This policy applies only to the Procinsta co., LTD and its associated products and services provided by the company and its extended functions (hereinafter referred to as the Procinsta service), including but not limited to the Procinsta and associated company APP website public number small programs and provide you with a new form by the development of technology in all kinds of products and services If a certain product provided by us has a separate privacy policy or special provisions in the corresponding user service agreement, the privacy policy of the product will be preferentially applied; The contents not covered by the privacy policy and user service Agreement of this product shall be subject to this policy. Please read the Procinsta Privacy Policy carefully (especially in bold) and be sure to understand our rules for handling your personal information. During the reading process, if you have any questions, please contact us through the “Procinsta Privacy Policy”.

Version effective date: July 2, 2024

If you have any questions, comments, or suggestions, you can contact us through the following contact information: email address:support@procinsta.com

Introduction

Welcome to choose Procinsta! We are an Internet high-tech manufacturing enterprise with a major business position in mainland China. Our business scope is mainly CNC precision machining mold manufacturing and sheet metal processing of injection molding products. We attach great importance to the protection of users’ privacy and personal information. We may collect and use your information when you use our products and/or services. We wish to explain to you through the Procinsta Privacy Policy (this Privacy Policy) how we collect, use, save, share and transfer such information when you use our products and/or services, and how we provide you with access, update, deletion and protection of such information. We encourage you to carefully read and confirm that you have fully understood the contents of this Privacy Policy before using our products and/or services, and allow you to make the appropriate choices in accordance with the guidelines of this Privacy Policy.

This Privacy Policy is closely related to the Procinsta services you use and various business functions included in the services (hereinafter collectively referred to as our products and/or services). We try to express the terms concisely involved in this privacy Policy and provide links for a further explanation so that you can better understand them.

Please pay special attention to it: This Privacy Policy applies to the products or services provided by the Procinsta. If the products or services provided by the Procinsta are used in the products or services of our affiliated companies but no independent privacy policy is set, this Privacy Policy also applies to those products or services.

Affiliates refer to one party now or in the future controlling controlled or under common control with any agencies as well as the control is to point to the legal representative of the company or organization, directly or indirectly, affects the ability of the mentioned company management, whether through ownership of voting shares a contract or other decided by a people’s court.

I. How do we collect and use your Personal Information

Personal information in electronic or other ways to record and the identified or identifiable natural person information, not including anonymizing sensitive personal information is processed information once a leak or illegal use, easily lead to a natural person harm human dignity or personal property safety hazards of personal information, including biometric health of religion Location, track, specific identity, financial account, address, and other information, as well as personal information of minors under the age of 14 (Sensitive personal information involved in this policy will be prominently identified in bold). We will collect and use your personal information voluntarily provided or generated by your use of products and/or Services and obtain your personal information from third parties for the following purposes as described in this Policy in accordance with the principles of justice, legality, and necessity. If we use your Personal Information for other purposes not specified in this Policy or use the information collected for a specific purpose, we will reasonably notify you and obtain your consent again before using it.

(I) Circumstances under which you authorize us to collect and use your personal information

Our products and/or services include a number of core functions, which include the functions necessary to realize online customized ordering, submission of requirements, feedback of quotations, and the functions necessary to ensure the security of transactions. We may collect, save and use the following information related to you to achieve these functions. If you do not provide relevant information, you will not be able to enjoy our products and/or services. These features include:

1. Realize the necessary functions of online customized ordering

(1) Account registration, login, and verification

When you register your Procinsta account, you need to at least provide us with your Procinsta account name, password, your mobile phone number or email, and other contact information. We will verify your identity by sending an SMS verification code. You can modify and supplement your nickname, company name, position, contact number, birthday, and other information, which belong to your “Account Information”. Your additional account information will help us provide you with a better shopping experience, but if you do not provide such additional information, it will not affect your use of the basic functions of online shopping.

(2) Automatic quotation

When you use the automatic quotation system to obtain a commodity quotation, you need to upload your model file information , we will collect your drawing information, but will not disclose it to the irrelevant third party.

(3) Ordering and order management

You need to fill in at least your consignee’s name, consignee’s mobile phone number, and delivery address in the order. At the same time, the order number, customized service you purchased, order time, amount, and payment method will be specified in the order. If you need to issue invoices, you also need to provide the invoice title, taxpayer identification number, and other necessary information for issuing invoices. If you need to provide electronic invoices, you need to provide the email address for receiving invoices.

You need to fill in at least your consignee’s name, consignee’s mobile phone number, and delivery address in the order. At the same time, the order number, customized service you purchased, order time, amount, and payment method will be specified in the order. If you need to issue invoices, you also need to provide the invoice title, taxpayer identification number, and other necessary information for issuing invoices. If you need to provide electronic invoices, you need to provide the email address for receiving invoices.

All the above information constitutes your “Order Information”, and we will use your order information to verify your identity, confirm transactions, pay and settle payments, complete delivery, query orders for you, and provide after-sales services. We will also use your order information to determine whether there is an anomaly in your transaction to protect the security of your transaction.

(4) Payment function

After placing an order, you may choose payment services provided by affiliated parties of Procinsta or third-party payment institutions cooperating with Procinsta (including Convergence Pay (Alipay pay, WeChat Pay), Paypal and other payment channels, hereinafter referred to as “Payment institutions”). Pay the function itself does not collect your personal information, but we need to put your Procinsta order number and transaction information, including your bank card number, validity, and payments, bank card (debit card, credit card) pay the necessary information to share with these institutions in order to realize its confirm your payment instructions and complete the payment, And the amount information of the account you have opened and recharged the balance of the Procinsta, so that you can normally use the recharge function.

(5) Deliver product and/or service functions

After you place an order and complete the payment, the third-party delivery company (hereinafter referred to as the “Delivery Company”) will complete the delivery of your order for you. You understand and agree that Procinsta, its affiliates, partners, and distribution companies will use your order information in the above links to ensure the safe delivery of your ordered goods.

(6) Customer service and after-sales functions

Your account information and order information will be used by our telephone customer service and after-sales functions. To ensure the security of your account, our customer service will use your account information to verify your identity with you. When you need us to provide customer service and after-sales service related to your order information, we will check your order information. You may provide other information other than the above information when communicating with our customer service personnel, such as when you ask us to change the delivery address, contact person, or contact number. If you are in return when the freight that produces may apply for by freight insurance service provider to undertake compensate, in order to realize protect and settle a claim, we will collect or inquire the quality objection that you buy goods start and end period, return goods express company of change goods, express bill number, return address, delivery time wait for necessary information.

2.Necessary functions to ensure transaction security

In order to ensure the stability and security of our system when you use our products and/or services, prevent your personal information from being illegally obtained, prevent fraud and protect account security more accurately, we need to collect your device information (operating system and software version), IP address and order information; We will also collect your equipment information for Procinsta of plant system problems, traffic statistics, and possible risks, and check when you choose to send abnormal information to us. If you do not provide the above information, we will not be able to protect the security of your service and account when you use the Procinsta service.

(II) Circumstances in which you have the freedom to choose the personal information to provide

1.In order to make your shopping more convenient or fun, and thus improve your online shopping experience in the Procinsta, we may collect and use your personal information in the following extended functions. If you do not provide this personal information, you can still make online purchases, but you may not be able to use the extended features that make shopping fun for you or you may need to fill in some information repeatedly when purchasing certain items. These extensions include:

(1) Extension function based on camera: You can use this extension function to take photos and videos of the received products and share pictures.

(2) Extended functions based on picture/video uploading: You can upload your photos in the Procinsta to realize the function of uploading quotation, Posting list, and evaluation. We will use the Posting list, evaluation, and question and answer content containing your uploaded pictures.

(3) Based on read/write to the expansion of the external memory function: when you open we can read/write after the permissions you equipment store, we will provide you equipment storage space to read or to write images, text, the collapse of the cache, necessary information, such as log information is used to improve the information to you or in the local log information, cache, and other functions, guarantee the stable operation of the application.

2. When you use the “Invite friends” function, we will send the invitation information to the email address provided by you in your name, using your name. You need to ensure that the email address provided is legally obtained and does not infringe the rights and interests of the invitee.

3. We will push the order status, logistics information, and discount information to the mailbox you use for registration. If you need to withdraw the above functions, you can contact the customer service personnel to cancel the corresponding push.

(III) You are fully aware that we do not need your authorization to collect and use personal information under the following circumstances:

1. Related to national security and national defense security;

2. Those related to public security, public health, or major public interests;

3. Those related to criminal investigation, prosecution, trial, and execution of judgment;

4. For the purpose of safeguarding the life, property, and other important legal rights and interests of the subject of personal information or other individuals, but it is difficult to obtain the consent of the subject;

5. The collected personal information is disclosed to the public by the subject or guardian of personal information;

6. Collect your personal information from legally publicly disclosed information, such as legal news reports, government information disclosure, and other channels;

7. Necessary to sign the contract according to your requirements;

8. Necessary to maintain the safe and stable operation of the provided products and/or services, such as finding and disposing of faults of the products and/or services;

9. Necessary for legitimate news reporting;

10. When academic research institutions carry out statistical or academic research necessary for the public interest and provide the results of academic research or description to the public, they de-label the personal information contained in the results;

11. Other circumstances stipulated by laws and regulations.

(IV) Rules for the use of your personal information

1. We will use the personal information collected in accordance with this Privacy Policy and for the purpose of realizing the functions of our products and/or services.

2. After collecting your personal information, we will de-label the data through technical means, and the de-labeled information will not be able to identify the subject. Please understand and agree that we have the right to use de-identified information in this case; on the premise of not disclosing your personal information, we have the right to analyze the user database and make commercial use of it.

3. Please understand and agree that all personal information provided by you when using our products and/or services will continue to be authorized to be used by us during your use of our products and/or services unless you delete or refuse to collect it. When you cancel your account, we will stop using and delete your personal information. For details, please refer to “Instructions for Canceling Procinsta Account” attached to this Privacy Policy.

4. We will collect statistics on the usage of our products and/or services and may share such statistics with the public or third parties to show the overall usage trend of our products and/or services. But these statistics do not contain any identifying information about you.

5. When we display your personal information, we will desensitize your information by means of content replacement and anonymous processing to protect your information security.

6. We seek your express consent when we use your Personal Information for other purposes not specified in this Privacy Policy, or when we use the information collected for a specific purpose for other purposes. Please understand that the products and/or services we provide to you are subject to constant change. If you choose to use other products and/or services not listed in this Privacy Policy, we will explain the purpose, method, and scope of information collection to you in detail and ask for your consent through agreements, page prompts, and other means before collecting your personal information. If you do not agree to provide such information, you may not be able to use the products and/or services, but this does not affect your use of existing products and/or services.

II. How do we use Cookies and similar technologies

(I) Use of Cookies

1. To realize your personalized needs for an online experience and make it easier for you to access the experience. We will send one or more small data files called Cookies on your computer or mobile device, specifying that the Cookies given to you are unique and can only be read by the Web server in the domain that issued the Cookies to you. We send Cookies to you to simplify your repeated login steps, store your shopping preferences or products in your shopping cart and other data to provide you with shopping preference Settings, help you optimize the selection and interaction of advertisements, and help judge your login status and account or data security.

2. We will not use Cookies for any purpose other than those stated in this Privacy Policy. You can manage or delete Cookies according to your preference. You can clear all Cookies saved on your computer. Most Web browsers automatically accept Cookies, but you can usually modify your browser Settings to reject Cookies as you see fit. In addition, you can also clear all Cookies saved in the software. However, if you do this, you may need to personally change the user Settings every time you visit the Procinsta website, and any information you have previously recorded will be deleted, which may have an impact on the security of the services you use.

(II) The use of network Beacon and similar technologies In addition to Cookies, we also use web beacons and other similar technologies on our sites. Our web pages often contain electronic images (called “single-pixel” GIFs or “web beacons”). We use Web Beacon in the following ways:

1. Calculate the number of users’ visits by using network Beacon on the website of Procinsta, and identify registered Procinsta users by accessing Cookies.

2. Provide personalized services for you through the Cookies information obtained.

III. How do we share, transfer and publicly disclose your Personal Information

(I) Sharing

1. We will not share your personal information with any company, organization, or individual other than Procinsta and its affiliated companies, except for the following:

(1) Obtain your explicit consent or authorization in advance;

(2) In accordance with applicable laws and regulations, the requirements of legal procedures, mandatory administrative or judicial requirements;

(3) To the extent permitted by laws and regulations, it is necessary to protect the Procinsta, its affiliated parties or partners, you or other future users of the factory or the public from damage, property, or safety;

(4) Only by sharing your personal information can we realize the core functions of our products and/or services or provide the services you need;

(5) Handle disputes or disputes between you and others as required;

(6) In accordance with relevant agreements signed with you (including electronic agreements signed online and corresponding platform rules) or other legal documents;

(7) Use based on academic research; (8) Based on the social public interest in accordance with laws and regulations.

2. In order to provide you with relevant products or services based on the account of Procinsta, show you the content that you may be interested in, and protect the security of your account and transaction, we may share your personal information with our affiliated parties. We will share your Personal Information with our affiliates in accordance with the provisions of this Privacy Policy, but we will only share necessary personal information and be bound by the purposes stated in this Privacy Policy. If our affiliates want to change the purpose of processing personal information, they will ask for your authorization again.

3. We may share your order information and account information with partners and other third parties to ensure the smooth completion of the services provided to you. However, we will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes and will only share such personal information as is necessary to provide the services. Our partners do not have the right to use the shared personal information for any other purpose. Our partners include the following types:

(1) Suppliers of goods or professional technical services. We may share your order information and personal information with third parties that support our functions. Such support includes supplying or providing infrastructure technical services, logistics distribution services, payment services, data processing, etc. The purpose of sharing such information is to realize the core shopping functions of our products and/or services. For example, we must share your order information with logistics service providers before we can arrange delivery. When the goods or services you order are delivered or provided by the supplier directly, we need to share the ordering information and receiving information in your order with the supplier to instruct it to deliver the goods or provide the services.

(2) Partners who entrust us with promotion. Sometimes we represent other companies in providing promotional services to groups of users who use our products and/or services. We may use your personal information and non-personal information collection for your indirect user portrait and entrust us to partner (“ the client ”) to share, but we will only offer these to the promotion of information coverage and effectiveness and do not provide your personal identity information, or we will summarize this information so that it doesn’t recognize you personally. For example, we can tell the client how many people have seen their promotional information or bought their products after seeing this information or provide them with non-personally identifiable statistical information to help them understand their audience or customers.

4. We will sign strict confidentiality agreements with companies, organizations, and individuals with whom we share Personal Information, requiring them to handle personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures. In the use of sensitive personal data, we require third parties to adopt data desensitization and encryption technologies to better protect user data.

5. Exchange information with other companies and organizations in order to comply with laws, enforce or apply our conditions of use and other agreements, or to protect the rights, property, or safety of Procinsta, you or other Procinsta customers, for example, to prevent fraud or other illegal activities and reduce credit risk. However, this does not include personal information sold, rented, shared, or otherwise disclosed for profit in violation of the commitments made in this Privacy Policy.

(II) Transfer

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

1. Obtain your explicit consent or authorization in advance;

2. In accordance with applicable laws and regulations, requirements of legal procedures, mandatory administrative or judicial requirements;

3. It is provided in accordance with relevant agreements signed with you (including online electronic agreements and corresponding platform rules) or other legal documents;

4. In the case of merger, acquisition, asset transfer, or similar transaction, if the transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue to be bound by this Privacy Policy; otherwise, we will require the company or organization to ask you for authorization again.

(III) Public disclosure

We will only publicly disclose your personal information if we take industry-standard security measures:

1. According to your requirements, disclose your designated personal information in a manner that you have expressly agreed to;

2. If we are required to provide your personal information in accordance with laws, regulations, compulsory administrative law enforcement, or judicial requirements, we may publicly disclose your personal information based on the type and disclosure method of personal information required. Subject to compliance with laws and regulations, when we receive such disclosure requests, we will require the issuance of corresponding legal documents, such as subpoenas or letters of investigation. We firmly believe that we should be as transparent as the law allows about the information we are asked to provide. We carefully review all requests to ensure they have a legitimate basis and are limited to data that law enforcement has a legitimate right to obtain for specific investigative purposes. As permitted by laws and regulations, all documents disclosed by us are protected by encryption keys.

IV. How do we protect and preserve your personal Information

(I) Our technology and measures to protect your personal information

We take personal information security very seriously and take all reasonable and practicable measures to protect your personal information:

1. Data security technical measures We will adopt industry-standard security measures, including the establishment of reasonable regulations and security technologies, to prevent unauthorized access, use, and modification of your personal information, and to prevent data damage or loss. The network service of Procinsta adopts encryption technology such as transport layer security protocol and provides browsing service through HTTPS to ensure the security of user data in the process of transmission. In the future, the factory will adopt encryption technology to encrypt and save users’ personal information and isolate it through isolation technology. Procinsta adopts strict data access control and multiple identity authentication technology to protect personal information and avoid unauthorized use of data. In the future, automatic code security inspection and data access log analysis are used to audit personal information security.

2. Other security measures are taken by the Procinsta to protect personal information. The Procinsta will regulate the storage and use of personal information by establishing data classification and classification systems, data security management standards and data security development standards. The Procinsta will implement comprehensive security control over data through contact confidentiality agreements, monitoring, and audit mechanisms. In the future, the factory will establish a data security committee and set up specialized information protection departments and data security emergency response organizations to promote and safeguard personal information security. We will also conduct security and privacy training courses to enhance employees’ awareness of the importance of protecting personal information.

3. We only allow employees and partners of Procinsta and affiliated parties of Procinsta who need to know such information to access personal information, and set up a strict access control and monitoring mechanism. We also require all personnel who may have access to your personal information to fulfill the corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or termination of the partnership with the Procinsta.

4. We will take all reasonably practicable steps to ensure that no irrelevant personal information is collected.

5. The Internet is not an absolutely secure environment, and email, instant messaging, social software, and other ways of communicating with other users cannot be fully encrypted. We suggest that you use complex passwords when using such tools, and pay attention to protect your personal information. When trading online products and/or services with third parties through Procinsta, you will inevitably disclose your personal information, such as contact information or postal address, to the counterparty or potential counterparty. Please protect your personal information and only provide it to others when necessary.

6. Security incident disposal

In order to deal with the possible risks of personal information disclosure, damage and loss, Procinsta has developed a number of systems to clarify the classification and grading standards of security incidents and security vulnerabilities and the corresponding processing procedures. Procinsta has also established a special emergency response team for security incidents. In accordance with the requirements of security incident disposal specifications, safety plans are initiated for different security incidents, and loss stops, analysis, positioning, remedial measures are formulated, and source tracing and attack are carried out jointly with relevant departments. Once the occurrence of personal information security incident, we will in accordance with the requirements of laws and regulations, timely inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, you can independently prevent and reduce the risk of suggestions, remedial measures for you, etc. At the same time, we will timely inform you of the relevant information of the event by email, letter, phone, push notification, and other ways. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to announce. At the same time, we will also take the initiative to report the disposal of personal information security incidents in accordance with the requirements of regulatory authorities.

7. The Internet environment is not 100% secure and we will do our best to ensure or guarantee the security of any information you send us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, which results in damage to your legitimate rights and interests, we will bear the corresponding legal liabilities.

8. If you have any questions about the protection of our personal information, you can contact us through the contact information agreed in this Privacy Policy. If you find that your personal information is leaked, especially your account and password, please contact us through the contact information specified in this Privacy Policy [How to Contact Us] immediately, so that we can take corresponding measures.

(II) Preservation of your personal information

1. Your personal information will be stored in the People’s Republic of China. If you use cross-border transaction services and need to transfer your personal information abroad to complete the transaction, we will obtain your authorization and consent separately and require the receiving party to process such personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

2. In your use of our products and/or services, your personal information will be in order to achieve the purpose of this policy as described within the time limit of preservation, at the same time will combine with the provisions of the law that have forced retained demand period, such as the electronic commerce of the People’s Republic of China law required information goods and services, trade information saves time from the date of completed not less than three years. Your file information, we save time is not more than half a year will be deleted.

3. Please note that we will delete or anonymize your personal information after you successfully cancel your Procinsta account. When you or we assist you in deleting relevant information, due to applicable legal and security technology limitations, we may not be able to immediately remove the corresponding information from the backup system. We will securely store your personal information and limit any further processing of it until the backup can be deleted or anonymized.

4. If we terminate our services or operations, we will notify you at least 30 days in advance and delete or anonymize your personal information after we terminate our services or operations.

V. How do you manage your personal information

Procinsta attaches great importance to your concerns about personal information, and will do its best to protect your right to access, correct, delete and withdraw consent to your personal information, so that you can fully protect your privacy and security. Your rights include:

1. Access and correct your personal information

Except as provided by laws and regulations, you have the right to access and correct your personal information at any time, including:

(1) Your account information: On the PC side, you can check all your personal information submitted to the Procinsta in the “Personal Information” menu of the page of “Personal Center”, and you can also update your personal information through the above channels.

(2) Your receiving information: On the PC side, you can add, change or delete your receiving address information (including consignee name, receiving address, telephone number, or email address of consignee) at any time by visiting the “Personal Information” – “Address Management” menu of the page of “Personal Center”.

(3) Your order information: on the PC side, you can view all your orders that have been completed, to be paid, or to be sold by visiting the “My Order” page. You can delete your order information by choosing to delete the order waiting for payment.

(4) Your browsing information: You can access or clear your search history, view and modify interests, and manage other data.

(5) Your comment information: On the PC side, you can access your personal comments or make follow-up comments on the products.

(6) Your invoice information: You can access or update or clear your invoice information.

(7) If you need to access or correct any other personal information generated during the use of our products and/or services, please feel free to contact us. We will respond to your request in the manner and period specified in this Privacy Policy.

(8) You don’t have access to and correction of personal information: in addition to the above-listed information, part of the personal information we can provide you with access to and correction of the service, the information is aimed to improve your user experience and ensure the safety of transaction, you use your device information collected when extend the functionality of personal information. The above information will be used within the scope of your authorization, you cannot access and correct it, but you can contact us to delete or do anonymous processing.

2. Delete your personal information

Information that you can clear or delete directly from our products and/or services page, including order information and shipping address information. You may request us to delete your personal information under the following circumstances:

(1) If we deal with personal information in violation of laws and regulations;

(2) If we collect or use your Personal Information without your consent;

(3) If our processing of personal information violates our agreement with you;

(4) If you no longer use our products or services, or you cancel your Procinsta account;

(5) If we terminate the Services and operations. If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us to delete it in a timely manner, unless otherwise provided by laws and regulations, or these entities have obtained your independent authorization. If we respond to your delete request, we cannot guarantee that the information will be deleted from the backup system immediately, but we will delete the information when the backup system is updated.

3. Change the scope of your license or withdraw your license

You may change the scope of your authorization to continue to collect personal information or withdraw your authorization by deleting information or other means. You may also revoke all of our authorization to continue collecting your personal information by deactivating your account. Please understand that each business function requires some basic personal information to be completed. After you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawal of consent or authorization, and will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the prior processing of personal information based on your authorization.

4. Close your account

You can apply to cancel your account directly on our website; you can log out of your account by accessing the personal center on a PC. If there are still outstanding orders, you will not be able to cancel until the order is completed. After you cancel your account, we will stop providing products and/or services to you, and clear all your account information. If you need to log in again, you must register again.

5. If you do not want to accept the notification we send you, you can cancel it at any time by the following means:

(1) You can cancel the order notification information by setting whether to enable order notification on the PC account page.

(2) We will cooperate with third-party platforms or media (“ platforms ”) to recommend personalized products to you based on your personal information. This personal information includes information such as the use of products and/or services on the Site, access to the websites of affiliated companies on the Site, and interests you have entered in your Account Settings. The platform only provides us with a window to display products. The link of the window content is the personalized product display information in the Procinsta station, which is managed by Procinsta. Therefore, we will not provide any personal information of you to advertisers. And we set up a screen function in the recommendation window, you can choose to screen the advertising you do not like. If you are not willing to accept the recommendation service of the Procinsta on a single platform, please contact the platform to close it. You acknowledge and understand that the platform is a self-operated entity and that Procinsta cannot manage it.

(3) In order to protect your privacy, we will not in any way or way push to you any promotion or product information related to religious belief, sexual orientation, or other sensitive content.

6. Respond to your request

If you are unable to access, correct, or delete your Personal Information through the above means, or you need to access, correct, or delete other personal information generated by you in the use of our products and/or services, or you believe that there is any violation of laws and regulations or the agreement with you on the collection or use of your personal information in the future, You may contact us by email at support@procinsta.com or by other means outlined in this Privacy Policy. For security purposes, we may require you to provide a written request, or provide your identification document, and we will respond to your request within 15 days of receiving your feedback and verifying your identity. For your reasonable request, we do not charge in principle, but for repeated requests, beyond the reasonable limit, we will charge a certain cost according to the situation. We may refuse unwarranted requests, require excessive technical means (for example, the development of new systems or fundamental changes in existing practices), pose a risk to the legal rights of others, or are highly impractical (for example, involving information stored on backup tapes). Under the following circumstances, we will not be able to respond to your request in accordance with laws and regulations:

(1) It is related to the performance of the obligations prescribed by laws and regulations by the personal information controller;

(2) Those related to national security and national defense security;

(3) Those related to public security, public health, or major public interests;

(4) Those related to criminal investigation, prosecution, trial, and enforcement of judgment;

(5) There is sufficient evidence that you have subjective malice or abuse of rights;

(6) It is difficult to obtain the consent of the subject of personal information or other individuals to safeguard their major legal rights and interests such as life and property;

(7) Responding to your request will seriously damage the legitimate rights and interests of you or other individuals or organizations;

(8) Those involving commercial secrets.

VII. Protection of minors’ personal information

1. Procinsta attaches great importance to the protection of minors’ personal information. If you are under the age of 18, you should obtain the consent of your guardian before using our products and/or services. The Procinsta shall protect the personal information of minors in accordance with relevant national laws and regulations.

2. We do not collect personal information directly from minors on our own initiative. We will only use, share, transfer or disclose the personal information of minors collected with the consent of the guardian if it is permitted by law, with the consent of the guardian, or necessary for the protection of minors.

3. If it is proved that minors have registered and used our products and/or services without the consent of their guardians, we will negotiate with the guardians concerned and try to delete the relevant personal information as soon as possible.

4. We will further take the following measures to protect the personal information of children under the age of 14 that may be involved:

(1) For children’s personal information collected, in addition to comply with our privacy policy regarding personal information provided, will uphold as necessary, informed consent, purpose, security, using the principle of in accordance with the law, strictly follow the law of the People’s Republic of China on children’s personal information network protection regulations and other laws and regulations requirements for storage, use, disclosure, We will delete or anonymize the children’s personal information after the expiration.

(2) When you, as the guardian, choose to use the services of Procinsta for your children under your guardianship, you may voluntarily provide us with children’s personal information when sharing information related to products with the functions of listing, evaluation, and Q&A. Please be clearly aware of this and choose carefully. As the guardian, you should correctly perform the guardianship duties and protect the safety of children’s personal information. If children themselves need to register or use our products and/or services, you should guide and monitor them properly.

(3) The child or its guardian has the right to access and correct the child’s personal information at any time, and may request us to correct, stop processing or delete the personal information, except for overwhelming justification and legal claims for filing, exercising or defending. If you have any comments, suggestions, complaints, or reports about children’s personal information, please contact us. We are always here to help you.

VII. Notices and amendments

1.In order to provide you with better service and with the development of the factory’s business in the future, this Privacy Policy will be updated accordingly. However, we will not reduce your rights under this Privacy Policy without your express consent. We will notify you of the update of the relevant content by Posting an updated version on the Procinsta website and notifying you of the update by website announcement or other appropriate means prior to the effective date. You are also invited to visit Procinsta to keep abreast of the latest privacy policy.

2. For major changes, we will also provide more prominent notices (we will explain the specific changes of the privacy policy through, including but not limited to, email, SMS, or special reminders on the browsing page). Material changes referred to in this Privacy Policy include, but are not limited to:

(1) Major changes have taken place in our service model. For example, the purpose of personal information processing, the type of personal information processing, the use of personal information, etc.

(2) We have undergone major changes in ownership structure and organizational structure. Such as business adjustment, bankruptcy merger, and acquisition caused by the owner change;

(3) The main object of personal information sharing, transfer, or public disclosure changes;

(4) Your rights to participate in the processing of personal information and the way to exercise them change significantly;

(5) Our responsible departments, contact methods, and complaint channels for handling personal information security change;

(6) The personal information security impact assessment report indicates that there is a high risk.

3. We will also archive the old version of this Privacy Policy for your review.

4. In order for you to receive the notice in time, we suggest that you inform us in time when your contact information is updated. If you continue to use our services after this policy update takes effect, it means that you have fully read, understood, and accepted the updated policy and are willing to be bound by the updated policy. We encourage you to review this policy every time you use our services.

VIII. How to contact us

1. If you have any complaints, reports, questions, comments, or suggestions about this Privacy Policy or your personal information, please contact us through the following methods. Email address：support@procinsta.com. You can also contact us at any time by visiting https://www.procinsta.com online customer service system or calling any of our customer service numbers.

2. Normally, we will reply within 15 days. If you are not satisfied with our response, especially if our personal information processing behavior has harmed your legitimate rights and interests, you can also complain or report to the Internet information, telecommunications, public security, industry and commerce, and other regulatory authorities

IX. Legal Basis

We deal with the principle of information, both on the basis of the law of the People’s Republic of China, reference GDPR and related regulations, because if there is any dispute of this agreement, both sides should be in line with the principle of equality and mutual benefit friendly consultations, such as negotiation cannot agree, you can submit to the international arbitration court of arbitration in Shenzhen, the applicable law of the People’s Republic of China, The language is Chinese.

Note: This Privacy Policy version will come into effect on July 2, 2024.