Last modified: May 19, 2023

1. Introduction

Hangzhou CE-soft Technology Co., Ltd ("Company," "we, " or "us") respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (the "Policy"). This Policy describes the types of information we may collect or that you may provide to us when you use WiLynk as developed by Hangzhou CE-soft Technology Co., Ltd (the "Product"), or use service(s) as provided by us or our affiliates (the “Service”), and our practices for collecting, using, maintaining, sharing, protecting and disclosing that information.

This Policy applies only to information we process when you use the Product or Service. This Policy does not apply to products or services provided by third party companies or individuals (hereinafter referred to as "Third Party Services"). Please be noted that your personal information may be processed by third parties without our control. You shall consider carefully and decide whether to use Third Party Services and we will not be liable for the Third Party Services in any event.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.

BY CHECKING THE CONSENT BOX FOR THIS POLICY AND THE TERMS OF USE OR USING OR ACCESSING THE PRODUCT OR SERVICE, YOU (A) ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS POLICY AND THE TERMS OF USE; (B) REPRESENT THAT YOU ARE 16 YEARS OF AGE (OR THE YOUNGEST AGE THAT APPLICABLE LAWS PROVIDE FOR AN ADULT) OR OLDER (COLLECTIVELY REFERRED AS APPLICABLE AGE); AND (C) ACCEPT AND AGREE THAT YOU ARE LEGALLY BOUND BY THIS POLICY AND THE TERMS OF USE. IF YOU DO NOT AGREE TO THIS POLICY OR THE TERMS OF USE, DO NOT ACCESS OR USE THE PRODUCT OR SERVICE.

We may modify this Policy from time to time (see "Changes to Our Policy" below).

2. Definitions

1) Personal Information: shall have the same meaning as “personal data” and shall include any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity. Examples of personal information include your name, telephone number, email address, physical address, profile photo, job department and position.

2) Personal Sensitive Information: it refers to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, etc., depending on the definition provided by applicable laws.

3) Product: it refers to WiLynk, which is a software developed by Hangzhou CE-soft Technology Co., Ltd for router management and home network monitoring.

4) Device: it refers to your router.

5) End Device: it refers to the products that use your router network, such as your mobile phone, computer.

3. How We Protect Children’s Personal Information

The Product is not intended for children under 16 years of age, or equivalent minimum age in the relevant jurisdiction (refer to “Child” or “Children” below) and we do not knowingly collect personal data from Children. If we learn we have collected or received personal data from a Child without verification of parental consent, we will delete that information. If you believe we might have any information from or related to a Child, please contact us at support@cce-soft.com.

4. Information We Collect, Purposes of Processing and Legal Grounds

We collect information from and about users of the Product or Service:

· Directly from you when you provide it to us, and/or;

· When you use the Product or Service or specific functions of the Product or Service.

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We will ensure that we only collect and process personal data that is necessary for using the Product or Service we offer to you, or which is permitted by applicable laws. In case that you choose not to provide certain information, you might not be able to use certain functions of the Product or Services.

Note that we may process your personal data for more than one legal ground depending on the specific purpose when you using the Product or Services. Please contact us at support@cce-soft.com if you need details about the specific legal ground we are relying on to process your personal data.

a. Registering for use of or access to the Product

1) Account information and managing your account

In order to register our Product and manage your account, you may be required to provide your Personal Information such as e-mail address, user name, mobile number and password (“Account Information”). You can change your user name or password through [ME-click the avatar-Change Password]. You can close your account through [ME-click the avatar-Delete Account]. You can send us an email at support@cce-soft.com to close your account on this Product at any time.

2) Account Sharing Function

For purpose of promoting the experience when you using our services, your account registered on this Product will be shared within the specific scope of Products automatically (“Account Sharing Function”). The Products including but not limited to DMSS, DoLynk Pro (“Products with shared account”). The Account Sharing Function enable you to use the account registered on this Product to login the Products with shared account and obtaining their corresponding services. We may collect your Personal Information for implementing the Account Sharing function and we will only process your Personal Information which is necessary.

If you want to cancel the Account Sharing Function, you have the right to request us to delete your Account information, by contacting us at support@cce-soft.com. Once the Account Sharing Function has been cancelled, all your personal information within the Products with shared account, including but not limited to your account information registered on this Product will be deleted at the same time. You have to register a new Account if you want to use this Product and the Products with shared account again.

In case your request is only to delete your Personal Information of this Product and you are still willing to use the Products with shared account, we offer the choice for you to request deleting your Personal Information of this Product only and you are entitle to use your account to login the Products with shared account. If you would like to use this Product again, you can login this Product with the account directly without processing the registration procedure.

Therefore, we highly recommend you to read this Policy carefully and specify clearly about your requirements when you sending emails to us.

b. Network connection

For purpose of network connection, we may collect your Device MAC address. These information is only stored on your local device.

c. End device management

For purpose of Terminal product management, we may collect MAC address, name, IP address of your Terminal product. These information is only stored on your local device.

d. We will obtain your explicit consent before processing your Personal Information unless there is any applicable law permits the processing without your consent:

(1) processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract;

(2) processing is necessary for compliance with a legal obligation;

(3) processing is necessary in order to protect the vital interests of data subject or of another natural person;

(4) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested;

(5) processing is necessary for the purposes of the legitimate interests pursued by we or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of data subject which require protection of personal data, in particular where the data subject is a child.

(6) other lawfulness of processing as specified in applicable laws.

5. How We Protect and Store Your Information

1) Data Security Measures

(1) We shall take all appropriate physical, electronic and management security measures to prevent your Personal Information from accidental losses and from unauthorized access, use, alteration and disclosure. For instance, we shall use encryption technology to improve the security of Personal Information and trusted protection mechanisms to prevent Personal Information from being maliciously attacked.

(2) We highly recommends you to use comprehensive and complex password in protecting the security of your account. We shall ensure the security and confidentiality of Personal Information you provide.

(3) In the case of a personal information leakage and other personal information security incidents, we shall without undue delay and, where feasible, after having become aware of it, notify the personal data breach to you and/or the supervisory authority competent in accordance with the applicable laws and regulations via email, phone, push notification, announcement or any other feasible methods in a reasonable and effective way. We shall inform you including the basic situation and possible impact, the disposal measures that we has taken or will take and recommendations for risk mitigation, etc.

2) Retention of Your Personal Information

Your personal data will be retained for no longer than it is required for the purposes described in this Policy or in so far as such is necessary for compliance with statutory obligations and for solving any disputes, or as otherwise communicated with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will cease to retain and delete or anonymize personal information once the purpose of collection is fulfilled, or we confirm your request for erasure except for retention is required by applicable law.

6. How We Share and Disclose Your Information

We may disclose aggregated or de-identified information about our users, and other information that does not identify any individual or device, without restriction as which it is permitted by applicable laws.

We may share or disclose personal data that we collect or you provide:

· to our subsidiaries and affiliates to deliver you the Product or Service you ordered;

· to our group companies, and other companies to facilitate the provision of Services to you;

· to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them;

· to third party hotline service provided for receiving and following up on your request for after-sales;

· to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Company about our Product users is among the assets transferred;

· to fulfill the purpose which is required for the functions or services you would like to use;

· for any other purpose with your explicit consent.

We may also disclose your personal data:

· to comply with any court order, law, or legal process, including to respond to any government or regulatory request;

· to enforce our rights arising from any contracts entered into between you and us, including the Product Software License Agreement and for billing and collection;

· which we believe disclosure is necessary or appropriate to protect the rights, property, or safety of third parties. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

7. Accessing and Correcting Your Personal data

You can send us an email at support@cce-soft.com to request access to, correct, or delete any personal data that you have provided to us. You may also object to or request us to restrict the processing of your personal data. If we process your personal data based on consent, you may withdraw your consent at any time by contacting us (see below). A summary of your legal rights is set out below:

· REQUEST ACCESS to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

· REQUEST CORRECTION of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us;

· REQUEST ERASURE of your personal data. This enables you to ask us to delete or remove personal data in this Product by submitting your request to us through sending email to support@cce-soft.com if there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your written request;

· OBJECT TO PROCESSING of your personal data where we are relying on our legitimate interest (or that of a third party), and there is something about your particular situation that makes you want to object to processing on this ground as you believe it affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that overrides your rights and freedoms;

· REQUEST RESTRICTION of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it;

· REQUEST THE TRANSFER of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to information which you initially provided consent for us to use or where we used the information to perform a contract with you;

· WITHDRAW CONSENT AT ANY TIME where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Product or Service to you. We will advise you if this is the case at the time you withdraw your consent.

For security reasons, we will take steps to authenticate your identity before providing access to your personal data. You also have the right to lodge a complaint with the relevant Data Protection Authority.

8. International Transfers

We are headquartered in the P.R. China and we operate globally. We have established subsidiaries and affiliates in different regions around the world and we offer our Product or Service through the use of servers located in different countries. As such, your personal data might be transferred outside the region and country you use our website, Product or Service, including to regions/countries outside the European Economic Area (“EEA”) which might have different legal rules and might not offer an adequate level of protection as determined by the European Commission. However, we have taken the necessary measures to ensure that your personal data is processed in conformity with the applicable laws and appropriate technical security measures are adopted to safeguard your privacy. Where necessary we use Standard Contractual Clauses, which are approved by the European Commission to comply with applicable legislation. Your personal data may be stored or processed in multiple countries, including United States, Germany, and Singapore. For the purposes described in this Policy, your information may be transferred to these territories in accordance with applicable law.

9. Changes to Our Policy

We may revise or change this Policy from time to time. You may access to the updated version after upgrading the Product software via online upgrade function of the Product. All changes are effective immediately when we post them and apply to all access to and use of the Product or Service thereafter; provided, to the extent required by law, we will seek your affirmative consent prior to applying material modifications to this Policy on how we use or disclose personal data that we collected or received prior to the date of the modification. You are expected to check this Policy frequently, so that you are aware of any modifications, as they are binding on you.

10. Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us at support@cce-soft.com, via email or by mail at:

Hangzhou CE-soft Technology Co., Ltd

A20, Binxing Road 1399, Binjiang District

Hangzhou, Zhejiang Province, P.R. China

310053

C/O: Data Protection Officer