Horry Technologies Ltd. and its affiliates around the world (“Horry,” “we,” “us,” and “our”) recognize that privacy is important to you and will respect your privacy. Please read and understand this Privacy Policy (this “Policy”) before submitting personal information to Horry. This Policy applies to Horry's websites and products and services that display this Privacy Policy or link to it. In particular, the Website is operated by Horry Technology Limited (with its registered office in Bantian, Longgang District, Shenzhen, China), which is the personal information processor of the personal information collected on the Website.

This policy sets out how Horry processes your personal information, but this policy may not address all possible data processing scenarios. Information regarding the collection of product- or service-specific data may be set forth by Horry in specialized privacy notices or supplemental statements issued for specific products or services, or in notices provided at the time of data collection.

We have created this Policy to help you understand the following:

1. How Horry collects and uses your personal information

2. how Horry uses cookies and similar technologies

3. how Horry discloses your personal information

4. Your Rights in Personal Information Processing Activities

5. How Horry Protects Your Personal Information

6. how Horry handles children's personal information

7. Third-Party Providers and Their Services

8. How Your Personal Information is Transferred Worldwide

9. How This Policy Can Be Updated

10. how to contact Horry

1. How Horry Collects and Uses Your Personal Information

1.1 How Horry Collects Your Personal Information

Personal information refers to all kinds of information recorded electronically or otherwise about an identified or identifiable natural person, excluding anonymized information. We may collect personal information from you when you use Horry products and services or interact with us. The specific types of data collected will vary depending on the products and services you use and your interactions with us. You are not required to provide personal information to Horry, but in some cases, if you choose not to do so, Horry may not be able to provide you with the relevant products or services, or respond to or resolve the issues you have encountered.Horry will collect and use your personal information only for the purposes set out in this statement, and the personal information we may collect includes:

1.1.1 Information you provide to Horry

(1) Account registration information. When registering for an account, we will ask you to provide the appropriate personal information, including your name, account number, password, e-mail address, contact number, etc.

(2) Personal contact information. When you contact us, give us comments, suggestions or inquiries, participate in our online and offline activities, subscribe to marketing materials, etc., you may leave your contact information, including your name, company name, position, email address, phone number and so on.

1.1.2 Information obtained in the course of your interaction with us or use of our products and services

(1) Device and Network Information. We collect information about your device when you use Horry's products and services, such as device type, device name or model number, device identifier, operating system type and version, browser type and version, screen resolution, language settings, IP address, network service provider, and other technical information that varies by product.

(2) Interaction log information. This type of information will be submitted by you directly to us when you use our website, products or services, and interact with us. Examples include requests for information that you provide to us, including inquiries that you enter or questions or information that you provide for customer service support. Records of your communications online or by phone, email, participation in online and offline activities, etc. 

(3) Log information. When you use Horry's products and services or view content provided by Horry, Horry automatically collects and stores necessary log information, such as the time of each access to the Services, the path of the page accessed, the IP address of the client, and information about events (such as errors, crashes, reboots, upgrades, etc.).

1.1.3 Third Party Source Information and Public Information

As permitted by law, we also obtain relevant data from public and commercial third parties or public sources, for example, by purchasing statistical data from other companies to support our services.

Horry may also collect and use non-identifying data. Non-identifying data is data that cannot be used to identify an individual. For example, Horry collects aggregated statistics, such as the number of visits to a website.Horry collects this data in order to understand how users use its website, products and services. By doing so, Horry can improve its services and better meet the needs of its customers.Horry may, in its sole discretion, collect, use, process, transfer or disclose non-identifying data for other purposes. We make every effort to segregate your Personal Information from Non-Identifying Data and to use the two types of data separately. If Personal Information is mixed with Non-Identifying Data, it will still be treated as Personal Information.

1.2 How Horry uses your personal information

We may use your personal information for the following purposes:

(1) Create an account. Customers interested in Horry products and services may create a Horry account. This account will allow us to authenticate you when you use Horry products and services, manage your rights to protect the security of the products and services, contact you, and send you important notices. In order to create an account, we collect the personal information you provide to us, including the name, account number, password, e-mail address, contact number, country or region you enter.

(2) Responding to your requests for interaction. We collect the following information from you when you visit our website, participate in an online or offline event, request changes or ask for information you have requested (e.g., marketing materials for products or services, white papers, subscriptions to e-zines), and when you contact us with any questions or product information (e.g., to provide technical support, to provide us with comments, suggestions, inquiries, etc.):

(3) To recommend relevant content, products or services for you. With your consent, to send you information about products and services that may be of interest to you; to invite you to participate in Horry activities (including promotions), market research or satisfaction surveys; or to provide you with personalized content and services when you visit online platforms, such as websites and apps. We will collect the following information from you:

If you do not want to receive such information, you can unsubscribe at any time by following the SMS alerts or other means provided by us.

(4) Other cases:

· Troubleshooting errors where you choose to send us details of the error.

· To protect the security of our products, services and customers or users and to implement and improve our loss prevention and anti-fraud programs.

· To comply with and enforce applicable legal requirements, relevant industry standards or our policies.

For these purposes, we may collect the following information from you:

2. How Horry uses cookies and similar technologies

2.1 Cookies

To ensure that our websites work properly, we sometimes store small data files on your computer or mobile device called cookies, which are plain text files that are stored on your computer or mobile device by a web server.The contents of a cookie can only be retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile application. cookies usually contain an identifier, the name of the site, and some numbers and characters. Cookies enable websites to store data such as user preferences or items in a shopping basket.

Horry enables cookies for the same reason that most websites or internet service providers enable cookies, to improve the user experience. With the help of cookies, websites are able to remember a user's single visit (using session cookies) or multiple visits (using persistent cookies). Cookies enable websites to save settings such as the language of the computer or mobile device, font size and other browsing preferences. This means that users do not have to reconfigure their preferences each time they visit. If a website does not use cookies, it treats a user as a new visitor every time they open a web page. For example, if you log on to a site and then go to another page, the site will not recognize you and you will be logged off again. Horry 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 stored on your computer and most web browsers have the ability to block cookies. However, if you do so, you will need to change your user settings personally each time you visit our website.

2.2 Web beacons and pixel tags

In addition to cookies, we use other similar technologies such as web beacons and pixel tags on our websites. For example, emails sent to you by Horry may contain a click-through URL that links to content on Horry's websites, and if you click on the link, Horry tracks the click to help us understand your product and service preferences and improve customer service. Web beacons are typically a transparent image embedded on a website or in an email. Pixel tags in emails allow us to know if an email has been opened. If you do not want your activity to be tracked in this way, you can unsubscribe from Horry's mailing list at any time.

Your use of our website means that you agree to the use of cookies, web beacons and pixel tags as described above.

3. How Horry discloses your personal information

Horry will not normally disclose your personal information to outside parties, except in the following circumstances:

(1) Where certain services are provided by an authorized partner of Horry, Horry may share your personal information with that partner as described in this Policy. For example, where a partner is engaged to handle hotlines, send emails, provide technical support, etc. on behalf of Horry, we will require the partner to use your personal information only to provide services to you on behalf of Horry;

(2) We may disclose personal information among Horry's affiliates, and we will only disclose your information within Horry's affiliates for specific, explicit, and lawful purposes, and only to the extent necessary to provide the service. For example, in order to avoid duplicate registrations when registering for a Horry account, we are required to verify the uniqueness of the account to be registered;

(3) Horry may also disclose your personal information to relevant law enforcement or other governmental authorities if required to do so by applicable law or in response to legal process. In some jurisdictions, your personal information may also be disclosed to counterparties if Horry is involved in a reorganization, merger or bankruptcy and liquidation proceeding.

(4) Horry will also disclose your data where there is a legitimate need to do so, for example, in order to perform a contract and where we believe that disclosure is necessary and appropriate to prevent physical harm or damage to property or to investigate possible or actual unlawful conduct.

4. Your rights in personal information processing activities

You should ensure that all personal information you submit is accurate, and Horry endeavors to maintain the accuracy and integrity of personal information and to keep this data up to date.

Where required by applicable law, you may (1) have the right to access and copy specific personal information we hold about you; (2) require us to update or correct your inaccurate personal information; (3) refuse or restrict our use of your personal information; (4) require us to delete your personal information; and (5) require us to provide explanatory notes on the rules governing the processing of personal information. If you would like to exercise the relevant rights, please click here to give us online feedback. For security purposes, you may be required to provide a written request. We may ask to verify your personal identity in accordance with local law. We may refuse to process requests if we have a reasonable basis to believe that they are fraudulent, unenforceable, or otherwise detrimental to the privacy rights of others.

You also have the right to withdraw your consent at any time when Horry processes your personal information based on your consent, where required by applicable law. However, revocation of consent will not affect the legality and validity of our processing of your personal information based on your consent prior to such revocation, nor will it affect our processing of your personal information based on any other appropriate basis of legitimacy.

5. How Horry protects and retains your personal information

Horry takes the security of personal information seriously. We use appropriate physical, managerial and technical safeguards to protect your personal information from unauthorized access, disclosure, use, modification, damage or loss. For example, we use encryption technology to ensure the confidentiality of data; we use protection mechanisms to prevent malicious attacks on data; we deploy access control mechanisms to ensure that only authorized personnel have access to personal information; and we conduct security and privacy training sessions to enhance employee awareness of the importance of protecting personal information. While we endeavor to protect your personal information, please note that no security measure can be invulnerable.

We will retain your personal information for as long as necessary to fulfill the purposes described in this policy, unless an extension of the retention period is required or permitted by law or permitted by law. Because the data storage period may vary based on different scenarios and different products and services, the criteria we use to determine the retention period include: the period of time for which personal information is required to fulfill the business purpose, including providing products and services, maintaining corresponding transaction and business records, controlling and improving the performance and quality of the products and services, ensuring the security of the system, products and services, responding to possible inquiries or complaints from users, locating problems, etc.; whether the user is aware of any problems; and whether the user's personal information will be retained for the period of time required to fulfill the purposes described in this policy. complaints, problem localization, etc.; whether the user agrees to a longer retention period; whether there are special requirements for retaining data by law, contract, etc., etc. We will retain your registration information as long as your account is necessary to provide you with the service. You can also choose to cancel your account. After you cancel your account, we will stop providing products and services based on that account and delete or anonymize your corresponding personal information without special legal requirements.

6. How Horry handles children's personal information

Our products, websites and services are primarily intended for adults. Children (minors under the age of 14) may not create their own user accounts without parental or guardian consent. In the event that personal information about a child is collected with parental consent, we will only use or disclose this data as permitted by law, with the express consent of the parent or guardian, or as necessary to protect the child. If Horry becomes aware that it has collected personal information from a child without first obtaining verifiable parental consent, it will attempt to delete the data as quickly as possible.

7. Third party providers and their services

In order to ensure a smooth browsing experience, you may receive content or web links from third parties external to Horry and its partners (hereinafter referred to as “Third Parties”), over which Horry has no control. Horry has no control over such Third Parties. It is your choice whether or not to access the links, content, products and services provided by Third Parties.

Horry has no control over the privacy and data protection policies of Third Parties and such Third Parties are not bound by this Policy. Please refer to the privacy policies of such third parties before submitting your Personal Information to them.

8. How your personal information is transferred globally

Horry is a multinational company, which means that your personal information collected by Horry may be processed in, or accessed from, the country in which you use the product or service, in other countries in which Horry or its affiliates, subsidiaries, or service providers, or business partners have facilities. These countries may have different data protection laws. In such cases, Horry will take steps to ensure that the data we collect is processed in accordance with this Policy and the requirements of applicable law. This includes when personal data of data subjects located in the European Union is transferred to a country or territory that is not recognized by the European Union as having an equivalent level of data protection, Horry may use legal mechanisms such as signing standard contractual clauses approved by the European Commission or requesting your consent for cross-border transfers of personal data or implementing security initiatives such as data anonymization prior to a cross-border data transfer. You can obtain a copy of the EU Standard Contractual Clauses by clicking here. Personal information collected and processed in connection with our operations in the People's Republic of China will be stored in the People's Republic of China.

9. How this policy may be updated

Horry reserves the right to update or modify this policy from time to time. If our Privacy Policy changes, we will post the latest version of the Privacy Policy here. If we make material changes to our Privacy Policy, we may also send you notice of the changes through various channels, for example, by posting a notice on our website or by sending you a separate notice.

10. How to Contact Horry

If you have a privacy complaint or question to contact Horry's Data Protection Officer, we will normally respond within fifteen working days. If you are not satisfied with our response, especially if our personal information processing practices harm your legitimate rights and interests, you may also file a complaint or report with the regulatory authorities such as Netcom, Telecom, Public Security and Industry and Commerce.

Last Updated: May 2024