Last updated on: August 10, 2022

This Policy is formulated to explain how does Foton Overseas (unless otherwise stated, Foton Overseas refers to the Beijing Foton International Trade Co., Ltd.) collect, access and store your personal information and what rights do you enjoy in the process of providing network services. Foton Overseas will explain relevant matters to you through this Privacy Policy. Foton Overseas hereby reminds you that you must carefully read and understand this Privacy Policy before accessing the services provided by Foton Overseas, and you may access the products or services provided by Foton Overseas only after confirming your full understanding and consent. Your accessing of products or services provided by Foton Overseas shall be deemed as your acceptance and approval of the contents of this Policy. If you do not agree to any of the clauses of this Policy, you should stop accessing the services provided by Foton Overseas.

This Policy will help you understand:

1. How Foton Overseas collects and uses your personal information

2. How Foton Overseas uses cookies

3. How is your personal information shared, transferred and publicly disclosed

4. How Foton Overseas protects your personal information

5. How Foton Overseas accesses, modifies or withdraws your personal information

6. How does your personal information transferred in a global context

7. How is this Policy updated

8. How to contact us

Foton Overseas deeply understands the importance of your personal information and will do our best to keep your personal information safe and secure. When you access the services provided on website of Foton Overseas, we will collect, process and disclose your information in accordance with this Privacy Policy. Foton Overseas is committed to maintaining your trust in us, and protecting your personal information by scrupulously adhering to the following principles: power and responsibility integration principle, purpose specification principle, selection consent principle, least enough principle, ensuring safety principle, subject participation principle, publicity and transparency principle, etc. Meanwhile, we promise that we will take appropriate security protection measures to protect your personal information in accordance with the mature security standards in the industry. Please read and understand this Privacy Policy carefully before accessing any of Foton Overseas's services.

1. How Foton Overseas collects and uses your personal information

1.1 The personal information refers to all kinds of information recorded electronically or by other means and can be accessed individually or in combination with other information to identify the identity of a specific natural person or to reflect the activities of a specific natural person.

1.2 When you access any of Foton Overseas's products and services, we will collect and access your personal information in the following ways:

(1) When you access any relevant services on Foton Overseas's website, you need to provide us with your username and mobile phone number. You can choose to continue to improve your information on the web page, including but not limited to your real name, industry involved, region, website, detailed address. We will keep this information strictly confidential and handle it in a lawful manner.

(2) Online message information. When you need to access the online message service provided on Foton Overseas's website, we will require you to provide your username and email address so that we can respond to your service request. We may retain your chat records and order information so that we can provide you with the services you wish to obtain.

(3) Operation and support information. Foton Overseas will, from time to time, launch operations for new services and features. If you participate in the relevant operation activities, we may collect your contact information (e.g. mobile phone number), contact address and transaction account information through the operation activities interface to ensure that you can successfully participate in the activities. If you do not participate in the relevant operation activities, you are not required to provide the foregoing information.

1.3 In summary, your personal information collected by the website will be used to:

(1) Provide, maintain or improve products or services for you;
(2) send important notifications to you;
(3) activate or validate any product or service;
(4) promote and introduce products to you as permitted by laws and regulations; and,
(5) achieve other purposes permitted by you.

1.4 If we intend to use the information collected for other purposes not specified in this Policy, we will seek your prior consent.

1.5 It should be noted that, as a user of Foton Overseas, if you access the technical services of Foton Overseas to provide relevant data services for your users, you shall separately agree on the privacy policy with your users because the control right of this part of business data belongs to you. This Privacy Policy does not apply to the processing of the above data.

2. How Foton Overseas uses cookies

2.1 In order to ensure the proper operation of the website, we will send small data files called cookies to your computer or mobile device. Cookies typically contain the identifiers, site name, and some numbers and characters. By taking use of the cookies, the website can store the information such as your preferences.

2.2 We will not use Cookies for any purpose other than those described in this Policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer, and most web browsers have Cookie blocking capabilities. However, if you do this, you are required to personally change the user settings every time you visit our site.

3. How Foton Overseas shares, transfers and publicly discloses your personal information

3.1 Sharing

We will not share your personal information with any corporation, organization or individual other than Foton Overseas, with the exception of:

(1) Sharing with express consent: We will share your personal information with other parties only after obtaining your express consent.

(2) Sharing your user information externally in accordance with laws and regulations, litigation or arbitral settlement, or as required by administrative or judicial authorities in accordance with law.

(3) Sharing with our affiliates: Your personal information may be shared with affiliates of Foton Overseas. We will only share necessary personal information and are bound by the purposes stated in this Privacy Policy. If any of our affiliates want to change the purpose for which personal information is processed, they will seek your authorization and consent again.

"Our affiliate" means any corporation or legal organization that is or will be controlled by us, control us or jointly controlled with us. "Control" means to have the power to determine the financial and business policies of a corporation, directly or indirectly enjoy more than 50% of the management or decision-making rights of the corporation, and can obtain benefits from the business activities of the corporation.

(4) Sharing with authorized partners: Certain of our services (e.g. real-name authentication) will be provided by authorized partners only for the purpose stated in this Policy. We will only access your personal information for lawful, legitimate, necessary, specific and explicit purposes, and will only provide the personal information necessary for the services. Our partners are not entitled to use the personal information obtained for any other purpose. For the companies, organizations and individuals with whom we share user information, we will sign strict information protection agreements with them and require them to handle user information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures. In addition, your personal information will be transferred to the storage space in the data center through the underlying network operator. For our services in China, we will cooperate with the Chinese underlying network operators and data centers located in China.

3.2 Transfer

We will not transfer your personal information to any corporation, organization or individual, with the exception of:

(1) Transfer with express consent: We will transfer your personal information to other parties only after obtaining your express consent.
(2) If the transfer of personal information is involved in merger, acquisition or bankruptcy liquidation, we will require the new corporation or organization holding your personal information to continue to be bound by this Privacy Policy, otherwise we will require the corporation or organization to seek authorization and consent from you again.

3.3 Public disclosure

We will publicly disclose your personal information only if:

(1) Your express consent is obtained.
(2) Disclosure is required by law: We may publicly disclose your personal information when being compulsorily required by law, legal process, litigation or government authorities.

3.4 Exceptions to obtaining prior authorization and consent when sharing, transferring or publicly disclosing user information

No prior authorization and consent from you is required to share, transfer or publicly disclose your user information if your user information is:
(1) related to national security and national defense security;
(2) related to public security, public health and major public interests;
(3) related to criminal investigation, prosecution, trial and execution of judgment;
(4) disclosed to protect your or other individuals' life, property and other major legitimate rights and interests, but it is difficult to get your consent;
(5) disclosed to the public by you on your own; and,
(6) collected from legally disclosed information, such as legal news reports, government information disclosure and other channels.

4. How Foton Overseas protects your personal information

4.1 Foton Overseas attaches great importance to the security of your information. We will endeavor to take all reasonable physical, electronic and administrative security measures to protect your user information. We will prevent unauthorized access, public disclosure, use, modification, damage or loss of user information. We will enhance the security of user information by adopting the encryption technology; we will protect our user information from being subjected to malicious attacks by adopting trustworthy protection mechanisms; we will deploy access control mechanisms to try to ensure that only authorized persons have access to user information; and we will organize security and privacy protection training courses to enhance staff awareness of the importance of protecting user information. Foton Overseas has passed numerous international and domestic management system certification.

4.2 We will take all reasonable and practicable measures to avoid the collection of irrelevant personal information as much as possible. We will only retain your personal information for as long as necessary to achieve the purposes stated in this Policy, unless otherwise specified by laws. After the expiration of the above user information retention period, we will delete or anonymize your personal information.

4.3 Please use a complex password to help us ensure the security of your account. We will do our best to ensure the security of any information that you send to us. In order to ensure your information security more effectively, we also hope that you can strengthen the awareness of self-protection. We are only liable for the disclosure of your personal information to the extent that it is directly caused by Foton Overseas. Therefore, please keep your account number and password information properly to avoid the disclosure of your personal information.

4.4 The Internet environment is not 100% safe, so we will try our best to ensure or guarantee the security of any information that you send to us. In the event of an unfortunate personal information security incident (leakage, loss, etc.), we will, in accordance with the requirements of laws and regulations, timely inform you of the basic situation and possible consequences of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will timely inform you of the relevant situation of the incident by email, letter, phone call, push notification and other means. When it is difficult to inform the subjects of personal information one by one, we will make a public announcement in a reasonable and effective manner. Meanwhile, we will also take the initiative to report the disposal of personal information security incidents in accordance with the requirements of the regulatory authorities.

5. How Foton Overseas accesses, modifies and deletes your personal information

5.1 You may request us to delete your personal information in accordance with the law; if we have a reasonable basis to believe that the request is deceptive, unenforceable or impairs the privacy rights or interests of others, we will refuse to process the request.

5.2 You may request us to delete your personal information if:

(1) You find that any behavior of our handling of personal information violates any laws and regulations;
(2) we collect and use your personal information without your express consent;
(3) any behavior of us in handling personal information seriously violates the agreement with you; and,
(4) you will no longer use any of our services.
For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to prove your identity before we process your request.

5.3 If you cancel your account by yourself, we will stop providing you with products or services, and delete your personal information or anonymize it according to applicable laws.

5.4 We do not charge for your reasonable request in principle. However, if the request is repeated many times and exceeds the reasonable limit, we will charge a certain cost at our discretion. We may reject requests that are gratuitously repeated or excessively self-conceited (e.g., those requiring the development of a new system or fundamental changes in existing practices), pose a risk to the legal rights of others, or are highly impractical (e.g., those involving the information stored on backup tapes).

5.5 We will not be able to respond to your request to delete personal information if:

(1) It is relevant to our performance of obligations stipulated in laws and regulations;
(2) it is directly related to national security or national defense security;
(3) it is directly related to public security, public health or major public interests;
(4) it is directly related to criminal investigation, prosecution, examination and approval and execution of judgment;
(5) we have evidence to show that you have engaged in subjective malice or abuse of power;
(6) it is for the purpose of safeguarding the major legitimate rights and interests of the personal information subject or other individuals, such as life and property, but it is difficult to get your consent;
(7) your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations; and,
(8) any trade secret is involved.

6. Preservation and cross-border transfer of your personal information

We will store the information that we collected about you in the People's Republic of China. If we transfer the personal information overseas for business purposes in accordance with applicable laws and regulations, we will obtain your consent in advance and inform you of the purpose of cross-border transfer, receiving party, security measures, security risks and other information.

7. How is this Policy updated

7.1 Our Privacy Policy is subject to change.

7.2 We will publish any changes to this Policy through our company's official website.

7.3 For any material changes, we will also provide a more prominent notice (including for some services, we will send a notice by email stating specific changes to the privacy policy).

7.4 The material changes referred to this Policy include but are not limited to:

(1) Material changes to our service model. For example, the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;
(2) material changes in our ownership structure, organizational structure, etc. For example, the change of owner caused by business adjustment, bankruptcy merger and acquisition;
(3) changes in the main objects of personal information sharing, transfer or public disclosure;
(4) material changes in your right to participate in the processing of personal information and the way in which you exercise it;
(5) changes in the departments responsible for handling personal information security, contact information and complaint channels; and,
(6) personal information security impact assessment report indicates that there is a high risk.

8. How to contact us

If you have any questions or comments about the content of this policy statement, or about Foton Overseas's practice and operation of this Privacy Policy, you can contact us at ftglobal@foton.com.cn.