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Sobot Personal Information and Privacy Protection

updated:2022-06-27

Welcome to our Sobot products and services! We know that your personal information is important to you, Sobot prioritizes customer trust, we will strictly comply with the law and regulatory requirements to take appropriate security protection measures, committed to ensure a secure environment for your information.

In view of this, the service providers of Sobot (Sobot Technologies PTE. LTD and affiliated companies, hereinafter referred to as "Sobot" or "we"), in accordance with the latest laws and regulations such as the Personal Information Protection Law of the People’s Republic of China (hereinafter referred to as "this Policy"), and reminds you that.

This policy applies to all platform products and services provided by Sobot, including mobile applications (Sobot Customer Service APP), clients (Sobot Customer Service PC version, web version), Sobot website (domain name: www.Sobot.io), Sobot SDK, WeChat official account, WeChat mini-program and all products and services provided to users in new forms as technology develops.

This policy does not apply to products and services provided to you by any other third parties through the aforementioned website, apps and client software. We recommend that you review the personal information and privacy policies of such third parties before using their products and services to understand how they handle your information. You are solely responsible for all the consequences of providing or sharing your personal information with third parties when you use their products and services.

Before using Sobot's products or services, please read and thoroughly understand this policy in its entirety, especially the terms and conditions highlighted in bold or underlined in bold, and confirm that you fully understand and agree to it before using the relevant products and services. By using Sobot's products and services, you acknowledge that you have fully understood and agreed to this policy.

Sobot's Personal Information and Privacy Policy contains the following:

1. How we collect and use your personal information

2. How we use cookies and other similar technologies

3. How we share, transfer and publicly disclose your personal information

4. How we store and protect your personal information

5. How you manage your personal information

6. How we handle personal information of minors

7. How your personal information is transferred globally

8. How this policy is updated

9. How to contact us

1.How we collect and use your personal information

The personal information we need to collect and use about you when you use our products and services as follows:

(1). In order to achieve the basic functions of providing our products and services to you, you must authorize the necessary information to be collected and used by us. If you refuse to provide the appropriate information, you will not be able to use our products and services properly.

(2). In order to provide you with additional functions of our products and services, you may choose to authorize the information that we collect and use. If you refuse to provide it, you will not be able to use the relevant additional functions properly or to achieve the functional effect we intend to achieve, but it will not affect your normal use of the basic functions of our products and services.

You understand and agree that.

(1). We are always committed to creating a diverse range of products and services to meet your needs. Due to the differences in the specific products and services that different users choose to use, the basic and additional functions and the type and scope of personal information collected and used may be different, please refer to the specific product and service functions.

(2). In order to give you a better experience of our products and services, we are always striving to improve our technology. We may subsequently introduce new or optimized functions at times, and accordingly, we may need to collect and use new personal information or change the purpose or ways of using personal information. In this regard, we will provide separate instructions by updating this policy, providing page tips, sending an email to your designated email address or sending a short message to your registered mobile number, meanwhile, we will provide you with options of choosing consent by yourself, collecting and using your personal information with your consent.

We will collect and use your personal information for the purposes of this policy as follows:

1. Help you become a registered user and manage your account with us

(1). Basic Account Services

In order to register as a Sobot Customer Service company/organization user, you will need to provide yourcontact name, mobile phone number and email address,as well as your company name, enterprise qualification certificate (a scanned copy of your business license or People’s Republic of China Certificate of Public Institution with Legal Person Status, etc.) and thepassword to be used. We may check your identity against the mobile phone number or email address you provide above. In order to log in to your Sobot customer service account, you will need your email address and a login password.

To achieve basic customer service account function, you must authorize us to collect and use the following customer service information: email account, customer service ID, customer service nickname, real name and mobile phone number.

(2). Additional account services

For additional account management functions, you can choose to complete and store the following customer service information:avatar, customer service work number, fixed telephone number, QQ number, customer service role, call account number, external number, login time and update time.

We may provide your account information (avatar, nickname and other page prompts) to third parties with your consent to enable you to easily register for a third party account or to log in directly with the third party for the purpose of account authorization. In addition, we may also obtain your third party account information from third parties based on your individual consent and link to your Sobot customer service account to enable you to log in and use our products and/or services directly with the third party. We will use your relevant information within the scope of your separate consent authorization.

If you use the Sobot customer service service on third parties such as WeChat official account, WeChat mini programs, Weibo, blog, etc., we may collect and use your open id, nickname, avatar, user gender, region (country, province, city) and other information.

2. To provide you with a display of information on products or services

When you use our products and services, we may automatically collect and store the following information as web logs in order to identify network status and account exceptions, to understand the adaptability of our products and services and to provide you with services that better adapt your needs, including:

(1). Equipment information

We will receive and record the necessary device and system information (including device identifier, Android ID, operating system type, system version, App package name, App version, device type, device manufacturer, device model, screen size, network type) that you use based on your specific actions during the installation and use of the software, and you will need to authorize device information permissions.

(2). Service log information

When you use the services provided by our website, APP or client, etc., in order to count the usage of platform users and optimize our products and services, we will automatically collect detailed information about your usage of our services and keep it as a service log, including the date and time of access, source URL, browsing history, search query, click to view, follow, browser and version, etc.

Please note thatservice log information and device information alone is information that does not identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person or use it in combination with personal information, such non-personal information will be regarded as personal information during the combined use and will be anonymized and de-identified unless authorized by you or otherwise required by law.

In order to send you notifications about your account and the content of our products and services, we may send you messages via the mobile phone number or email address you provided when you registered. We may also send you product and/or service updates, management and other service notifications that we deem necessary to inform you of, such as via SMS, site notifications, etc.

We are committed to protect your using experience andonce you have opted out of receiving content from us, you will need to unsubscribe via email or SMS or contact customer service.Please note that your cancellation of a service notification will directly result in you being unable to continue using that product or service.

3. Customer service and dispute solution

If you have any comments or suggestions on the use of Sobot products and/or services, or if you need to make a complaint or be given feedback, you can contact us using work orders, telephone or online customer service.

To protect the security of your account and our systems,we require you to provide the necessary personal information to verify your identity as a user. We may keep a record of your communications, correspondence/calls and related content (including session content, account information, work order information, other information you provide to prove a fact, or contact information you leave behind) in order to contactyou, help you resolve a problem as soon as possible or record the outcome of the problem.We will use your account information and work order information if you make an enquiry, complaint or provide advice in relation to a specific work order.

4. Providing you with security

In order to improve the security of your use of the services provided by us and our partners, to protect you or other users or the public from infringement of personal property, to better prevent phishing sites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusion and other security risks, and to more accurately identify violations of laws and regulations or the rules of the relevant agreement of Sobot, we embed in the applications Security SDK which developed by us to collect your device information, service log information, and may use or integrate your registration information, device information, service log information and information that our partners obtain your authorization or share in accordance with the law to make a comprehensive determination of your account risk, conduct identity verification, detect and prevent security incidents, and take the necessary recording, auditing, analysis and disposal measures in accordance with the law.

5. Other additional services

In order to provide you with more convenient, better quality and personalised products and/or services and to enhance your experience, the following additional services we provide to you may collect and use your personal information by enabling system permissions. If you do not agree to enable the relevant permissions, it will not affect your use of the basic services of Sobot,but you may not be able to obtain the user experience of these additional services.

You can turn these permissions on or off at any time at your discretion.

Please note that by enabling any of the permissions, you authorize us to collect and use the relevant personal information to provide you with the corresponding services, and by disabling any of the permissions, you cancel your authorization and we will no longer be able to collect and use the relevant personal information based on the corresponding permissions, nor can we continue to provide you with the services corresponding to those permissions. Your decision to turn off your access will not affect any previous collection and use of information based on your authorization.

Additional services related to system permissions include.

1. Location permissions: If you use location-related services, you may provide information related to your location, such as country code, city code, mobile network code, mobile country code, house identification, time zone settings. We will access your location information after you have enabled location permissions to help customer service staff better understand new information and provide services.

2. Camera/video permissions: You can use this function to send pictures and videos with camera/video permissions enabled.

3. Microphone permission: You can use this feature to send voice messages and make voice calls after turning on the microphone permission.

4. Phone permission: When you use the Sobot call centre, voice robot and other call product functions, you need to take the initiative to provide a specific phone number, open the phone permission to make or receive calls. After you use the above functions, we will store the caller’s called number, call time, call recording, etc.

5. Storage permission: You can use this function to send/save pictures, files and videos after enabling the permission to allow the APP to read/write to external storage.

6. Clipboard permission: You can use this function to copy messages and mobile phone numbers etc. after opening the permission to allow the APP to access the clipboard content.

7. Network permission: You can use this function to achieve app networking and monitor network changes after enabling the permission to allow the app to access the network/get the network (WIFI) status.

8. Vibration permission: You can use this function to achieve device vibration reminder after turning on the permission to allow APP to use vibration.

9. Wake lock permission: You can use this function to allow the Android version of the app to use the wake lock permission after enabling the program to keep the screen awake even after the device screen is turned off and background processes are still going on.

10. Sound settings permissions: You can use this function to modify global audio settings, such as adjusting the volume and the speakers used for output, after enabling the Allow Android version of the app to modify sound settings permission.

11. Broadcast management permission: You can use this function to enable the application to receive ACTION_BOOT_COMPLETED broadcast in the system to complete the startup after you have enabled to allow the Android version of APP to use broadcast management permission.

6. Third party software tool development kits (SDKs) accessed

In order to analyze the use of our products or services and to enhance the user experience, our applications may include third party SDKs or other similar applications. If you use such services provided by third parties on our platform, you agree that your information will be collected and processed directly by them (e.g. in the form of embedded code, plug-ins, etc.).

1. The third-party SDK accessed by the PC-based Sobot Customer Service Workbench

Name of the SDK source: Shanghai Oray Information Technology Co.

Purpose of use: remote collaboration

Access to information: account information (avatar, nickname), geolocation (location information), camera (video), album (photo gallery), microphone and address book

Link to privacy policy: http://service.oray.com/question/5387.html

2. The third party SDKs accessed by Sobot Customer Service APP include Umeng+SDK and Push Channel SDK (such as Xiaomi, Huawei, oppo, vivo, Meizu, etc.), please refer to "List of Third Party SDKs Used by Sobot Customer Service APP" for details.

To maximize the security of your information, we recommend that you check the personal information protection policy of any third party SDK service before using it. If you find that these SDKs or other similar applications are at risk, we recommend that you terminate them immediately and contact us promptly.

7. Description of the use of personal information collected by the Sobot SDK

For details of the personal information collected by Sobot when mobile Internet applications (apps) access the Sobot SDK service, refer toDescription of the use of personal information collected by the Sobot SDK

8. Others

1. If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing such personal information to Sobot. If personal information of minors is involved, you must obtain the consent of the guardian of the corresponding minor before publishing, and the guardian has the right to contact us through the means in section 9 of this policy to request correction or deletion of the content involving personal information of minors.

2. We will obtain your prior consent if we use information for purposes other than those set out in this policy, or if we use information collected for a specific purpose for other purposes, or if we obtain your personal information from a third party on our own initiative.

If we obtain your personal information indirectly from a third party, we will explicitly request the third party in writing to collect it after we have obtained your consent in accordance with the law and inform you of the content of the information obtained before collecting it, and where sensitive information is involved, we will require your explicit consent before providing it to us for use, and require the third party to make a commitment to the legality and compliance of the source of the personal information, and if the third party acts in breach of the law, We will explicitly ask it to bear the corresponding legal responsibility; at the same time, our professional security team will carry out security reinforcement of personal information (including sensitive information reporting, sensitive information encrypted storage, access rights control, etc.). We undertake to protect such indirectly acquired personal information with means and measures no less protective than those we use for our own users' personal information.

3. Information without authorized consent

You fully understand and agree that we do not require your authorized consent to collect and use your personal information and that we may not respond to your requests for correction/revision, deletion, cancellation, withdrawal of consent, request for information when:

(1) Relating to national security and defence security.

(2) Relating to public safety, public health, or significant public interest.

(3) In connection with the judicial or administrative law enforcement, such as the investigation, prosecution, trial and enforcement of judgements for offences.

(4) Where it is necessary to protect your or another individual's vital legal rights and interests, such as life or property, but it is difficult to obtain your consent.

(5) Personal information that you disclose to the public at your own discretion.

(6) Where personal information is collected from legitimate publicly disclosed information channels, such as legitimate news reports, government information disclosure and other channels.

(7) Necessary for maintaining the safe and stable operation of the products and services provided, such as the detection and disposal of faults in products and services.

(8) Necessary for legitimate journalism.

(9) Where it is necessary for an academic research institution to carry out statistical or academic research in the public interest, and where the results of the academic research or description are made available to the public, the personal information contained in the results is de-identified or anonymized.

(10) Other situation as stipulated by laws and regulations.

Please understand that, inaccordance with applicable law, if we process your personal information in a way that makes it impossible for the recipient of the data to re-identify a specific individual and cannot be recovered, or if we may de-identify the information we collect for research, statistical analysis and prediction purposes, to support products or services for business decisions, and to improve our products and services (including the use of anonymised data for machine learning or model algorithm training), then such processed data may be used without separate notice to you and without your consent.

4. Tips on sensitive personal information

Sensitive personal information is personal information which, if disclosed, unlawfully provided or misused, may endanger the safety of persons and property, and is highly likely to lead to damage to a person's reputation, physical or mental health, or discriminatory treatment, etc. Information provided by you voluntarily or collected by us from you may include your personal sensitive information, includingidentity document numbers, personal biometric information, bank account numbers, property information, whereabouts, transaction information, and personal information of minors under 14 years of age (inclusive).

Please be careful when providing sensitive personal information.Where sensitive personal information is involved, we will ask for your consent again in a separate pop-up window when providing the relevant service, and you can set your permission to turn it off at any time via your device once it has been turned on.

2. How we use cookies and other similar technologies

Cookies and similar device information identification technologies are commonly used on the Internet and are small files that are stored by a web server on your computer, mobile phone or other smart device when you log on to a website or browse web content, usually containing an identifier, the name of the site and some numbers and characters. The website recognizes your browser by the cookie when you return to the respective website.

When you use our services, we may collect your device model, operating system, device identifier, login IP address information, as well as cache your browsing information, and click information through cookies or similar technologies. Cookies allow us to identify you when you visit and may also be used to show you information or functions that may be of interest to you. Cookies also save you from having to repeatedly enter search content, account information and other steps. We promise that we will not use cookies for any purpose other than those described in this policy.

You may manage or remove certain categories of tracking technology from cookies according to your preferences. Most browsers provide users with the function to clear the browser's cache data, and you may be able to clear the data accordingly, or you may be able to modify your acceptance of cookies or reject our cookies. You may not be able to use services or corresponding functions that rely on cookies because of these modifications.

3. How we share, transfer and publicly disclose your personal information

(1) Sharing

We will not share your personal information with third party companies, organizations and individuals outside of Sobot unless we have your consent, except for the following:

1. Sharing under legal situations:We may share your personal information with the public in accordance with legal regulations, litigation, dispute resolution needs, or as requested by administrative or judicial authorities in accordance with the law.

2. Sharing with explicit consent: We will share your personal information with other parties after obtaining your explicit consent.

3. Sharing where necessary for the conclusion and performance of a contract to which you are a party: By purchasing a Sobot product or service, we will, at your option, share the necessary information about you with the provider of the relevant service.

4. Sharing with Affiliates:In order to facilitate the provision of some of our services to you in conjunction with our affiliates, to identify abnormalities in Sobot customer service accounts, and to protect the personal and property safety of Sobot's affiliates or other users or the public from harm, your personal information may be shared with our affiliates and/or their designated service providers.We will only share personal information that is necessary and subject to the purposes stated in this policy, and will seek your authorized consent again if we share your sensitive personal information or if our affiliates change the purposes for which the personal information is used and processed.

Please note that the information you voluntarily share or even publicly share when using our services may involve personal or even sensitive personal information about you or others. Please consider and make your decision more carefully.

(2) Commissioning

We may commission an authorized partner to process your personal information in order to authorize the partner to provide certain services or perform functions for you on our behalf. We will only commission them with your information for the lawful, legitimate, necessary, specific and explicit purposes stated in this policy, and the authorized partner will only have access to the information required to perform its duties and will be required by agreement not to use this information for any other purposes beyond those commissioned to it. If an authorized partner uses your information for a purpose that we have not commissioned to them, they will obtain your consent separately.

Currently, we commission the following types of authorized partners:

1. Authorized partners in the advertising and analytics services category. We will commission these partners with the processing of information relating to the placement, reach and effectiveness of advertising, subject to the use of security technology common to the industry. We do not commission your personally identifiable information to our partners.

2. Suppliers, service providers and other partners. We commission the processing of information to suppliers, service providers and other partners who support our business, including data storage services commissioned by us, technical infrastructure services, analysis of how our services are used, measuring the effectiveness of advertising and services, providing customer service or conducting academic research and surveys.

(3) Transfers

We will not transfer your personal information to any company, organization or individual, except for the following:

1.Transfer with explicit consent: we will transfer your personal information to other parties after obtaining your explicit consent.

2. In the event of a merger, acquisition or insolvency of us and our affiliates, or other circumstances involving a merger, acquisition or insolvency involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this privacy policy, or we will require that company, organization and individual to seek your authorized consent again.

(4) Public disclosure

We will only disclose your personal information publicly if:

1. We may disclose your personal information publicly based on your active choice and other individual consent.

2. If we determine that you have violated laws and regulations or seriously violated the relevant agreements and rules of Sobot, or to protect the personal and property safety of Sobot users or the public from infringement, we may disclose personal information about you, including relevant violations and the measures that Sobot has taken against you.

(5) Exceptions to prior authorized consent for sharing, transfer, or public disclosure of personal information

Your prior authorized consent is not required for the sharing, transfer or public disclosure of your personal information in the following situations:

1. Relating to national security and defence security.

2. Relating to public safety, public health or significant public interest.

3. In connection with judicial activities such as crime investigation, prosecution, trial and judgement enforcement or administrative law enforcement activities.

4. For the purpose of safeguarding your or other individuals' significant legitimate rights and interests such as life and property but where it is difficult to obtain your own consent.

5. Personal information that you disclose to the public at your own discretion.

6. Where personal information is collected from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure and other sources.

Please understand that, in accordance with applicable law, if we take technical and other necessary measures to process personal information in such a way that the recipient of the data cannot re-identify a specific individual and cannot recover it, the sharing, transfer, or public disclosure of such processed data does not require separate notification to you and your consent.

4.How we store and protect your personal information

(1) Information storage

1. Storage period

We will take reasonable and practicable steps to avoid collecting irrelevant personal information. We will only retain your personal information for as long as is necessary to achieve the purposes described in this policy, unless there is a mandatory retention requirement by law. After your personal information has been retained beyond that time, we will promptly delete or anonymize your personal information as required by applicable law.

2.Storage location

Generally speaking, your personal information will only be stored in the territory of the People's Republic of China, and your information will not be actively transferred by us outside the country. If we need to transfer personal information outside of China for business purposes in accordance with applicable laws, we will obtain your consent in advance, inform you of the purpose of the outbound information, the recipient, security measures, security risks, etc., and conduct a security assessment in accordance with the law.

3.When our products or services cease to operate, we will notify users in accordance with legal requirements, including but not limited to message push, platform announcement, etc., and delete or anonymize your personal information within a reasonable period of time.

(2) Protection measures

1. The technical measures we have taken to protect data

We have taken reasonable and practicable security measures in accordance with industry standards to protect your information from unauthorized access, public disclosure, use, modification, damage or loss. Currently, the system on which we store your personal data has been assessed by the Ministry of Public Security for security level 3 protection. We use encryption technology to enhance the security of personal information; we use trusted protection mechanisms to prevent malicious attacks on personal information; and we deploy access control mechanisms to ensure that only authorized personnel have access to personal information.

3. Guarantee of the terms of the cooperation agreement

Before we collect your personal information indirectly from a third party, we will explicitly require the third party to collect and process your personal information with your express consent in writing (e.g. cooperation agreement, commitment), and require the third party to commit to the legality and compliance of the source of the personal information in a written agreement, and if the third party acts in breach, we will explicitly require the other party to bear the corresponding legal liability.

Before we share your personal data with our partners, we strictly require our partners to undertake data protection obligations and responsibilities. To this end, we will require our partners to sign a data processing agreement or include provisions on data protection in the cooperation agreement signed by both parties prior to the cooperation. The agreement strictly stipulates the partner's obligation to keep user information confidential, including the storage, use and flow of information, which shall meet our control requirements and be subject to our review, supervision and audit, and in case of any breach, we will require the other party to bear the corresponding legal responsibility.

4. You should also protect the security of your account

The Internet is not an absolutely secure environment and we strongly recommend that you do not use communication methods other than those recommended by Sobot when using Sobot services to send your information and that you use complex passwords to help us protect the security of your account.

Please note that the information you voluntarily share or even publicly share when using our services may involve personal information or even sensitive personal information about you or others. Please consider more carefully whether to share or even publicly share such information in connection with your use of our services.

(3) Notification of security incidents

1. If our physical, technical or administrative protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of information, damaging your legitimate rights and interests, we will promptly initiate emergency plans and take reasonable remedial measures to minimize the impact on your personal information and other rights and interests.

2. After the unfortunate occurrence of a personal information security incident, we will inform you in accordance with the requirements of laws and regulations: the basic situation of the security incident and the possible impact, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, the remedial measures for you, etc. We will inform you of the incident by email, letter, telephone, push notification, etc. If it is difficult to inform the subject of personal information individually, we will take reasonable and effective ways to make an announcement. At the same time, we will also report on the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

5.How you manage your personal information

(1) Access to your personal information

You have the right to access your personal information, if you want to exercise your right to access data, you can access it by yourself in the following ways: super management users can check the customer service information under their current account by clicking on personal information in the intelligent customer service system, and check other customer service information in the customer service list under the customer service management module, including customer service ID, customer service nickname, avatar, real name, customer service work number, mobile number, phone number, social media number, customer service role, call number and external number.

(2) Correction of your personal information

When you wish to change your personal information, you can do it directly in the intelligent customer service system in Personal Information under that account, and the super admin account can change the information under the current account as well as other accounts in his customer service list.

(3) Deletion of personal information or account cancellation

If you wish to completely delete your personal information or cancel your registered account, you can send a written request to the following email address: Privacy@sobot.io and our dedicated staff responsible for personal information protection will promptly process it and provide you with feedback on the outcome within 15 working days.

(4) Access to copies of personal information by subjects of personal information

You have the right to obtain a copy of your personal information, which you can do yourself by: you can export your customer service information from your customer service list in the customer service manager of the new version of the intelligent customer service system.

6.How we handle personal information of minors

Sobot provides products and/or services primarily to adult users. You are presumed to have the appropriate civil capacity to use Sobot's products and/or services. If you are a minor, we hope that you ask your parent or other guardian to read this policy carefully and to use our services or provide us with information with the consent of your parent or other guardian. We do not knowingly collect personal information from minors. If you become aware that we have inadvertently collected personal information from a minor, please notify us immediately and we will attempt to delete the data as soon as possible.

If you are a child under 14 years of age, before you use our services, you and your guardian should carefully read our specially developed Sobot Children’s Personal Information Protection Rules and Notices For Guardians You should ensure that you have the consent of your guardian before using our services and that you use our services with the guidance of your guardian to ensure your safety when using our services. If you are a parent or other guardian of a child, please be aware that the child is using our services with your authorized consent. If you have questions about a child's personal information, please contact our dedicated personal information protection department.

7.How your personal information is transferred globally

In principle, personal information collected and generated by us in the People's Republic of China will be stored in the People's Republic of China, except in the following cases.

1. The applicable law is clearly defined.

2. To obtain your express authorization.

3. Your personal initiative such as cross-border transactions via the internet.

In these situations, your personal information may be transferred to, or accessed from, jurisdictions outside the country in which the product or service you are using is located. Such jurisdictions may have different data protection laws or even no such laws. In such cases, we will ensure that your personal information is adequately protected to the same extent as it is in the People's Republic of China. For example, we will implement security measures such as data de-identification prior to cross-border data transfers.

8.How this policy is updated

We may revise the content of this Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your express consent. We will post any changes to this policy on this page. We will also provide more prominent notice of material changes (including, for certain services, email notification of specific changes to our personal information protection policy).

Material changes within the meaning of this policy include, but are not limited to:

1. Significant changes to our service model. such as the purposes for which personal information is processed, the types of personal information processed, and the manner in which personal information is used.

2. Significant changes in our ownership structure, organizational structure, etc. such as changes in ownership resulting from business restructuring, bankruptcy mergers and acquisitions, etc.

3. A change in the primary recipients of the sharing, transfer or public disclosure of personal information.

4. Significant changes in your rights to participate in the processing of personal information and the manner in which they are exercised.

5. In the event of a change in the department responsible for handling the security of personal information, our contact details and complaint channels.

6. When the personal information security impact assessment report indicates a high risk.

You have the right to choose to accept the update Privacy Policyor to discontinue using our products and services or to cancel your account, but please note that your actions and activities prior to cancellation or cessation of use of the Service are still governed by this Privacy Policy.By continuing to use the products or services provided by Sobot, you are deemed to have accepted the revised Privacy Policy.

9.How to contact us

If you have any questions, comments or suggestions regarding this Personal Information Protection Policy, contact us at:

1.Call the customer service hotline: 4008-690-981 (weekdays: 09:30-18:30)

2. Send personal information protection email: Privacy@sobot.io

3. Mail the letter to: 2M Floor, Building9, No.2, Hanwei International Plaza, Fengtai District, Beijing (100070), addressee:personal information protection officer.

We will complete the identification and response process within 15 working days after receiving your comments and suggestions. If we are unable to respond to your request, we will send you a notice with an explanation of why within the maximum time required by law.

If you are not satisfied with our response, or if our handling of your personal information infringes your legitimate rights and interests, and we are unable to provide you with a satisfactory response and refuse to improve after your feedback to us, you may file a complaint and report to the relevant regulatory department.

We would like to notice you again that please read the terms marked in bold in the content of this Privacy Policy carefully. By clicking the "Register"/"Login" button, you are deemed to have fully accepted all the contents of this Privacy Policy. Before clicking, please reconfirm that you have known and fully understood the entire contents of this Privacy Policy. 2. Please send personal information protection emails at Privacy@sobot.io