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Privacy Policy and Information Security

1.1 Personal Data

Personal data is information that, when used alone or in combination with other information, can identify an individual. Such personal data is submitted to us by you when you use our website, products or services and when you interact with us, or is obtained by us through recording how you interact with our website, products or services, for example, through technology like cookies. The data we collect varies depend on the websites you visit or the products and services you use, and may include personal data such as name, address, email, phone number, etc. The purpose of our collection of personal data is to contact you in order to provide corresponding services or to send important notices.

1.2 Privacy Policy

Shanghai Putailai New Energy Technology Co., Ltd. and its subsidiaries around the world (hereinafter referred to as "Putailai", "we" or "our") understand the importance of personal data to customers and users. To this end, Putailai attaches great importance to the protection of personal data of customers and users, strictly abides by the provisions of the Personal Information Protection Law and the General Data Protection Regulation (GDPR), and takes a series of measures to ensure that relevant businesses comply with applicable personal data protection requirements.

1.2.1 Putailai adopted industry-recognized personal data protection methods and practices and uses various methods to assess and reduce personal data security risks in products and services.

a) Putailai requires full evaluation of personal data involved in products and services, and projects involving personal data must be evaluated;

b) Projects involving personal data shall establish data inventories and data flow diagrams;

c) Projects involving personal data must identify possible risks in the process of data processing (including personal data’s collection, usage, storage, sharing, deletion, etc.), and take corresponding measures (including management, physical and technical measures) according to the level of risk;

d) After the evaluation is completed, the corresponding report must be issued and approved by the relevant internal departments.

1.2.2 Putailai has adopted technical methods including intrusion detection, access control, encryption, data leakage prevention, anti-spam, terminal security protection, vulnerability scanning, etc., and has been testing the effectiveness of personal data protection measures through penetration testing.

1.2.3 Putailai has established an emergency response mechanism for personal data leakage. In the event of a personal data leakage, Putailai will immediately initiate an emergency response process, use its best effort to reduce the possible loss incurred by such personal data leakage and ensure that the affected persons are properly notified.

1.2.4 Putailai has established a continuous employee privacy policy training mechanism to ensure that every employee involved in data assessment can accurately understand the legal principles of data protection based on their specific job responsibilities, and strictly implement the company's applicable systems and procedures.

1.2.5 To ensure compliance to applicable laws and regulations, Putailai has implemented necessary technical audits and process audits for personal data protection.

1.2.6 Putailai has established a sound privacy protection policy for minors. Unless it is required by laws, regulations or mandatory provisions of law enforcement agencies and relevant authorities, we will not actively or individually collect personal information of minors.

Personal data protection is not only a legal requirement, but also a corporate’s social responsibility. Putailai will continue to optimize products and services to ensure security and protection of privacy, and reduce the risk of personal data leakage for customers and users.

1.3 Policy Updates

Putailai reserves the right to update or modify this policy from time to time. If this policy changes, we will post the latest version of the policy here. If we make material changes to our Privacy Policy, we may also send you notice of the change through various channels, such as a notice on our website or a separate notice to you.