1.1 This Privacy Policy explains how Shenzhen Baoguo Intelligent Technologies Co.,Ltd. along with its affiliates (herein after referred to as “we”, “us” or “Baoguo”), collects, uses, shares, transfers and protects the personal information of the user (hereinafter referred to as “you”) and the corresponding rights of the user. Personal information refers to any information related to a natural person that has been identified or is identifiable. Please let us know if you have any questions.

1.2 This Privacy Policy shall apply to platforms on which it is displayed, including but not limit to the Baoguo site, products, and services, and other platforms which link to this Privacy Policy. If this Privacy Policy does not cover certain specific personal information processing scenarios, we will explain it to you in the form of supplementary policies or pop-up windows.

1.3 We may process your personal information in different scenarios based on different legal reasons, such as performing contracts and providing products and/or services to you, based on legitimate business interests or with your prior consent.

In any scenario in which you interact with us, we are likely to ask you to provide personal information. If you do not provide the relevant information, you may not be able to achieve the specific purpose for a particular scenario. For example, you cannot purchase a Baoguo product; our call center cannot reach you and provide you with pre-sales and after-sales service; or you cannot download updated software systems and/or applications. Here are some of the scenarios where we may collect your personal information:

2.1 When you register for an account and purchase a Baoguo product, you may provide relevant personal information, such as user name, gender, phone number, email, mailing address, zip code, consignee information, method of payment and bank account information, etc.

2.2 Where permitted by law, Baoguo may also obtain data about you from third-party sources. For example, when you use a third-party network account to register for an account in Baoguo or login to our website, Baoguo may obtain your account information from a third-party network service company. Depending on your choice of third-party network account, we may collect your Twitter account, Instagram account, Facebook or Google account information. In such case, only the account information will be obtained.

2.3 When you activate and use a Baoguo product, we may also collect information about your device or software, such as device name and model, device ID (such as IMEI and SN), operating system version number, language selected for the device, time zone, information of SIM card telecom operator, serious error log of system and other information.

2.4 Network information: for example, the type and version of browser used when you login to the Baoguo online store, language, OS version, resolution, website operating elements, your web IP address and web browsing information, as well as user behavior and other information collected by Baoguo through cookies and other similar technologies.

2.5 Location information: real-time information from you or other users, including your geographic location, such as the region contained in the account information you have provided; country information displayed by the telecommunications carrier code you use. Some pre-loaded, location service-based apps such as maps, navigation and weather service apps will collect your location information with your consent.

2.6 When you call our customer service center for assistance, we may ask for your name, phone number, product information and receiving time, and record your number of calls, date of call, problem encountered and the solution we give to you.

2.7 If you participate in one of Baoguo offline product experience events, we may also ask for information such as your name, gender, email address, and phone number.

Baoguo will use your personal information based on the following legitimate purposes. One or more purposes may be applied at the same time. If we use your personal information beyond the following purposes or the scope allowed by the law, we will obtain your consent again on the basis of special purpose needs.

3.1 Used for authentication, security, fraud monitoring, archiving and backup purposes to ensure the security of products and services provided to you by Baoguo.

3.2 Provide you with services such as order processing; receipt and delivery of goods; refund of payment for goods; after-sales maintenance; implementation of electronic security plans; push system upgrade information, and other similar purposes.

3.3 Help Baoguo to improve products and services. For example, Baoguo will analyze and study the collected data to make user-friendly adjustments to its operating system and interface design in accordance with user characteristics. When you choose to send error details to Baoguo, Baoguo can modify the software according to the specific error information, which helps to ensure that the similar software errors will not happen again.

3.4 Baoguo may know about the regional distribution of Baoguo products through the receiving address of the user and the country in which the SIM card operator is located, and adjust our after-sales service network layout, personnel, language and other details, so as to make it easier for users to purchase Baoguo products and experience Baoguo services.

3.5 With your consent, Baoguo may send you our latest product and service information, and may also send you holiday greetings. You may choose to unsubscribe at any time if you do not wish to receive such information.

3.6 Description of services based on location information: some pre-loaded apps in Baoguo mobile phones provide services based on the user's precise or unique geographic location, such as maps, navigation and weather services. These services are provided by third parties independent of Baoguo. Therefore, your personal information, including your location, will be collected and processed by third parties and not controlled and processed by Baoguo. You can choose to turn off location-based services and refuse to share location information.

4.1 In order to ensure that the website works well, Baoguo will use cookies and similar technologies such as pixel tags and website beacons. Cookies are plain text files that are stored on a computer or mobile device by web server. The content of cookies can only be retrieved or read by the server that creates it. Each cookie is unique to your web browser or mobile app. Cookies usually contains some identifiers, commonly-used information and other details. For instance, you can reduce the number of login authentications needed and improve your experience through cookies technology when browsing different web pages of Baoguo website. Otherwise, you may not be identified as the same person and may be asked to enter the authentication information again if logging onto to Baoguo website and then be required to go to another web page of Baoguo website.

4.2 These technologies help Baoguo and third parties to better understand user behavior, tells Baoguo which section of Baoguo website you have browsed, and measure and improve the effectiveness of Baoguo’s services. Baoguo will not use cookies for any purposes other than as described in this policy. You can manage or delete cookies based on your own preferences. However, please note that some Baoguo services may be designed to require the use of cookies and disabling cookies may affect your rights to use these services or some of these features.

4.3 In addition to cookies, Baoguo also uses other similar technologies such as local storage, web beacons, and pixel tags on its website. Like local storage of HTML5, this can cache frequently-used data related to you so that such data can be rendered to you quickly when you switch between different web pages of the Baoguo website. For another example, an email sent to you may contain a click URL linked to the content of the website. If you click on the link, this click will be tracked to help Baoguo better understand your product and service preferences and improve customer service. Web beacons are usually transparent images embedded in websites or e-mails. With the help of the pixel tags in emails, Baoguo can know whether the email content is effectively served to the user.

5.1 We may disclose your personal information between affiliates or subsidiaries and ensure that the same level of protection is provided for your personal information between affiliates and subsidiaries.

5.2 In addition, Baoguo may disclose your information to public authorities with jurisdiction over the territories in which we operate to provide personal information of our users in compliance with the law or in the performance of legal procedure.

5.3 In any case of sharing your personal information with third parties, we endeavor to disclose it to such third parties only to the extent permitted by law and we require data recipients to process and protect your personal information in compliance with applicable laws and regulations.

5.4 Baoguo promises not to sell personal data to any third party and guarantees the legitimate and fair use of user information only to the extent permitted by law.

6.1 Baoguo will do its utmost to take the appropriate technical measures to ensure that you can access, update, correct and delete your own registration information or other personal information provided when using Baoguo services. When you access, update, correct and delete the aforementioned information, you may be asked for authentication to protect the information security.

6.2 You can control your own personal information. For example, you can turn off the location sharing button to stop sharing your device's location information, or you can revoke prior consent for data collection and processing. However, please understand that once you make above choice, you may not be able to enjoy the related services.

6.3 Wherever required, you can contact us through contact information provided in this Privacy Policy. If we have a reasonable basis to believe that your request is fraudulent and/or cannot be verified, or certain personal data rights are not stipulated by law in your country and region, we will reject your request.

7.1 Baoguo only retains your personal information for the time period necessary for the purposes described in this Privacy Policy and as required by applicable laws and regulations.

7.2 Baoguo uses various management policies (such as establishing information security system; signing a confidentiality agreements with information management employees; allowing only work-related employees to access the information collected; and other similar policies) and security techniques and procedures (such as entering passwords before access, access control isolation, monitoring for computer use, etc.) to prevent the loss of information, improper use, and unauthorized reading or disclosure. For example, in some services, Baoguo uses encryption technology (such as SSL) to protect the personal information you provide. However, please understand that due to technical limitations and possible malicious means, it is impossible for any company providing Internet-related services to guarantee 100% security of information, even if all efforts are made to strengthen security measures. You need to understand that the systems and communication networks you use to access Baoguo services may be subject to problems that are beyond Baoguo’s control.

7.3 If Baoguo is informed that the security of the data it has acquired and stored is compromised or the user's nonpublic information is disclosed to an unrelated third party due to external acts (such as hacker attack), Baoguo will take reasonable actions (including but not limited to internal investigations, reporting and notification to law enforcement agencies, and cooperation with the law enforcement agencies) as it may consider appropriate, notwithstanding any disclaimer in this Policy. In parallel, Baoguo will take legal and reasonable steps as it deems appropriate to notify the relevant users, informing them of the information disclosed and the extent to which we are aware of such situations.

7.4 Data cross-border transfer: your personal information may be transmitted and transferred across borders (regions), and stored and processed in the target country (region). Depending on the laws in your country and region, the receiving country and region of these data may not meet the requirements. We promise that we will have the right security measures to ensure that the protection level of data can meet the full requirements of the laws and regulations of your country and region.

8.1 Our products and services are primarily designed for adults. Anyone who is identified to be a minor customer under the laws of the country in which (s)he is located must obtain the consent of his or her parents or guardians before using our products and services upon purchase.

8.2 We value the privacy protection of minors and encourage parents to always play an active role in their child's online experience.

9.1 This Privacy Policy does not apply to products and services provided by third parties. Baoguo products and services may include products and services from third parties, as well as links to third-party websites. When you use these third party products or services and personal information is collected and/or processed, the privacy policy of the third party shall apply.

9.2 We are not responsible for how third parties collect, use, share, transfer and protect user's personal information, and cannot control how it is processed.

9.3 To avoid any misunderstandings, please refer to this third party's service agreement and read its privacy policy.

10.1 We may amend or update this Privacy Policy from time to time. You will be able to see our last updated privacy policy, along with its revision date. The revised privacy policy will take effect from the date of publication. Please check the Privacy Policy from time to time to confirm whether we have made any changes with reference to use of personal information.

10.2 If any changes to this Privacy Policy have a material impact on your rights, we will take reasonable steps to notify you of such changes.

11.1 Any notice from Baoguo will be sent to the email address, phone number, and/or mailing address left when you register for an account or purchase of Baoguo product, or pushed directly through mobile phone system. If sent via electornic methods, notice shall be deemed served when your device or the used electronic system receives the message;

if sent by courier, it shall be deemed served on the third day after sending out.

If you have any questions, comments, suggestions or doubts about this Privacy Policy or our products, please feel free to give us a feedback. Our contact:

Mailing Address:service@baoguogroup.com 4F, Zhongzheng Fortune Building, No.6093 Bao’an Ave, Bao’an District, Shenzhen, 518000, P.R. China

Tel.: +86-755-88828256

Last updated: May 2018 Last updated: May 2018