Issued on: June 8, 2023

Effective from: July 25, 2023

Introduction

Shenzhen Asmax Infinite Technology Co., Ltd is a limited liability company established under the laws of the People's Republic of China (hereinafter referred to as "ASMAX" or "we", including its parent company, subsidiaries, affiliates, etc.). We attach great importance to the maintenance and protection of users' personal information. When you use our products and services, we will collect and use your personal information. This Privacy Policy aims to explain to you how we collect, store, use or share your personal information.

Please read and fully understand this Policy before using/continuing to use our products and services, and make appropriate choices according to the guidance of this Policy when necessary. If you do not agree with the content of this Policy, which may cause our products and/or services to fail to operate normally, or fail to achieve the desired service effect, you should immediately stop accessing/using our products and/or services. Your use or continuing use of our products and/or services indicates that you fully understand and agree with the entire content of this Privacy Policy (including updated versions).

1. Collection of Personal Information

We will adhere to the principles of propriety, legality, and necessity in order to collect and utilize the personal information you proactively provide during your use of our services or generated through the utilization of our products and/or services, for the purposes described in this policy. If we intend to employ your personal information for other unspecified purposes or utilize the collected information for a specific purpose different from its original intent, we will duly inform you in a reasonable manner and obtain your consent once again prior to usage.

Account registration and login

1.1. When you register and log in, we will collect your email address.If you use a third-party account to log in, we will ask the associated third party for your personal information.

1.2. You can choose to fill in or change your profile picture, nickname, date of birth, region, vehicle type, club and signature to improve your information according to your own needs. However, if you do not provide such information, it will not affect your use of the product and related services.

1.3. If you successfully register your account with us, we will display your profile picture and nickname in the AsMax application and website.

Providing products and/or services to you

2.1. Information browsing, publishing, likes, favorites and sharing functions.

2.1.1. When you use the publishing punch point function, we will ask you to authorize the photo and camera permission. If you refuse to authorize, you will be unable to use the corresponding function, but it will not affect your normal use of other functions of AsMax.

2.1.2. When you use the publishing, commenting, likes, favorites and sharing functions, the text, photos, comments, likes, favorites and sharing records you publish will be stored in our server, because the storage is necessary to realize this function. We will store them in an encrypted manner. 2.2. Voice communication function. When you use the AsMax multi-person talkback, we ask you to authorize the microphone, phone status and storage permission. In order to allow you to normally use the multi-person instant talkback, call interrupt recovery and other related functions in voice communication. If you refuse to authorize, you will be unable to use the voice communication function, but it will not affect your normal use of other functions of AsMax.

2.3. Push service. In order to provide you with push service, send notifications about software updates or new product releases (including marketing information), evaluate advertising effectiveness and other purposes, you agree that we temporarily obtain the message content from third-party applications. We will also collect your device identification information including IMEI/OAID (for Android Q and above systems), IMEI MD5/MEIDMD5, Android ID, VAID, AAID. The device model you use, network type, device storage device running process information, application version, SDK version, and your country or region settings will also help us provide you with better push services and experience. At the same time, we will use your settings information, including whether to block notification bars, whether to set the lock screen popup message, to provide you with services. We will also collect the application information (package name, version number, application name, first installation time, last update time) to ensure that you will not receive notifications related to the application after you uninstall the application.

2.4. Search function. When you use the search function of AsMax, we will collect the keywords you query, and collect this information only for the purpose of showing you your search history.

2.5. Interaction function. When you use the contacts to add friends function, after obtaining your explicit consent, we will collect your contact information, for the purpose of recommending our friends in your contact list to you. The contact information is personal sensitive information. Refusing to provide this information will only make you unable to use the above function, but will not affect your normal use of other functions of AsMax.

2.6. Activity function. When you participate in our marketing activities, we will collect your name, contact information, mailing address and other information, which is the basis for you to obtain the activity gifts. If you refuse to provide this information, we will not be able to issue gifts to you.

2.7. Customer service function. When you contact us to provide feedback and suggestions on our products, we will suggest you provide contact information, so as to solve the problem for you as soon as possible and improve our products and/or services. At the same time, we may contact you by telephone, SMS, notice and other relevant ways to communicate with you about the problems you have in using our products and services.

2.8. OTA upgrade function. When you use the firmware upgrade function of the headset, we will collect the list of software installation of your device after obtaining your express consent, which is used to determine whether you have installed the AsMax OTA application. This is the basis for you to use the firmware upgrade function. If you refuse to provide this information, you will only be unable to use the above function, but will not affect your normal use of other functions of AsMax.

2.9. Device permission invocation summary. In the process of providing services for AsMax, we will invoke your major device permissions as follows. You can choose to close part or all permissions in the device's settings function. In different devices, the display mode and closing mode of permissions may be different. For details, please refer to the instructions or guidelines of the device and system developer:

2.9.1 Device permission: microphone

Corresponding service function: multi-person real-time voice communication function

Scenario description: in the convoy, multi-person real-time talkback

Can be closed: yes, after being closed, only the corresponding function will be affected, and other functions of the APP will not be affected

2.9.2 Device permission: address book

Corresponding service function: add friends, synchronize address book

Scenario description: add AsMax users in the address book as friends and synchronize the address book to the AsMax device

Can be closed: yes, after being closed, only the corresponding function will be affected, and other functions of the APP will not be affected

2.9.3 Device permission: notification

Corresponding service function: system notification

Scenario description: push APP-related news

Can be closed: yes, after being closed, only the corresponding function will be affected, and other functions of the APP will not be affected

2.9.4 Device permission: network permission

Corresponding service function: core service function

Scenario description: real-time network talkback, content reading and updating Can be closed: Yes, after closed, the APP cannot be used for real-time intercom, real-time reading and update, and normal use of the APP.

2.9.5 Device permission: Camera

Corresponding service function: change the profile picture; publish punch point, scan code to bind the tire pressure gauge

Function scenario description: take pictures when changing the personal profile picture, take pictures when changing the group profile picture;take pictures when changing the club profile picture;take pictures when publishing punch point, open the camera to scan code when binding the tire pressure gauge

Can be closed: Yes, after being closed, only the corresponding function will be affected, and other functions of the APP will not be affected

2.9.6 Device permission: Photos

Corresponding service function: change the profile picture

Function scenario description: upload photos when changing the personal profile picture, upload photos when changing the group profile picture

Can be closed: Yes, after being closed, only the corresponding function will be affected, and other functions of the APP will not be affected

2.9.7 Device permission: Float window

Corresponding service function: convoy intercom

Function scenario description: float over other content during convoy intercom

Can be closed: Yes, after being closed, only the corresponding function will be affected, and other functions of the APP will not be affected

2.9.8 Device permission: Storage

Corresponding service function: stable operation of the APP; record trajectory;

Function scenario description: log information recording, information caching;record trajectory during cycling

Can be closed: Yes, after being closed, only the corresponding function will be affected, and other functions of the APP will not be affected

2.9.9 Device permission: Call status

Corresponding service function: intercom interrupt recovery Function scenario description: When the real-time communication is interrupted by the phone state, the real-time communication will be restored in time when the phone state is over.

Can it be turned off: Yes, after being turned off, only the corresponding function will be affected, and other functions of the APP will not be affected.

2.9.10. Device permission: Software installation list

Corresponding business function: Firmware upgrade

Function scenario description: Get whether to install firmware to upgrade the APP

Can it be turned off: Yes, after being turned off, only the corresponding function will be affected, and other functions of the APP will not be affected.

2.10. Log information: When you use our AsMax, we may automatically collect some information and store it as a log file. When you encounter problems, the stored log will be uploaded to the background for developers to troubleshoot. These log files may include your IP address, access time, browser type, language preference, access page number, etc.

3. Exceptions to obtaining authorization

According to relevant laws and regulations, we may collect and use some necessary personal information without obtaining your authorization in the following circumstances:

(1) Relevant to our performance of obligations stipulated by laws and regulations;

(2) Directly related to national security and national defense safety;

(3) Directly related to public safety, public health and major public interests;

(4) Directly related to criminal investigation, prosecution, trial and execution of judgments and related matters;

(5) For the purpose of safeguarding your life, property and related major legal rights and interests of you or other individuals, but it is difficult to obtain your consent;

(6) The collected personal information is disclosed to the public by you;

(7) Collect your personal information from legally publicly disclosed information: from legal news reports, government information disclosure and related channels;

(8) Necessary according to the online agreement or contract you sign with the platform;

(9) Necessary for maintaining the safe and stable operation of our products and/or services: to find and deal with the failures of products or services and related problems;

(10) Other circumstances stipulated by laws and regulations Why we collect your personal information

II. We collect your personal information for the following purposes:

(1) To authenticate your identity to prevent fraud;

(2) To clarify your technical service needs; (3) Confirm the products and services suitable for you;

(4) Provide products and services according to your requirements;

(5) Comply with the requirements of laws and regulations.

III. How we share, transfer and publicly disclose your personal information

1. Sharing:

We will not share your personal information with any company, organization or individual, except in one or more of the following circumstances:

(1) We have obtained your prior authorization;

(2) You propose it yourself;

(3) Necessary sharing with business partners:

You understand and acknowledge that, in order to provide you with more perfect and high-quality products and services, we will authorize our business partners to provide you with some services. In this case, we may share some of your personal information with our partners to provide better customer service and user experience. Please note that we will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and only share the personal information necessary for providing services.We will conduct security assessment and processing on the output form, flow and use of information data to protect data security.At the same time, we will conduct strict supervision and management of our partners. Once we find that they have violated the rules on handling personal information, we will immediately stop cooperation and investigate their legal liability.

Currently, our partners include the following types:

A. Content review service providers: In order to ensure the safety of the content published by users on the Internet information platform, we may share the content information published by you on the AsMax platform with the entrusted third-party content review service providers.

B. Third-party SDK service providers: When you use the functions provided by third parties in the AsMax APP, we may access the software development kit (SDK) provided by third parties to achieve relevant functions.At this time, the third-party SDK service provider will collect your personal information.The aforementioned service providers shall comply with their own privacy terms for collecting and processing information, which shall not apply to this policy.In order to maximize the security of your information, we suggest that you first check their privacy terms before using any third-party SDK services.In order to protect your legitimate rights and interests, if you find that such SDK or other similar applications have risks, we suggest that you immediately terminate relevant operations and contact us in a timely manner.

Third-party SDK collection and use information description:

Others

Bugly

Purpose: Provide mobile developers with professional abnormal reporting and operation statistics, help developers quickly find and solve abnormalities, master product operation dynamics, and follow up user feedback in real time.

Type of information collected: abnormal data

SDK

Purpose: Provide device application performance monitoring services, provide anti-scamming services, propose cheating devices, and investigate the causes of application performance crashes

Type of information collected: Device identifier (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI/IP/ICCID)

Link to the third-party privacy policy: Link

(4) You may share your personal information or other information with third parties (including non-specific objects) based on the AsMax platform, but AsMax is not responsible for the information disclosure, use and related situations caused by your sharing behavior, and AsMax will not bear any legal liability.

2. Transfer: Transfer refers to transferring the control right to obtain your personal information to other companies, organizations or individuals.We will not transfer your personal information to any company, organization or individual unless we obtain your express consent.However, the following circumstances are excluded:

(1) Your consent has been obtained in advance;

(2) You propose it yourself;

(3) If the company is merged, acquired or liquidated, it may involve the transfer of personal information, in which case we will inform you of the situation and require the new company or organization holding your personal information to continue to be bound by this policy.Otherwise, we will require it to obtain your express consent again.Other circumstances stipulated by laws and regulations.

3. Public disclosure

Public disclosure refers to the act of releasing information to the public or unspecified groups.In principle, we will not publicly disclose your personal information.However, the following situations are excluded:

(1) when displaying necessary desensitization information when announcing account winnings or penalties;

(2) after obtaining your express consent

4. Exceptions to authorization and consent for sharing, transferring and publicly disclosing personal information

According to the provisions of relevant laws and regulations, we may share, transfer or publicly disclose your personal information without obtaining your prior authorization and consent in the following situations:

(1) related to our obligations under laws and regulations, including disclosing your personal information to the competent authorities in accordance with legal provisions or mandatory requirements of judicial or administrative organs;in this case, we will require the disclosure requester to issue valid legal documents corresponding to its request, and take security measures for the disclosed information in accordance with laws and industry standards;

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

(3) directly related to public safety, public health and major public interests;

(4) directly related to criminal investigation, prosecution, trial and judgment execution and related matters;

(5) for the sake of safeguarding your life, property and major legal rights and interests of you or other individuals, but it is difficult to obtain your consent; (6) Personal information you disclose to the public by yourself;

(7) Personal information collected from legally publicly disclosed information: legal news reports, government information disclosure and related channels

(8) Other circumstances stipulated by laws and regulations.

Please be aware that, in accordance with current legal provisions and regulatory requirements, sharing and transferring de-identified personal information and ensuring that the data receiving party cannot recover and re-identify the personal information subject does not need to be separately notified to you and obtain your consent.

IV. How do we store your personal information

No matter how your personal information is provided to us, it will be stored and protected by us.We have established an information security control system to prevent your personal information from being used, accessed, modified, copied, destroyed, disclosed, lost or stolen by others.

To store and protect your personal information, we adopt various confidentiality means and strict confidentiality procedures, such as tangible or electronic.For example, we strictly restrict personnel access to information processing and storage areas, restrict the staffing of personnel who discharge information confidentiality, use passwords, identification codes, standby passwords, firewalls and information transmission encryption, and use password locks for file cabinets and file rooms. When we entrust third parties to provide services and provide them with your necessary personal information, we will sign relevant confidentiality agreements with them to ensure that your personal information is protected and used only to provide services to you.

V. How we use your personal information

The personal information we collect about you may be used for the following purposes:

(1) To provide services to you.

(2) To help us design new products or new services and improve our existing products or services.

(3) For identification, customer service, security, archiving or backup, etc.

(4) To let you participate in our product or service survey.

(5) We may entrust other third parties to provide services on our behalf, such as data processing, account management and marketing.We only provide the first party with the information necessary to complete the services, and we sign confidentiality agreements with these third parties with the same confidentiality standards we follow.These third parties may be from overseas, and according to the laws of their location, these overseas third parties may have certain information disclosure obligations.

VI. Your Rights

1. Account cancellation

We provide you with the function and customer service channel for account cancellation. You can "cancel your account" on AsMax App. The cancellation process will be completed within 7 working days. Once you cancel your account, you will not be able to use the services associated with your account, so please operate with caution.In order to protect the legitimate rights and interests of you or others, we need to verify your identity before cancelling your account, and judge whether to support your cancellation application based on your use of AsMax App. Unless otherwise provided by laws and regulations, after the account is cancelled, we will stop providing you with the corresponding services and delete your personal information.

2. Managing personal information

We attach great importance to and do our best to protect your rights related to your personal information.

2.1 In some cases, you have the right to refuse to provide us with certain information, but we may not be able to provide you with certain products, services or information.To protect the interests of both parties, for example, to ensure that your requirements are implemented and to prove that we have provided you with the required information, we may monitor your telephone or email exchanges with us to ensure the quality of our services.

2.2 Access, acquisition, correction and deletion of personal information copies Through the design of the interactive interface, we provide you with channels to access, acquire, correct and delete relevant personal information. You can set up the following ways:

1) Access, acquire and correct your personal information through [My - Personal Information], including profile picture, name, birthday, region, vehicle type, equipment, club and personalized signature;

2) Set, access, acquire and correct account information through [My - Settings - Account Management], including email address, login password and bound third-party platform account (including Apple ID);

In addition to the above, we shall take the initiative to delete your personal information, and you have the right to request us to delete it:

1) The processing purpose has been realized, cannot be realized or is no longer necessary for the realization of the processing purpose;

2) We have stopped providing products or services, or the storage period has expired;

3) You have explicitly withdrawn your consent;

4) If you have sufficient reasons to believe that we handle your personal information in violation of laws, administrative regulations or agreements;

5) Other circumstances stipulated by laws and administrative regulations.

2.3 Change or withdrawal of authorization scope

1) You can change the binding of third-party accounts through [My - Settings - Account Management]; 2) You can also change or withdraw your authorization of microphone (recording), address book, notification, network, camera (camera), calendar, floating window, geographical location, camera (camera), storage (album, media and other files), and phone status through the operating system of the device itself. Different device models may have different functions. We will collect personal information according to the settings you change or withdraw authorization. If you withdraw authorization, we will no longer collect information related to these permissions, but please note that this will result in the unavailability of some or all functions.At the same time, your decision to change or withdraw authorization will not affect the processing of personal information we have previously carried out based on your authorization.

2.4 Conditional right to transfer personal information

If you need to transfer your personal information to other platforms, enterprises or organizations, you can contact us through the means disclosed in this Privacy Policy.We will review your request and provide you with the means to transfer the corresponding personal information under the conditions stipulated by the Cyberspace Administration of China.

2.5 Automatic decision-making of constrained information system

In some business functions, we may make decisions only based on non-manual automatic decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us to explain, and we will provide appropriate remedies.

2.6 In accordance with the relevant legal requirements, your close relatives can exercise the above rights to access, copy, correct, delete and other related personal information of you;unless you have other arrangements.

2.7 Contact us for management

For security and identity identification considerations, you may not be able to directly through the AsMax interactive interface to access, correct or delete some information (information after real-name authentication, part of your usage records and related information); if you do need to access, modify or delete such information according to law, please contact us in accordance with the contact information provided in Article 9 of this policy, and send your questions to the designated email address. We will review the issues involved as soon as possible and reply to you in a timely manner after verifying your user identity.

3. Marketing

If you do not want to receive our communication about direct marketing, please inform us, and we will delete your personal information from the direct marketing list.If you do not want us to share your personal information among our members, please inform us.In this case, we may not be able to provide you with specific products or services due to the lack of information.

4. Protection of minors If the user is a minor under the age of eighteen (especially for children under the age of four).The user should read this Agreement and use the AsMax related services under the guardianship, guidance and consent of the guardian.We attach great importance to the protection of minors' personal information.When filling in personal information, minor users should strengthen the awareness of personal protection and treat it carefully, and please use the AsMax related services correctly under the guidance of the guardian.We will protect the confidentiality and security of minors' information in accordance with relevant national laws and regulations and the provisions of this Policy.If we find that we have collected the personal information of minors without the prior consent of their parents or legal guardians, we will try to delete the relevant data as soon as possible.

VII. Changes We may from time to time amend the terms of this Privacy Policy, which shall form part of this Privacy Policy.If the amendment results in a substantial reduction of your rights under this Privacy Policy, we will notify you by prominently posting a reminder on the homepage or sending you an email or by other means before the amendment becomes effective.In such case, if you continue to use our services, you shall agree to be bound by the amended Privacy Policy.

VIII. Our Commitment We appreciate the opportunity to provide you with products and services.Since our establishment, winning and maintaining your trust has always been our service tenet.We promise to respect and protect the privacy and personal information you provide. We also hope you can understand our Privacy Policy, including how to collect, use and disclose your personal information. We designate a dedicated team responsible for managing your personal information protection, including systems, dispute resolution, training, liaison and other aspects, and report directly to the Board of Directors and General Manager on matters related to privacy protection.We will ensure that you are informed of the above information collection purposes when you apply for any products or services.If we wish to use your personal information for other purposes, we will apply to you.

How to contact us

If you have any complaints, suggestions or questions about the protection of personal information. Or you have any questions about this policy, you can contact us through the following ways, we will review the issue as soon as possible, and within 15 working days after verifying your user identity to reply: support@tiho-mobi.com