1. Scope of Application of This Policy and Meanings of Relevant Terms

1.1 Scope of Application of This Policy

This Policy applies to the web version of "Kutetailor Platform" and related technical services. Please note that this Policy does not apply to other third-party products/services you access through our products and services ("other third parties" include the other party to your transaction, any third-party website, third-party service providers, etc.). Third-party services are subject to their own privacy policies. Before choosing to use third-party services, you should fully understand the functions and privacy policies of the third party's products/services.

1.2 Special Notes on End Customer Information

This platform is a service mainly for enterprise users. When you, as an enterprise user, enter the personal information of your customers (i.e., "end customers") into this platform, this act constitutes the sharing of personal information by you to us (Qingdao Kutesmart Co.,Ltd.). In this scenario, both you and we are independent personal information processors and will each bear corresponding legal responsibilities.

You promise and guarantee that before sharing any personal information of end customers with us, you have obtained sufficient, valid and clear separate consent from the end customers in accordance with applicable laws and regulations. Such consent must clearly inform the end customers that their personal information will be provided to "Qingdao Kutesmart Co.,Ltd." for the purposes of customer management, order processing, virtual fitting, etc., as stated in this Policy. All responsibilities and disputes arising from your failure to obtain legal authorization from end customers shall be borne by you.

1.3 Meanings of Relevant Terms

• Personal Information: Refers to various types of information recorded in electronic or other forms that can identify a specific natural person individually or in combination with other information, or reflect the activities of a specific natural person.
• Sensitive Personal Information: Refers to personal information that may endanger personal and property safety, and easily lead to damage to personal reputation, physical and mental health or discriminatory treatment if leaked, illegally provided or abused. The sensitive personal information involved in this Policy will be marked in bold and specially noted.
• Shared Information: Refers to information about you that you voluntarily share publicly with your social network and all users of this service in our services, or information about you shared by other parties. For example, information containing details about you uploaded or posted by them, and information about you contained in the communications they send to you and other users of our services.
• Non-Personally Identifiable Information: Refers to any information related to you but which cannot actually identify you directly or indirectly, including personal information provided in an aggregated, anonymous or pseudonymous manner. You acknowledge and agree that information that cannot identify your personal identity does not belong to personal information.

2. How We Collect and Use Your Information

We will follow the principles of legitimacy, legality and necessity, and collect and use the personal information you actively provide or generate due to the use of products/services during your use of the services for the following purposes stated in this Policy. For detailed information on our collection of personal information, you may also refer to the List of Personal Information Collected released together with this Policy.

2.1 Information Collected and Used to Realize Business Functions

(1) Lead and Customer Management

To assist you in business lead registration and Customer Relationship Management (CRM) for subsequent business follow-up and order placement, we may need to collect and use the following information:

1. Lead Registration: In the lead registration scenario, we will collect the potential customer's name, gender, contact phone number, address and company name.
2. Customer Relationship Management (CRM): When you use the CRM function to view customer information for order placement, we will process the customer's information including name, email address, mobile phone number, weight, height and address code.

(2) Order and Bill Services

To provide you with complete order processing, logistics inquiry and bill management services, we may need to collect and use the following information:

1. Order Center: When you view the created orders in the Order Center, we will process the order placement time, production start date, delivery date of the order, as well as size information including special body features, net body measurement and matched ready-to-wear size.
2. Shipment and Logistics Inquiry (SHIPPED): To provide you with the service of inquiring about the shipment status of your order, we will collect the order information including the delivery address, as well as logistics information including waybill number, courier company, shipment date and receipt time.
3. My Bill: To facilitate your viewing of payment records and financial status in "My Bill", we will collect bill information such as transaction date, transaction item, account name, order number, product category and customer name.

(3) Intelligent Functions

To provide you with richer and more convenient intelligent services, we will collect and process the following information when you use specific functions:

1. Virtual AI Fitting: When you use the Virtual AI Fitting function, to realize the identification of key human body points, contours and body shapes, we need to process the human body image information you upload.
2. Image-Based Search/Text-Based Image Search: When you use this function, to retrieve and match similar images or products in the image library, we will collect the image information you upload or the text information you input.

(4) Basic Experience Optimization

To optimize your user experience, we will provide multilingual services. To realize this function, we will identify your device's language preference settings so as to automatically translate the text content in the application into your preferred language.

Others

We hope to provide you with comprehensive services, so we will continuously improve our services, including technology. This means that our services may often launch new functions, which may require the collection of new information. If there are major changes or adjustments to the personal data we collect or the methods of use, we will notify you through appropriate means and may revise this Policy. For detailed information on the collection of personal information, please refer to the List of Personal Information Collected.

2.2 Calling of Device Permissions

To provide you with services, we may need to request corresponding permissions from your device within a necessary scope. You can decide to enable or disable these permissions in the browser settings at any time. Please note that your enabling of any permission means that you authorize us to collect and use the relevant personal information to provide you with the corresponding service. Once you disable any permission, it means that you revoke the authorization. We will no longer continue to collect and use the relevant personal information based on the corresponding permission, nor will we be able to provide you with the service corresponding to that permission.

2.3 Collection and Use of Sensitive Personal Information

In the process of providing services to you, we may collect some of your sensitive personal information. Sensitive personal information refers to personal information that may endanger personal and property safety, and easily lead to damage to personal reputation, physical and mental health or discriminatory treatment if leaked, illegally provided or abused.

If we are to collect your sensitive personal information, we will use methods such as independent pop-up prompts to seek your separate consent again for the processing of this sensitive personal information. We will only process this information after obtaining your explicit authorization. You may refuse to provide it, but you may not be able to use the corresponding service.

3. How We Share, Transfer and Publicly Disclose Your Personal Information

3.1 Sharing

We promise to strictly keep your information confidential. If it is necessary to share your information with a third party to provide you with services, we will assess the legality, legitimacy and necessity of the third party's information collection. We will sign relevant legal documents with the third party and require the third party to comply with laws and regulations when processing your personal information, and make every effort to require the third party to take relevant protection measures for your information. For detailed information on information sharing, you may also refer to the List of Personal Information Shared with Third Parties released together with this Policy.

To ensure the realization of the relevant functions of this website, we may access Software Development Kits (SDKs) provided by third parties to achieve relevant purposes; to complete the transportation service of your goods, after you place an order, we will share your order information and consignee information with logistics companies such as UPS Express and SF Express to complete the goods delivery. We will conduct strict security monitoring on the information acquisition behavior of cooperative parties to protect data security.

3.2 Transfer

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

• Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
• In the event of merger, acquisition or bankruptcy liquidation, 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 seek authorization and consent from you again.

3.3 Public Disclosure

We will only publicly disclose your personal information in the following circumstances:

(1) After obtaining your explicit consent;

(2) Disclosure based on law: Under the circumstances of laws, legal procedures, litigation or mandatory requirements of government authorities, we may publicly disclose your personal information.

3.4 Processing of Personal Information Under Statutory Circumstances

We may process your personal information in accordance with the requirements of laws and regulations in the following situations:

(1) It is necessary for the conclusion or performance of a contract in which an individual is a party;

(2) It is necessary for the performance of statutory duties or obligations;

(3) It is necessary to respond to public health emergencies or protect the life, health and property safety of natural persons in emergency situations;

(4) Processing personal information that has been publicly disclosed by an individual or otherwise legally publicly disclosed within a reasonable scope in accordance with the provisions of the Personal Information Protection Law;

(5) Other circumstances stipulated by laws and administrative regulations.

4. How We Protect and Store Your Personal Information

4.1 Storage of Personal Information

(1) Storage Location: In accordance with the provisions of laws and regulations, we store your personal information in Hong Kong, China. If cross-border storage is required, we will separately obtain your authorization and consent again.

(2) Storage Period: Unless otherwise stipulated by laws or relevant regulations, we will retain your personal information for the period necessary to provide our services. After you cancel your account, we will delete your personal information or anonymize it in accordance with your request, unless otherwise stipulated by laws and regulations.

4.2 Protection of Personal Information

We attach great importance to information security and use various security technologies and procedures to prevent information loss, improper use, unauthorized access or disclosure. For example, in some services, we will use encryption technology (such as SSL) to protect the personal information you provide to us. However, please understand that due to technical limitations and the limitations of risk prevention, even if we have tried our best to strengthen security measures, we cannot always guarantee 100% security of information. You need to be aware that the system and communication network you use to access our services may have problems due to circumstances beyond our control.

We have established a dedicated team responsible for the research, development and application of various security technologies and procedures. We will conduct security assessments on the person in charge of security management and personnel in key security positions. We have established a sound information security management system and internal security incident handling mechanism. We will take appropriate security measures and technical means that meet industry standards to store and protect your personal information to prevent the loss, unauthorized access, use, damage or leakage of your information. In accordance with our security management system, incidents of personal information leakage, damage or loss are classified as major security incidents. Once they occur, the company's emergency plan will be activated, and a joint emergency response team composed of multiple departments such as the Network Operations Department, Information Management Department, Customer Service Department and Legal Department will handle them.

We will conduct data security awareness training and security capability training and assessment for employees, conduct identity authentication and permission control for employees who process personal information, and sign confidentiality agreements with employees and partners who have access to your personal information to clarify job responsibilities and codes of conduct. If there is a violation of the confidentiality agreement, the labor or cooperation relationship with us will be terminated immediately, and relevant legal responsibilities will be pursued. Confidentiality requirements are also put forward for personnel who have access to personal information when they leave their posts.

In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation of the security incident and its possible impact, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant situation of the event through email, letter, phone call, push notification, etc. If it is difficult to inform each individual information subject one by one, we will issue an announcement in a reasonable and effective manner.

At the same time, we will also actively report the disposal of personal information security incidents in accordance with the requirements of regulatory authorities.

We also ask you to understand that in the Internet industry, due to technical limitations and rapid development, as well as various possible malicious attack methods, even if our company does its best to strengthen security measures, it cannot always guarantee 100% information security. Therefore, we strongly recommend that you take active measures to protect the security of your personal information, including but not limited to using complex passwords, changing passwords regularly, and not disclosing your account password and other personal information to others.

5. Your Rights

Right of Access

In principle, you can access your personal information through the following methods:

• Account Information: After logging in, click "Personal Center" to view your account information;
• Order and Shipment Information: Click "Order Center" to view order information and shipment information;
• Customer Information: Click "Management CRM" to view customer information;
• Usage Information: You can also contact us through the method provided at the end of this Policy to delete this information. We will provide this service after verifying your identity, unless otherwise stipulated by laws and regulations;
• Other Information: If you encounter operational problems during this access process or need to obtain other personal information content that cannot be obtained as mentioned above, you can contact us through the method provided at the end of this Policy. We will provide this service after verifying your identity, unless otherwise stipulated by laws and regulations.

Right to Copy, Transfer and Supplement Personal Information

You can submit your application for copying, transferring or supplementing to us through the contact information/customer service provided at the end of this Policy, and request us to copy, transfer or supplement your data.

Right to Request Explanation of Personal Information

You can submit your application for explanation of personal information through the contact information/customer service provided at the end of this Policy, and request us to provide an explanation of your personal information.

Right to Correction

You may submit a correction application to us through the contact information/customer service provided at the end of this Policy, requesting us to correct or update your data, unless otherwise specified by laws and regulations.

Right to Deletion

You may submit a request to us for the deletion of your personal information through the contact information provided at the end of this Policy (for example, when you no longer need us to continue providing services to you), except where the data has been anonymized or otherwise specified by laws and regulations.

Right to Be Informed in Advance of the Cessation of Operation of Products and Services

We are willing to be with you at all times. If, due to special reasons, some or all of our products and services have to cease operation, we will notify you 15 days in advance through the homepage of the product or service, in-site messages, emails sent to you, or other appropriate means that can reach you. We will stop collecting your personal information and will delete or anonymize your personal information in our possession in accordance with legal provisions, except where otherwise specified by laws and regulations.

Exceptional Circumstances

In the following circumstances, in accordance with the requirements of laws and regulations, we will not be able to respond to your request:

1. Those directly related to national security and national defense security;
2. Those directly related to public security, public health, and major public interests;
3. Those directly related to criminal investigation, prosecution, trial, and execution of judgments;
4. There is sufficient evidence to prove that you have subjective malice or abuse of rights;
5. Responding to your request will cause serious harm to the legitimate rights and interests of you or other individuals or organizations;
6. Those involving trade secrets.

6. How We Handle Children's Personal Information

Our products and services are mainly oriented to adults. Although we do not target children as users, we still attach great importance to the protection of children's personal information.

If you are a child under the age of 14, please be sure to carefully read this Privacy Policy together with your parents or other guardians (collectively referred to as "Guardians" hereinafter) under their guidance, and only after obtaining your Guardian's consent, ask your Guardian to assist you in completing the registration and using our services.

If we identify that you are a child under the age of 14, we will suspend the provision of services to you. In accordance with the requirements of laws and regulations, we will take measures to notify your Guardian and seek verifiable consent from the Guardian. We will only collect and process children's personal information when permitted by law, with the explicit consent of the Guardian, or when necessary to protect the child. Meanwhile, we have established strict rules for the collection and use of minors' information to ensure the security of minors' personal information. You can learn more specific details by reading the Kutesmart Children's Privacy Protection Guidelines.

If you are a Guardian of a child, please pay attention to whether the child under your guardianship is using our services. If you have any questions about the personal information of the child under your guardianship, or need to modify or delete it, please feel free to contact us through the contact information provided in this Policy at any time.

Contact Email: service@kutesmart.com

7. How Your Personal Information Is Transferred Globally

Our platform is available to users worldwide. After your personal information is collected in the country or region where you are located (such as the European Union, the United States, etc.), it will be transmitted and stored in our data center located in Hong Kong, China.

We will comply with the legal requirements of the jurisdiction where you are located and the data receiving location to ensure that your personal information is fully protected during cross-border transmission. We will mainly ensure this through the following methods:

1. Obtaining your separate consent: Before you register or use this platform for the first time, we will clearly inform you that your personal information will be transmitted to Hong Kong, China for processing and storage through an independent interface, and seek your separate consent.
2. Adopting necessary legal mechanisms: For specific jurisdictions (such as the European Union), we will comply with local legal requirements to ensure the legality and security of cross-border transmission.

If you do not agree to the cross-border transmission of your personal information, we will not be able to provide you with the services of this platform.

8. How This Policy is Updated

Our Privacy Policy may be changed.

Without your explicit consent, we will not reduce the rights you are entitled to under this Privacy Policy. We will post any changes made to this Policy on this page.

For material changes, we will also provide more prominent notifications (including through channels related to this website or company that can effectively reach users, such as "public notice on the webpage", "prompt through pop-up window", or "sending notifications to your reserved contact information").

Material changes referred to in this Policy include but are not limited to:

1. Significant changes in our service model, such as the purpose of processing personal information, the type of personal information processed, the method of using personal information, etc.;
2. Significant changes in our ownership structure, organizational structure, etc., such as changes in ownership caused by business adjustments, bankruptcy and mergers and acquisitions;
3. Changes in the main objects of sharing, transferring or publicly disclosing personal information;
4. Significant changes in your rights to participate in the processing of personal information and the way to exercise such rights;
5. Changes in the department responsible for the security of personal information processing, contact information and complaint channels;
6. When the personal information security impact assessment report indicates high risks.

9. How to Contact Us

You can contact us through the following methods, and we will respond to your request within 15 days:

1. If you have any questions, opinions or suggestions about the content of this Policy, you can contact us via service@kutesmart.com;
2. If you find that your personal information may have been leaked, you can file a complaint or report via service@kutesmart.com;
3. We have appointed a person in charge of personal information protection, and the contact information is: Xuhua@kutesmart.com.

If you are not satisfied with our response, especially if you believe that our personal information processing practices have harmed your legitimate rights and interests, you can also seek a solution by filing a lawsuit with the people's court that has jurisdiction over the defendant's domicile.