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Primarius Technologies Co., Ltd. Customer Privacy Statement

Last updated September, 2020

Customers are Primarius Technologies Co., Ltd.’s (“Primarius”)most valuable asset. We recognize that building a long-term businessrelationship with you depends a great deal on trust. This trust beginswith our commitment to respecting and protecting your privacy. ThisPrivacy Statement provides a clear and prominent explanation of how wecollect, use, share and protect your personal data.

This Privacy Statement covers the following subjects:

  1. Types of Personal Data We Collect
  2. How We Collect Personal Data
  3. How We Use the Personal Data We Collect
  4. How We Share Your Personal Data
  5. How We Store, Process and Protect Your Personal Data
  6. Your Choices About Your Personal Data
  7. Additional Information
  8. Changes to Our Privacy Statement
  9. How to Contact Us

These areas are described in detail below. This Privacy Statement does notapply to the practices of third parties that we do not own or control,including but not limited to any third-party websites, services andapplications that you elect to access through our websites.

Comments or questions about our privacy practices can be sent toPrimarius’s Privacy Advocate(contact@khai-long.com).

1. Types of Personal Data We Collect

Personal data is any information relating to an identified oridentifiable natural person, including information that can be used toidentify you as an individual, directly or indirectly by reference toone or more factors specific to you. Personal data can include thefollowing types of information:

Personal information: Primarius collects and usespersonal information from our customers and potential customers. Suchinformation includes your name, contact information (postal address,telephone number, fax number, and email address), billing information,transaction history and payment information or other financialinformation. You may also elect to provide Primarius with informationregarding your personal or professional interests, demographics,experience with our products and contact preferences.

Online usage information: Primarius also sometimescollects and uses information from your online interactions with us.Online usage information can include IP address, browser size, type andlanguage, referring/exit pages and URLs, number of visits to our websiteand the hyperlinks you visited.

Software usage information: Primarius collects and usespersonal data relating to users of the software or other Primariusproducts connected to the software. Such information may includesoftware or device username, host name, device ID, IP address, Wi-Fiaccess point information, email address associated with the software,and/or information about usage of the software or its features.

We may combine the information you provide to us through differentcommunications and contact channels, for example by combining datacollected online with information provided offline.

2. How We Collect Personal Data

Primarius collects personal information in several ways. We collectpersonal information that you choose to provide Primarius onwww.khai-long.com, in person, on the phone orelectronically. Additionally, we may now or in the future receivepersonal information about you from third parties that legally acquiredthe information and that have the right to share it with Primarius. Forexample, we may receive contact information from a relevant trade showor event sponsor.

Primarius uses cookies and other technologies such as web beacons, localshared objects, local storage, e-tags, and JavaScript, to collect onlineusage information. Please review Primarius’s Cookie Policy for moreinformation regarding Primarius’s use of these technologies and yourchoices about them.

Certain Primarius software collects software user information via anautomatic data feed when connected to the internet. Specific informationabout which personal data is collected by a particular software productis available in the documentation associated with that product.

3. How We Use the Personal Data We Collect

Use of personal information: Primarius uses your personalinformation: (a) to respond to your correspondence; (b) to help youcomplete a transaction or order; (c) to provide updates on service andbenefits; (d) to personalize our website for your needs; (e) to provideadvertising, promotions or newsletters regarding Primarius products andservices to you online or by email; (f) to conduct market research tohelp us better meet our customers’ needs; (g) to obtain your feedback onPrimarius products or services you have purchased; (h) to comply withPrimarius’s legal obligations, including export controls and tradecompliance laws; and (i) for payment and order processing. Whenever wecollect credit card numbers or other financial data, such informationwill be encrypted, will only be used for payment processing and will notbe retained for other purposes.

Use of online usage information: Primarius collectsonline usage information to optimize your online experience,specifically: (a) to remember information so that you will not have tore-enter it during your visit or the next time you visit the site; (b)to provide custom, personalized content and information; (c) to provideand monitor the effectiveness of our website; (d) to monitor aggregatemetrics such as total number of visitors, traffic, and demographicpatterns; (e) to diagnose or fix technology problems; (f) to help youefficiently access your information after you sign in; and (g) toprovide advertising for Primarius products and services to you online orby email.

Use of software usage information: Primarius usespersonal data collected from software usage for the following purposes:(a) to analyze software performance and functionality to improve theuser experience; (b) to check for and provide software updates; (c) toensure compliance with terms and conditions of software licenseagreements; (d) to identify unlicensed usage of the software; and (e) toprovide usage reporting to Primarius customers.

Use of combined personal data: Primarius may sometimescombine your personal information with online usage information and/orsoftware usage information to build a broader profile of our individualusers so that we can better serve our customers. This combined data willbe used only for the purposes outlined in this Privacy Statement.

Online advertising: We partner with trusted thirdparties to manage Primarius advertising on other websites. These partnersuse cookies to collect information about your activities on Primarius’swebsite, so that we can provide you advertising for Primarius products andservices that are relevant to your interests. For more information aboutthird-party cookies and online advertising, please reviewPrimarius’s Cookie Policy.

4. How We Share Your Personal Data

Personal information: Primarius will not rent or sellyour personal information to parties. We will only share your personalinformation outside of Primarius for the reasons described below:

Primarius business partners: We may share your personalinformation with Primarius business partners including sales, rental andsolution partners and agents offering Primarius products and services, andvendors acting at our direction. We do so only to the extent necessaryfor the specific business partnership, or as otherwise permitted byapplicable law. Such Primarius business partners are required to keep thisinformation confidential and may not use it for any purpose other thanto offer, sell or rent Primarius products and services, or to provideservices at Primarius’s direction.

Corporate transactions: Circumstances may arise wherePrimarius decides to sell, buy, merge or otherwise reorganize businessesin some countries. Such a transaction may involve the disclosure ofpersonal information to prospective or actual purchasers, or the receiptof such information from sellers. It is Primarius’s practice to disclosepersonal information in these circumstances only as permitted byapplicable data protection law and to seek appropriate protection forpersonal information in these types of corporate transactions.

Legal necessity: Primarius also may disclose yourpersonal information: (a) if we are required to do so by law; (b) if webelieve that it is necessary to enforce or apply our terms of use andother agreements or otherwise protect and defend the rights, property orsafety of Primarius or that of our customers; or (c) to comply with ajudicial proceeding, bankruptcy proceeding, court order or other legalobligation or government inquiry

Your consent: Primarius also may disclose your personalinformation to any other third party with your prior consent.

Online usage information: We may share online usageinformation: (a) in any manner permitted for personal information; and(b) with vendors or service providers for the purposes described in thesection above on “How We Use the Personal Data We Collect.” We may alsoaggregate or otherwise strip data of all personally identifyingcharacteristics and may share that aggregated, anonymized data withthird parties. Any aggregated information shared in these contexts willnot contain your personal information.

User content: Primarius provides some opportunities foryou to generate your own internet-based content about Primarius and ourproducts and services. Typically, the personal information that youprovide in this user content will be shared outside of Primarius asdescribed below.

User-generated comments: Primarius’s website may containareas where users can transmit or post communications, for example, onblogs or in user forums. Any personal information you submit there willbe publicly available, and can be read, collected or used by otherusers, and could be used to send you unsolicited messages. We are notresponsible for the personal information you choose to submit in suchpublic areas.

Social media widgets: Primarius’s website may includesocial media features, such as the Weibo Like button, widgets such asthe “Share This” button or interactive mini-programs that run on ourwebsite. These features may collect online usage information throughcookies or web beacons. Social media features and widgets are eitherhosted by a third party or hosted directly on our website. Yourinteractions with these features are governed by the privacy statementof the social media company providing them.

Testimonials: Primarius sometimes posts on the websitecustomer testimonials that may contain personal information. We obtainour customers’ consent to post their name or other personal informationalong with their testimonial prior to posting the testimonial on ourwebsite. If you wish to update or delete your testimonial, pleasecontact Primarius’s Privacy Advocate.

5. How We Store, Process and Protect Your Personal Data

Storage and processing of your personal data: Inprinciple, the personal data we collect and generate within theterritory of the PRC will be stored within the territory of the PRC.However, Primarius’s organizational structure requires the transfer ofpersonal data inside and outside China within the Primarius group ofcompanies. As a result, we may transfer personal data to, and store orprocess personal data in, countries other than the country in which thepersonal data originally was collected. When we transfer, store orprocess personal data in other countries, we will take all stepsreasonably necessary to ensure that your data is treated securely and inaccordance with the SCCs and this Privacy Statement.

Data Retention: We retain your personal data as part ofyour individual customer record for a period of [five years] followingany activity on your account. After that time, your record will beinactivated and then deleted in accordance with Primarius’s data retentionpractices. We may retain personal data associated with orders, quotes,or other official business records for a longer period of time asnecessary to comply with our legal obligations, resolve disputes, andenforce our agreements.

Security: Primarius puts in place appropriate physical,electronic and organizational measures to safeguard and secure yourdata. These measures follow generally accepted industry standards bothduring transmission and once it is received. Unfortunately, thetransmission of information over the internet is not completely secure.Although we will do our best to protect your personal data, we cannotguarantee the security of your data transmission to our website.

Data compromise: In the event that your personal dataunder our control is compromised, Primarius will investigate the situationand take all steps required by applicable law. This includesnotification of the competent data protection authority whereapplicable, and when appropriate notification of those individuals whosepersonal data may have been compromised. Primarius may take other steps inaccordance with any applicable laws and regulations.

6. Your Rights and Choices About Your Personal Data

You have certain rights with respect to your personal data, including:the right to information about the personal data we store about you, theright to have your personal data corrected if it is inaccurate, and theright to object, on grounds relating your particular situation, at anytime to processing of your personal data. You also have the right, undercertain circumstances, to erasure, restriction of processing, andportability of your personal data.

To exercise your rights please contact Primarius’s Privacy Advocate. Wewill respond to your request as soon as is reasonably practicable and inany event [within 30 days]. To protect your privacy and security, wewill also take reasonable steps to verify your identity before grantingyou access or enabling you to make corrections. Additional ways you mayexercise choice about your personal data are outlined below.

Opting out of collection of personal information: Youmay, of course, decline to submit any personal information to Primarius,but then you may not be able to take advantage of some features of ourwebsite and we may not be able to communicate with you about Primariusproducts and services. In addition, personal information may be requiredto determine access eligibility for certain restricted parts of ourwebsite.

Opting out of collection of online usage information:Your browser or mobile device may allow you to delete and disablecookies. Note that disabling cookies may disable many of the featuresavailable through Primarius’s website. Please refer to our CookiePolicy for more information about any choices you may have with respectto cookies and the other technologies we may use to collect online usageinformation.

Opting out of software usage information: You may beable to opt out of certain personal data collection by Primarius software.Please review the documentation associated with each software product todetermine what choices you have with respect to software usageinformation.

Opting out of Primarius emails: You may choose to opt outof receiving marketing emails from Primarius, including newsletters andpromotions by following the unsubscribe instructions included in eachmarketing email or by contacting Primarius’s Privacy Advocate. However,please note that opting out may prevent you from receiving emailmessages regarding updates, improvements, or special offers. If you optout of marketing emails, we may continue to send you transaction orservice-related emails about our business dealings with you to theextent required to establish, carry out or terminate such businessdealings. We reserve the right to contact you for non-promotionalpurposes when we believe it is necessary, including where required bylaw. If you have any difficulty exercising your choices or feel thatchoices you made on particular websites have not been taken intoaccount, please use Primarius’s unsubscribe form.

Opting out of advertising: You may opt out directlywith  browser. Please note this does not opt you out of being servedadvertising altogether. You will continue to see generic ads.

Deletion of user content: To request that Primariusremove your user content or personal information from public areas ofour website, contact Primarius’s Privacy Advocate. In some instances, wemay not be able to remove your user content or personal information, inwhich case we will let you know if we are unable to do so and why. Inaddition, such information may continue to be available online evenafter it is removed from our website.

7. Additional Information

Other websites: We are not responsible for thepractices employed by websites or services linked to or from Primarius’swebsite including the information or content contained therein. Pleaseremember that when you use a link to go outside Primarius’s website, ourPrivacy Statement does not apply to third-party websites or services.Primarius is not responsible for and does not control any third partiesthat you authorize to access your user content. If you are using athird-party website or service (like Weibo) and you allow such a thirdparty access to your user content, you do so at your own risk.

Dispute Resolution: If you have questions or concernsregarding this Privacy Statement, you should first contact Primarius’sPrivacy Advocate. If you believe that the collection or processing ofyour personal data by Primarius is not compliant with applicable dataprotection laws, or have a privacy or data use concern you may alsocontact the data protection authority in your country of residence.

8. Changes to Our Privacy Statement

This Privacy Statement is effective as of the date stated at the startof this Privacy Statement. We reserve the right to modify this PrivacyStatement at any time by posting the revised statement on our websiteand updating the date the statement was last revised. If we makematerial changes to our privacy practices, we will notify you by emailor by means of a prominent notice on our home page.

9. How to Contact Us

Please contact Primarius’s Privacy Advocate with questions or commentsabout our privacy practices at:

Contact@khai-long.com

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