providers for certain technical data analysis, processing and/or storage offerings (e.g., IT, data analysis, payment and related services). These Third Party service providers are carefully selected and meet high data protection and security standards. We only share data with them that is required for the services offered and We contractually bind them to keep any information We share with them as confidential and to process Personal Data only according to Our instructions.We will impose strict requirements and responsibilities on these Third Party service providers for information protection.

3.3 Entrusted processing

3.1.1 If we entrust a third party to process your Personal Information, we will agree with such third party on purposes, period and methods of and protection measures for such processing, types of Personal Information to be processed, and rights and obligations of the parties, and will supervise the Personal Information processing by the entrusted party.

3.4 Sharing

3.4.1We use Hotjar in order to better understand our users’ needs and behaviour on our Site of Software and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback.

When you browse our website of Software, Hotjar will collect data about your interactions and behavior (e.g. where you click, scroll your mouse, move in between pages). Hotjar will also record all your interactions and behavior on our website of Software. In addition, Hotjar will collect your devices information ( e.g. device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, and the preferred language used to display our website of Software.)

Hotjar may use such data to create visual representations of the experience, and to analyze, develop, improve, secure or optimize the use, function and performance of Our Sites of Software, or to make sure We are reaching out to the right audience.

Hotjar stores such data and information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on Our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

3.4.2 We may share your Personal Information upon your explicit consent or authorization, including your consent or authorization made based on this Policy and your consent or authorization under other agreements or rules in respect of the Software. In particular, by uploading your Personal Information to the Software and using the sharing or posting function of the Software to share the same to the public area of the Software or to any third-party media platform designated by you, you are deemed to have authorized us to share your Personal Information to other users in the public area of the Software or to your designated third-party platform;

3.4.3 Sharing as required by laws: We may share your information with third parties as required by applicable laws, regulations or legal proceedings, or pursuant to mandatory administrative or judicial requirements;

3.4.4 Sharing with our affiliates: In order to provide you with consistent services and to facilitate your uniform management, we may share your Personal Information with our affiliates, provided that such sharing will be limited to the extent necessary only and solely for the purposes set forth herein. If any of our affiliates intends to use your Personal Information for any other purpose, we will obtain your separate authorization or consent;

3.4.5 We may share data with third parties based on the application programming interfaces (APIs) or software development kits (SDKs).; and

3.4.6 We may share your Personal Information carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.

3.4.7 We may share your Personal Information if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our customers or others.

Other than the cases mentioned above,We will not share your Personal Information with any other company, organization or individual, unless with your explicit consent.

3.5Transfer

3.5.1 “Transfer” means the process of transferring the control over the Personal Information to other companies, organizations or individuals.

3.5.2 We will not transfer your Personal Information to any other company, organization or individual, except under the following circumstances:

(1) We may transfer your Personal Information upon your explicit consent or authorization, including your consent or authorization made based on this Policy and our consent or authorization under other agreements or rules in respect of the Software;

(2) Transfer as required by laws: We may transfer your information to third parties as required by applicable laws, regulations or legal proceedings, or pursuant to mandatory administrative or judicial requirements; and

(3) With the continuous development of our business, in the event of our merger, acquisition or bankruptcy, or in any other event relating to such merger, acquisition or bankruptcy, we may transfer your information as part of such transaction. In such case, we will request the new company, organization or individual in possession of your Personal Information to continue to be bound by this Policy; alternatively, we will request such company, organization or individual to obtain your separate authorization and consent.

3.6 Disclosure

3.6.1 Subject to the implementation of security measures consistent with industrial standards, we will disclose your Personal Information only in the following circumstances:

(1) We may disclose your Personal Information with your explicit consent or at your voluntary option;

(2) We may disclose your Personal Information pursuant to laws, regulations, rules or normative documents or as required by administrative, judicial or other competent authorities. If such disclosure is required by a competent law enforcement authority, we will promptly notify you, unless otherwise prohibited by such law enforcement authority. Subject to the compliance with laws and regulations, when we receive such requirement for disclosure, we will request such law enforcement authority to issue the corresponding legal document, such as subpoena or investigation letter. All such requirements will be carefully reviewed by us to ensure that they are made on legal basis and are only for data that the law enforcement authority has the legal right to access for the specific investigatory purpose;

(3) In case of your violation of any applicable law or regulation, or your breach of service agreement or other applicable rule in respect of the Software, or in order to protect the users of our Software and our affiliates or the public from personal injuries and property damages, we may disclose your Personal Information in accordance with the applicable laws and regulations or the service agreement or applicable rules in respect of the Software; and

If you are an eligible claimant of intellectual property rights who have filed a complaint, we may disclose your Personal Information to the respondent at its request for the settlement of potential dispute over rights and obligations between the claimant and the respondent.

3.6.2 Please be aware that pursuant to laws, sharing and transfer of de-identified Personal Information which cannot be recovered by the recipient to re-identify the subjects of such Personal Information do not constitute sharing, transfer or disclosure of such Personal Information, and the storage and processing of such Personal Information will not be subject to further notice to you or your further consent.

3.7Please refer to the table below for how we may use, share, transfer and disclose your Personal Information and the categories of Personal Information we collect and have collected over the past 12 months:

Category of Personal Information

Sources of Personal Information

Business or Commercial Purpose for Collection

Categories of Third Parties with whom We Share This Personal Information

Identifiers

collected from you;

collected automatically;

collected from the third party.

Authentication and Account Access;

Providing and Customizing the Services;

In other ways with your express consent.

Our affiliates;

Our vendors and service providers;

Other third parties for the legal reasons(e.g. a court or a government agency);

Parties you authorize, access or authenticate

Usage Data

collected from you;

Providing and Customizing the Services;

Product Improvement and Development;

In other ways with your express consent.

Our affiliates;

Our vendors and service providers,such as behavior and web analytics tools ;

Other third parties for the legal reasons(e.g. a court or a government agency);

Parties you authorize, access or authenticate

Commercial Information

collected from you;

collected automatically;

collected from the third party.

Transact Commerce;

Processing Transactions;

Fulfilling orders;

In other ways with your express consent.

Our affiliates;

Our vendors and service providers, such as payment processor;

Other third parties for the legal reasons(e.g. a court or a government agency);

Parties you authorize, access or authenticate

Biometric Information

collected from you;

Providing and Customizing the Services;

In other ways with your express consent.

Our affiliates;

Our vendors and service providers;

Other third parties for the legal reasons;

Parties you authorize, access or authenticate

Internet or other similar network activity

collected from you;

collected automatically;

collected from the third party.

Customer Support;

Help,Secure, Troubleshoot and Marketing;

Product Improvement and Development;

In other ways with your express consent.

Our affiliates;

Our vendors and service providers, such as behavior and web analytics tools ;

Other third parties for the legal reasons(e.g. a court or a government agency);

Parties you authorize, access or authenticate

Geolocation Data

collected from you;

collected automatically;

collected from the third party.

Providing and Customizing the Services;

In other ways with your express consent.

Our affiliates;

Our vendors and service providers;

Other third parties for the legal reasons (e.g. a court or a government agency);

Parties you authorize, access or authenticate

Inferences drawn from other Personal Information

collected from you;

collected automatically;

collected from the third party.

Inferring characteristics about a consumer;

Personalized Advertising;

In other ways with your express consent.

Our affiliates;

Our vendors and service providers,such as behavior and web analytics tools;

Other third parties for the legal reasons(e.g. a court or a government agency);

Parties you authorize, access or authenticate.

3.8 Cross-Border Transfer of Personal Data

You understand and agree that the personal information you provide to us and we collect from you may be processed and stored on servers located in various jurisdictions, including in the United States. For example, to facilitate our global operations, your personal information may be transfer to our offices, subsidiaries, and affiliates operating outside your country of residence. Besides,to provide our Services, perform our contract with you, your personal information may be processed by our third-party service providers or partners, whose facilities and servers may located outside your country of residence, e.g. European Union(EU).

While data protection law varies by country, We will endeavour to put in place appropriate safeguards to ensure that your personal data will be protected at the same level of protection as or not less than the level of protection in your country when transferred to other country and pursuant to legally valid transfer mechanisms.We will require that third parties (the recipient) shall comply with the local Data Privacy laws and regulations, such as CCPA, GDPR,etc.You may request additional information in respect of transfer mechanisms by exercising your rights as set out below.

4. How we protect your Personal Information

4.1 We have been attaching great importance to the protection of our users’ Personal Information. To this end, we have adopted security technologies and organizational, management and other measures consistent with industrial standards to minimize the risks of leakage, damage, misuse, unauthorized disclosure or alteration of or unauthorized access to your information.

4.2 Technologies and measures adopted by us to protect your Personal Information

4.2.1 We have adopted security measures consistent with industrial standards to protect your Personal Information from unauthorized access, disclosure, use, alteration, damage or loss.

4.2.2 Our network services adopt encryption technologies such as Transport Layer Security protocol, and provide browsing services through secure browsing modes such as HTTPS protocol, so as to ensure the security of user data during transmission.

4.2.3 We will adopt encryption technologies to store our users’ Personal Information in encrypted form, so as to enhance the security thereof.

4.2.4 We will use trusted protection mechanism to protect Personal Information from malicious attack, and will use isolation technologies for isolation.

4.2.5 We will deploy an access control mechanism to protect Personal Information with strict data access control and multiple identity verification technologies, so as to ensure that the Personal Information will be accessible only to authorized personnel.

4.2.6 We will provide training sessions on security and privacy protection, in order to enhance our employees’ awareness of the importance of Personal Information protection.

4.2.7 We will take reasonable and practical measures to avoid collecting irrelevant Personal Information. We will retain your Personal Information only for the period necessary to achieve the purposes set forth herein, unless it is necessary to extend the retention period or such retention is permitted by law.

4.2.8 We have established a data security department to enhance and ensure the Personal Information security, and will conduct background checks on personnel in charge of security management and those holding key security-related positions.

4.2.9 We will implement comprehensive data security control through non-disclosure agreements for persons with access to information, as well as monitoring and audit mechanisms.

4.3 Please be aware that although we will use our commercially reasonable efforts to ensure the security of any information from you, the Internet is never absolutely secure. Therefore, we strongly suggest that you do not send your Personal Information through any communication methods other than those recommended by us. Please properly protect your Personal Information and provide it to others only when necessary. If you find that your Personal Information, especially your account name or password, is divulged, please immediately contact the customer services personnel of the Software, so that we may take corresponding measures as requested by you. We suggest that you use complex password for the tools hereunder to help us keep your account secure. Although we will use our commercially reasonable efforts to ensure the security of any information from you, we will not be liable for any risk or loss arising from or in connection with your misuse of your Personal Information.

4.4 In the event of any Personal Information security incident, we will, in accordance with the laws and regulations, promptly notify you of basic information and possible consequences of such security incident, measures taken or to be taken by us, suggestions on how you may prevent or mitigate risks on your own, and remedies to be taken for you. We will notify you of the relevant information on such incident through email, letter, phone call or push notification. If it is difficult to notify each Personal Information subject one by one, we will publish an announcement in a reasonable and effective manner. In addition, we will also report the handling of Personal Information security incident as required by regulators.

4.5 By submitting your Personal Information through the Software, you agree and authorize us to collect, use, share and protect your Personal Information. If you intend to withdraw your consent in respect of your Personal Information because you find that your Personal Information is divulged or due to any other particular reason, especially if your account information is divulged, please immediately contact us via the contact details set forth in [9. How to contact us], so that we may take corresponding measures.

4.6 Storage of your Personal Information

The personal information that you provide to us and that we collect from you may be transferred to, stored at, or processed in, countries outside your country of residence, such as to the United States. During your use of the services hereunder, we will retain your Personal Information based on our needs and legal requirements, and such retention will be for such period as is necessary to provide the services in principle and for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. If we cease to operate the Software, or you close your account or voluntarily delete your Personal Information, or the necessary storage period of your Personal Information expires, we will delete or anonymize your Personal Information in our possession in accordance with applicable laws within a reasonable period, unless:

(1) otherwise required by laws and regulations relating to information retention;

(2) a reasonable extension of such period is required for the purpose of finance, audit, dispute resolution or otherwise; or

(3) otherwise required by the Customer as Personal Information processor.

5. Your rights

5.1 We attach great importance to the management of your Personal Information, and use our commercially reasonable efforts to protect your rights to access, correct, delete and withdraw consent to your Personal Information as well as your other legitimate rights, so that you will be fully capable of protecting your privacy and security.

5.2 Privacy Protection Rights

We want you to be in control of how your personal data is used by us. Subject to local law, you may have the right to:

• be informed of, and request access to, the personal data we process about you;

• update your Personal Information if you change your Personal Information;

• correct any inaccurate Personal Information about you;

• object to the processing of your Personal Information;

• request the restriction or deletion of your Personal Information;

• request a restriction on the processing of your Personal Information;

• withdraw your consent where we obtained your consent to process Personal Information (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal); and/or

• lodge a complaint with your local data protection authority.

You may exercise those rights by contacting us via contact details set forth in [9. How to contact us]. For security reasons, we may need to request specific information from you to help us confirm your identity when you claim the above rights.

We will honor such requests for access, correction, deletion, or restriction, and/or any withdrawal or objection as required under the applicable data protection laws and regulations. However, please note that such rights are not absolute: they do not always apply, and exemptions may be applicable. We will usually, in response to any such request, ask you to verify your identity and/or provide information that helps us to better understand your request. If we do not comply with your request, we will explain why.

If you are not satisfied with how we process your Personal Information and want to exercise the above rights, please let us know and we will investigate your concern. If you are not satisfied with our response, you have the right to further contact us.

5.3 Access to and correction of your Personal Information

5.3.1 In addition to the rights available under laws and regulations, you shall have the right to access and correct your Personal Information at any time by contacting us via the contact details set forth in [9. How to contact us].

5.3.2 If you need to access or correct other Personal Information generated during your use of our products and/or services, you may contact us via the contact details set forth in [9. How to contact us], and we will respond to your request in such manner and within such period as set forth herein.

5.3.3 If you become aware of any error in your Personal Information processed by us, after identity verification, you shall have the right to request us to make correction or supplement, provided that such correction will not affect the objectivity or accuracy of such Personal Information.

5.3.4 If you are an Authorized User, given the relationship between you and the Customer, you acknowledge and agree that you shall first contact the Customer or the Customer’s administrator to access and correct your Personal Information.

5.4 Deletion of your Personal Information

5.4.1 You may request us to delete your Personal Information via the contact details set forth herein if:

(1) we process Personal Information in violation of any law or regulation;

(2) we collect or use your Personal Information without your explicit consent;

(3) we process your Personal Information in breach of any agreement with you;

(4) you no longer use our products or services or you voluntarily make a request for closing your account;

(5) we no longer provide you with products or services, or the storage period of your Personal Information expires; or

(6) the purpose for which we process your Personal Information has been achieved, or it becomes impossible to achieve such purpose, or your Personal Information is no longer necessary for achieving such purpose.

5.4.2 If we decide to grant your request for deletion, we will also notify those entities that have obtained your Personal Information from us and request them to delete the same in a timely manner, except as otherwise provided by laws and regulations or that such entities have been separately authorized by you.

5.4.3 After you delete information from our services, we may not immediately delete such information from the backup system of the Software, but we will delete it when updating the backups.

5.4.4 If you are an Authorized User, given the relationship between you and the Customer, you acknowledge and agree that you shall first contact the Customer or the Customer’s administrator to delete your Personal Information.

5.5 Change or withdrawal of your authorization

5.5.1 If you intend to change the scope of Personal Information that you have authorized us to collect, or you intend to withdraw your authorization, you may withdraw your consent entirely by closing your account, or contact us via the contact details set forth in [9. How to contact us] to withdraw the corresponding authorization.

5.5.2 Please understand that our products and/or services may rely on collecting necessary Personal Information. Once you withdraw your consent or authorization, we will not be able to provide the service corresponding to such consent or authorization, and will no longer process your corresponding Personal Information. However, your decision to withdraw your consent or authorization will not affect the Personal Information processing previously carried out under your consent or authorization.

5.5.3 If you are an Authorized User, given the relationship between you and the Customer, you acknowledge and agree that you shall first contact the Customer or the Customer’s administrator to change the scope of Personal Information to be collected or withdraw your authorization.

5.6. Closure of your account

5.6.1 If you an Individual User and intend to stop using our products and/or services, you can close your registered account directly on the Software. After you close your account, we will stop the provision of products and/or services to you, and the contents, information, data, records, etc. under such account will be deleted or anonymized, unless otherwise provided by any law or regulation or required by any regulator. In addition, once your account is closed, it will be unrecoverable.

5.6.2 If you are an Authorized User, given the relationship between you and the Customer, you acknowledge and agree that you shall contact the Customer or the Customer’s administrator to close your account.

5.6.3 If you are an Administrator who uses the Software and Services hereunder on behalf of a Customer, you shall contact us for account closure after obtaining your Customer’s consent, and we will close your account after verification,and we reserve the right to delete or anonymize all data under your account, except those that are required to be retained under laws and regulations.

5.7 If you intend to access this Policy

You may view it in its entirety on the registration and login page of the Software.

5.8 Response to your requests above

5.8.1 If you are unable to exercise your rights by the means above, or you believe that we have violated any law or regulation or breached any agreement with you on the collection or use of your Personal Information, you may contact us by sending an email to our email address. After receiving your feedback, we will respond in time, and will deal with the same within 15 working days.

5.8.2 To ensure your account security, when you make any request above, you may be required to provide written documents, and we may ask you to verify your identity before processing your request.

5.8.3 In principle, we will not charge any fees for your reasonable request. However, we may charge certain costs on a case-by-case basis if your requests are made repeatedly beyond the reasonable scope, and we may reject your requests that are made repeatedly without justifiable reason, that require excessive technical means, that pose risks to others’ legitimate rights and interests, or that are extremely impractical.

5.9 Exceptions where we will not grant your request

We will not grant your request if:

(1) it is related to our performance of obligations under laws and regulations;

(2) national safety or national defense security is involved;

(3) public security, public health or major public interests are involved;

(4) criminal investigation, prosecution, judgment or enforcement is involved;

(5) we have sufficient evidence to prove your subjective malice or abuse of rights;

(6) it will cause material damage to the legitimate rights and interests of you or other individuals or entities;

(7) it is necessary for protecting your or other individual’s life, property or other major lawful rights and interests but in a circumstance where it is difficult to obtain the consent of the relevant Personal Information subject; or

(8) trade secret is involved.

6. How we process Personal Information of minors

While the Software and services are intended for a general audience, our Software and services are not intended for children. Our website does not knowingly collect Personal Information online from children below 13 years of age. If you are under 13 years of age, do not use or provide any information on the website or through any of its features, register on the website, make any purchases through the w1ebsite, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we have received Personal Information from a child below 13 years of age, we ask that a parent or guardian contact us and notify us of the matter so that we can delete the information. If you believe we might have any information from or about a child under 13 years of age, please contact us.

7. How we update this Policy

7.1 With the development of the Software business, we may update and modify this Policy from time to time at our sole discretion by posting a new version on our website, with the “Effective” date at the top of this Privacy Policy and will notify you of such update via email if you select to receive such communication from us. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this Policy to check for any changes. Changes to this Policy are effective when they are posted on this page. Your use of our Software and services after we have made changes to our Policy will mean that you have accepted those changes..

7.2 A more prominent notice (including in the form of Software website announcement) will be provided by us for any material change. “Material change” referred to herein includes but is not limited to:

(1) material change of our business/service mode, such as the purpose of Personal Information processing, the types of Personal Information we process and the ways in which we use Personal Information;

(2) our material change of control, such as change of ownership owing to M&A and reorganization;

(3) change of the main subjects to whom the sharing, transfer or disclosure of Personal Information is made;

(4) material change of your rights to participate in Personal Information processing or the ways to exercise such rights;

(5) change of our department responsible for the security of personal data processing, its contact details or complaint channel; and

(6) existence of high risk as shown in the Personal Information security impact assessment report.

7.3 By continuing to use our Software and services after any amendment to this Policy, you acknowledge that you have fully read, understood and accepted, and are willing to be bound by, the amended Policy.

8. Disclaimer

IN ADDITION TO THE ABOVE, WE SHALL NOT BE HELD LIABLE FOR:

8.1 ANY LEAKAGE OF PERSONAL INFORMATION/CORPORATE INFORMATION DUE TO YOUR DISCLOSURE OF YOUR USER PASSWORD TO OR SHARING OF YOUR REGISTERED ACCOUNT WITH ANY OTHER PERSON; OR

8.2 ANY LEAKAGE, LOSS, MISAPPROPRIATION, OR TAMPERING OF PERSONAL INFORMATION/CORPORATE INFORMATION CAUSED BY COMPUTER PROBLEM, HACKER ATTACK, INVASION OR ATTACK OF COMPUTER VIRUS, TEMPORARY DOWNTIME DUE TO GOVERNMENT CONTROL, OR FORCE MAJEURE THAT AFFECTS THE NORMAL OPERATION OF NETWORKS.

9. How to contact us

9.1 Should you have any question, comment or suggestion about this Policy or your Personal Information, please feel free to contact us at any time.

Email:contact@rendora.ai

Postal Code:19801

Contact Address:1209 Orange Street, Wilmington, New Castle County, Delaware

9.2 After receiving your feedback, we will usually accept and process within 15 business days. If you are dissatisfied with the way we deal with your feedback, especially if our processing of Personal Information damages any of your legitimate rights and interests, you may also file a complaint or report to the competent cyberspace administration, public security organ, industrial and commercial administration and other regulators.

Release Note