Guangdong Miyuan (Group) Co., Ltd. (hereinafter referred to as “Miyuan Group,” “we,” or “our”) fully understands the importance of privacy to you and will respect your privacy. Please read and understand this Privacy Policy (hereinafter referred to as “this Policy”) before submitting your personal data to Miyuan Group. This Policy applies to the relevant services provided to you on the websites owned and operated by Miyuan Group (hereinafter referred to as “Miyuan Group Website”). This Policy describes the information practices of the Miyuan Group Website, including what information is collected, how such information is used, with whom such information is shared, and how such information is protected. This Policy explains how your personal data is handled, though it may not cover all possible data processing scenarios. Please read and fully understand this Policy before using our services. Your continued use of our services after reading means that you agree to this Policy and any subsequent updates.

It is particularly important to note that the Miyuan Group Website may contain links to third-party websites or services. You are free to choose whether to access and use such third-party websites or services. Please note that we do not control these third-party websites or services, and they are not governed by this Policy. We recommend that you carefully read the third party’s privacy policy before visiting or using their websites or services. If you find risks in these third-party websites or do not agree with their privacy policies, we recommend that you discontinue related actions to protect your legal rights.

The purpose of formulating this Policy is to help you understand the following:

1.How Miyuan Group collects and uses your personal data

2.How Miyuan Group uses cookies and similar technologies

3.How Miyuan Group discloses your personal data

4.How to access or modify your personal data

5.How Miyuan Group protects your personal data

6.How Miyuan Group handles children's personal data

7.Third-party providers and their services

8.How your personal data is transferred globally

9.How this Policy is updated

10.How to contact Miyuan Group

1. How Miyuan Group Collects and Uses Your Personal Data
Personal data refers to information that is recorded electronically or by other means and can be used alone or in combination with other information to identify a specific natural person. It does not include information that has been anonymized. Such data may be directly submitted by you when using our website, products, or services, or when interacting with us. For example, we may obtain it by recording how you interact with our website, products, or services, such as through cookies or similar technologies, or by receiving usage data from software running on your device. Where permitted by law, we may also obtain relevant data from public or commercial third-party sources. The data we collect depends on how you interact with Miyuan Group, including the websites you visit or the products and services you use, and may include your name, gender, company name, job title, address, email address, and telephone number. You may be required to provide personal data when using Miyuan Group’s products or services. In some cases, you may choose not to provide personal data, but if you choose not to, Miyuan Group may not be able to provide you with related products or services or respond to or resolve issues you may encounter.

We may use your personal data for the following purposes:

(a) To fulfill your transactions or service requests, including fulfilling orders; delivering, activating, or verifying products or services; providing training and certification, and managing and processing training and certification results; participating in online or offline events; making changes at your request or providing requested information; and offering technical support.
(b) With your consent, to contact you; send you information about products and services that may interest you; invite you to participate in Miyuan Group events, market surveys, or satisfaction surveys; or send you marketing messages. If you do not wish to receive such information, you may unsubscribe at any time.
(c) To provide you with a personalized user experience and personalized content.
(d) To verify and manage suppliers and business partners, and to communicate or do business with them.
(e) To conduct internal audits, data analysis, and research to improve our products and services.
(f) To analyze business operational efficiency and measure market share.
(g) To troubleshoot errors when you choose to send us error details.
(h) To protect the security of our products, services, and users, and to enforce or improve our loss prevention and anti-fraud programs.
(i) To comply with and enforce applicable legal requirements, relevant industry standards, or our statements.

Miyuan Group may also collect and use non-identifiable data. Non-identifiable data refers to data that cannot be used to determine an individual's identity. For example, Miyuan Group may collect aggregated statistical data such as website traffic. The purpose of collecting such data is to understand how users use our website, products, and services. This enables Miyuan Group to improve its services and better meet customer needs. Miyuan Group may, at its own discretion, collect, use, process, transfer, or disclose non-identifiable data for other purposes. We will make every effort to isolate your personal data from non-identifiable data and use both types of data separately. If personal data is mixed with non-identifiable data, it will still be treated as personal data.

When Miyuan Group processes your personal data, we do so in accordance with applicable laws and on appropriate legal grounds, including:
· Processing your personal data to fulfill a contract when responding to your transaction or service requests;
· Processing your personal data based on your consent;
· Processing your personal data based on our or third parties’ legitimate interests when contacting you, conducting marketing or market research, improving our products and services, implementing and enhancing our loss prevention and anti-fraud programs, etc. Such legitimate interests include enabling us to more effectively manage and operate our business and provide our products and services; protecting the security of our business, systems, products, services, and customers; internal administration, compliance with internal policies and procedures; and other legitimate interests as described in this Policy;
· We may also process your personal data for the purpose of complying with and enforcing legal obligations.

You fully understand that, in accordance with applicable laws, we may collect and use your personal information without your prior consent in the following circumstances:

(a) When it concerns national security or public interest;
(b) When necessary for fulfilling our statutory duties or legal obligations, or responding to instructions from government authorities;
(c) When necessary for signing or performing a contract to which you are a party;
(d) When necessary for responding to public health emergencies, or to protect your or others’ life, health, and property safety in emergencies;
(e) When reasonably processing personal information that you have voluntarily made public;
(f) When reasonably processing your personal information collected from legally disclosed sources (such as legitimate news reports, government information disclosure, etc.);
(g) Other circumstances as stipulated by laws and regulations.

2. How Miyuan Group Uses Cookies and Similar Technologies
To ensure the normal operation of our website, continuously improve our website content, and provide you with a better service experience, we will collect and store certain terminal device data and website usage data through Cookies and other similar technologies (including but not limited to web beacons, Flash cookies, and HTML5 local storage objects (LSO)).

You can clear all cookies saved on your computer. Most web browsers are equipped with functions to block cookies. However, if you do so, you will need to change your user settings manually each time you visit our website.

Suppliers and partners who provide certain functions or display ads on our website based on your web browsing behavior may also use HTML5 and other LSOs to collect and store information. Different browsers may offer their own management tools for removing HTML5 LSOs.

2.1 Cookies
A Cookie is a plain text file stored on your computer or mobile device by a web server. The content of a Cookie can only be retrieved or read by the server that created it. Each Cookie is unique to your browser or mobile application. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of Cookies, websites can store user preferences and provide better service. Miyuan Group enables Cookies for the same purposes as most websites or internet service providers—to improve the user experience. With Cookies, websites can remember a user's single visit (using session Cookies) or multiple visits (using persistent Cookies). Cookies allow websites to save settings such as the language, font size, and other browsing preferences of your computer or mobile device. This means you do not need to reconfigure your preferences every time you visit. Without Cookies, websites will treat each visit as a new user session. For example, if you log in to a website and then navigate to another page, the site will not recognize you and you will be logged out again.

Miyuan Group will not use Cookies for any purposes other than those described in this Policy. You can manage or delete Cookies based on your preferences. For more details, please refer to AboutCookies.org.

If you click a hyperlink on the Miyuan Group website that directs you to a third-party website, those third-party websites may send Cookies to you. These third-party websites have their own Cookie policies which we cannot control. For more information on the Cookies used by these third parties and how to manage them, please contact the third-party websites directly.

3. How Miyuan Group Discloses Your Personal Data
3.1. Sharing with Third Parties
In principle, we do not share your user information with other organizations or individuals, except in the following cases:
3.1.1. With your explicit consent: We will share your user information with other parties only after obtaining your explicit consent.
3.1.2. In certain services provided by authorized partners of Miyuan Group, we will share your personal data with such partners as described in this Policy.
3.1.3. Sharing as required to fulfill legal obligations: We may share your user information externally as required by laws and regulations, litigation, arbitration, or as requested by administrative or judicial authorities in accordance with the law.
3.1.4. Miyuan Group may also share your data when there is a legitimate need, such as when it is necessary for entering into or performing a contract to which you are a party, or when necessary to investigate possible or actual illegal activities and such sharing is appropriate.

3.2. Public Disclosure
We will only publicly disclose your user information under the following circumstances:
3.2.1. With your explicit consent or based on your voluntary choice, we may publicly disclose your user information.
3.2.2. If we are required to provide your personal information by law, regulation, or compulsory administrative or judicial request, we may publicly disclose your user information based on the type of personal information requested and the manner of disclosure.
3.2.3. To protect the personal and property safety of Miyuan Group, its affiliates, users, or the public, we may disclose your user information according to applicable laws or Miyuan Group-related agreements and rules.

3.3. Exceptions to Prior Authorization and Consent for Sharing or Public Disclosure
We may share or publicly disclose your user information without your prior authorization and consent in the following circumstances:
3.3.1. Related to national security or national defense;
3.3.2. Related to public security, public health, or major public interests;
3.3.3. Related to criminal investigation, prosecution, trial, and enforcement of judgments;
3.3.4. To protect your or other individuals’ significant legitimate rights and interests, such as life and property, when it is difficult to obtain your consent;
3.3.5. Personal information that you have voluntarily disclosed to the public;
3.3.6. Personal information collected from lawful public disclosures, such as legal news reports or government information disclosure channels;
3.3.7. Other circumstances as provided by laws and regulations.

4. How to Access or Modify Your Personal Data
You should ensure that all personal data you submit is accurate. Miyuan Group will do its best to maintain the accuracy and completeness of personal data and to update such data in a timely manner.

Where required by applicable law, you may have the right to access and obtain specific personal data we hold about you; to request that we update or correct inaccurate personal data; to object to or restrict our use of your personal data; and to request that we delete your personal data. If you wish to exercise these rights, please contact us via the contact information provided in Article 10 of this Policy. To protect security, you may be required to submit a written request. If we have reasonable grounds to believe that these requests are fraudulent, unenforceable, or may infringe on the privacy of others, we will refuse to process the request.

Where required by applicable law, if Miyuan Group processes your personal data based on your consent or authorization, you also have the right to withdraw your consent at any time. Once you withdraw your consent or authorization, we will no longer provide you with the corresponding services, nor will we process your related personal information. However, the withdrawal of consent or authorization will not affect the lawfulness and effectiveness of our processing of your personal data prior to the withdrawal, nor will it affect our continued processing based on other appropriate legal grounds.

5. How Miyuan Group Protects and Retains Your Personal Data

Miyuan Group values the security of personal data. We adopt appropriate physical, administrative, and technical safeguards to protect your personal data from unauthorized access, disclosure, use, alteration, damage, or loss. For example, we use encryption technologies to ensure data confidentiality; we implement protection mechanisms to prevent malicious attacks; we deploy access control systems to ensure only authorized personnel can access personal data; and we conduct security and privacy protection training to enhance employees' awareness of the importance of protecting personal data.

We strive to protect your personal data; however, please note that no data transmitted over the internet can be guaranteed to be 100% secure. Therefore, although we take appropriate measures to protect your personal information, Miyuan Group cannot guarantee the security of any information you provide to us or obtain from our website. You use the website at your own risk.

For information on how to report security issues, matters, or potential incidents to Miyuan Group and its information security team, please contact us anytime at 【enquiry@siic.com】. In the event of a personal information security incident, we will notify you and report to regulatory authorities in accordance with legal requirements.

We will retain your personal data for the period necessary to fulfill the purposes described in this Policy, unless an extended retention period is required or permitted by law. Since storage periods may vary depending on different scenarios and the products and services involved, the criteria we use to determine retention periods include: the time needed to fulfill the business purpose, respond to possible user inquiries or complaints, troubleshoot issues; whether the user consents to a longer retention period; and any special legal or contractual retention requirements.

6. How Miyuan Group Handles Children’s Personal Data

6.1. Our services on the Miyuan Group website are primarily intended for adults. If you are a minor, we require that you have your parents or other guardians carefully read this Policy and obtain their consent before using our services or providing us with information.
6.2. Please be aware and understand that during the real-name verification process, if we identify that you are a child under the age of 14, we may refuse to provide certification services to you.
6.3. Due to current technology and business models, it is difficult for us to proactively identify minors’ personal information during account registration. If you are a guardian of a minor and discover that we have obtained personal information of minors without authorization, you may contact us through the contact information listed in Article 10 of this Policy. Upon receipt of the notification, we will promptly investigate and, if verified, promptly delete or anonymize the relevant information. If we proactively discover such situations during our review, we will also delete or anonymize the relevant personal information accordingly.

7. Third-Party Providers and Their Services

To ensure a smooth browsing experience, you may receive content or web links from third parties (hereinafter referred to as “Third Parties”) outside of Miyuan Group and its partners. Miyuan Group does not control such third parties. You may choose whether or not to visit links, content, products, and services provided by third parties.
Miyuan Group cannot control the privacy and data protection statements of third parties, and such third parties are not bound by this Policy. Before submitting personal information to third parties, please review their privacy statements.

8. How Your Personal Data is Transferred Globally

Miyuan Group is a global company. Where permitted by law, we may share your personal information within Miyuan Group (including subsidiaries, affiliates, and parent companies) or with our suppliers and business partners, and may transfer such information to other countries or regions where we operate. Additionally, because we may not have data storage centers in your country, your personal data may be transferred to data centers outside your country for storage. In such cases, Miyuan Group will take measures to ensure that the data we collect is processed in accordance with this Policy and applicable laws.

Including where personal data of data subjects in the European Union is transferred to countries or regions not recognized by the EU as having an equivalent level of data protection, Miyuan Group will use various legal mechanisms, such as signing the EU Commission’s approved Standard Contractual Clauses or obtaining your consent for cross-border transfer of personal data, or implementing data anonymization and other security measures before cross-border data transfer.

9. How This Policy Is Updated

Miyuan Group reserves the right to update or modify this Policy from time to time. If our privacy statement changes, we will post the latest version here. If we make significant changes to the privacy statement, we may also notify you through different channels, such as posting a notice on our website. Where required by applicable data protection laws, we will seek your consent for any major changes affecting how we use your personal information. We recommend that you regularly review this page to stay informed about our latest privacy practices.

9.1 Significant changes referred to in this Policy include:
9.1.1 Significant changes in our service model, such as changes in the purpose of processing user information, types of user information processed, or how user information is used;
9.1.2 Significant changes in control, organizational structure, such as ownership changes caused by business adjustments, bankruptcy, or mergers and acquisitions;
9.1.3 Changes in the main recipients of user information sharing, transfer, or public disclosure;
9.1.4 Significant changes in your rights to participate in the processing of user information and how those rights are exercised.

10. How to Contact Miyuan Group

If you have any questions, comments, or suggestions, please contact us by email at: 【waimao@miyuan.com】. We will respond within fifteen business days. If you are not satisfied, you may also file a complaint through the following channels.

When Miyuan Group processes your personal data in accordance with this Privacy Policy, the Miyuan Group entity responding to your requests, contacting you, providing products or services to you, or entering into or about to enter into a contract with you is the data controller of your personal data.

Last Updated: October 2024