Privacy Policy

Effective Date: December 27, 2024

Guangdong Mentech Technology Co., Ltd. (hereinafter referred to as “mentech” or “we”) values your privacy and the protection of your personal information. When you use our related services, we may process your personal information. Through this Privacy Policy (hereinafter referred to as “this Policy”), we aim to explain what personal information we collect from you while using our services, how we handle this information, and how we provide you with the means to exercise your rights regarding your information. We understand the importance of personal information to you and will do our utmost to ensure its security and reliability.

We are committed to maintaining your trust by adhering to the following principles in protecting your personal information: Principle of Accountability, Principle of Purpose Specification, Principle of Choice and Consent, Principle of Data Minimization, Principle of Security Assurance, Principle of User Participation, Principle of Openness and Transparency.

We also promise to implement appropriate security protection measures in accordance with mature industry standards to protect your personal information. Please read and understand this Privacy Policy carefully before using our products or services.

We will regularly update our software applications (including our websites such as www.mentech.com, and related clients like the PanoX App) for improvements. To ensure that this Privacy Policy accurately reflects your usage of the services, you must ensure that you are using the latest version of mentech’s software applications. Please understand that we will only collect, use, process, and store your personal information based on the revised Privacy Policy if you confirm and agree to the changes. You have the right to refuse to agree to the revised Privacy Policy; however, please be aware that refusing to consent to the revised Privacy Policy may result in your inability to fully use mentech's related services and functions or achieve the intended service outcomes.

1. How We Collect and Use Your Personal Information

1.1 In general, we will only collect your personal information in the following scenarios:

When using mentech's products or services, you may need to provide us with the following information to ensure the normal operation of the corresponding functions of mentech’s products and services:

• The serial number of the mentech product you purchased

• Permission for us to access your phone's storage to obtain external storage information (such as videos and photos on your phone, SD card data, etc.)

• Your device's geographical location information

• Device hardware model

• Operating system version number

• Sensor information (such as accelerometer data)

• Device identifiers (for Android: device serial number, IMEI, Android ID, OAID, IMSI, ICCID, GAID, MEID; for iOS: IDFV, IDFA, SN; different identifiers may vary in validity, user reset capability, and acquisition methods)

• List of installed mobile applications

We may also collect your network device's hardware address (MAC address), IP address, WLAN access point (such as SSID, BSSID), Bluetooth information, software version number, network access method, type, status, network quality data, operational logs, usage logs, service logs, and SIM card serial number.

We may also collect your device's geographical environment and location information, device configuration information, shared text or images, and other data (including sensor data, navigation system data, device data, control data, and environmental sensing visual data). Additionally, we may collect product usage logs, the IP address used to access our products or services, and time information.

If you refuse to provide such information, we may not be able to provide you with the corresponding services, but it will not affect your use of other functions of mentech's products and services.

1.2 How We Use Personal Information

mentech will use the personal data collected for the following purposes:

(i) Enhancing Product Functionality

As discussed in this policy, we will use the information to understand how users interact with our features and services, provide higher quality content, and improve the product experience for mentech users through research and analysis.

(ii) Business Operations

The information we collect will be used for various business operations, such as detecting security incidents, preventing malicious, deceptive, fraudulent, or illegal activities, and prosecuting responsible parties; maintaining your account; and debugging to identify and fix errors that may harm our services.

(iii) Quality Feature Services

We may combine personal information from one service with information from other services to provide you with enhanced functionality, such as expanding your social circle through use, sharing, or disclosure.

We have the right to collect and use your personal information without your authorization in the following situations:

a. Related to national security and defense security;

b. Related to public safety, public health, and significant public interests;

c. Related to criminal investigations, prosecutions, trials, and the enforcement of judgments;

d. To protect your or others' significant legal rights regarding life and property when it is difficult to obtain your consent;

e. When the personal information is publicly disclosed by you;

f. When collecting your personal information from legally disclosed sources, such as legitimate news reports or government disclosures;

g. Necessary for contract signing at your request;

h. Necessary to maintain the safe and stable operation of the provided products and/or services, such as detecting and handling faults in the products and/or services;

i. Necessary for legitimate news reporting;

j. Necessary for academic research institutions to conduct statistical or academic research in the public interest, with the de-identification of personal information in the results when provided externally;

k. Related to our legal obligations;

l. Other situations stipulated by laws and regulations.

Your personal information may contain sensitive information, such as your race, religious beliefs, personal health status, or sexual orientation. You may upload or publish such sensitive information through public channels while using our products or services. Please handle such personal sensitive information with caution.

The information you provide will continue to authorize us for use during your use of mentech products and services. We will comply with legal requirements regarding information retention times.

The above information will be stored within the territory of the People's Republic of China. For cross-border transfers, we will conduct security assessments in accordance with legal requirements.

If we need to use information for purposes not stated in this policy, we will seek your consent in advance. If we intend to use information collected for specific purposes for other purposes, we will also seek your consent in advance.

1.3. How We Use Cookies and Similar Technologies

(i)  Cookies

To ensure the normal operation of our website, we store small data files called cookies on your computer or mobile device. Cookies typically contain an identifier, the site name, and some numbers and characters. With the help of cookies, the website can store your preferences or data about items in your shopping cart.

We will not use cookies for any purposes other than those described in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer, and most web browsers have features to block cookies. However, if you do this, you will need to manually adjust your user settings each time you visit our website. For more detailed information on how to change your browser settings, please visit the official introduction pages of the respective browsers.

(ii) Cookies and Similar Technologies

In addition to cookies, we may also use web beacons, pixel tags, and other similar technologies on our website. For example, emails we send to you may contain clickable URLs linking to content on our website. If you click on that link, we will track the click to help us understand your preferences for our products or services and improve customer service.

Web beacons are typically transparent images embedded in websites or emails. With the pixel tags in emails, we can determine whether the email has been opened. If you do not wish for your activity to be tracked in this way, you can unsubscribe from our mailing list at any time.

1.4 How we use SDK

To provide and optimize our services, our Apps may be embedded with the third-party SDKs. These third-party SDKs can cooperate with us to provide you with more comprehensive services, and may collect your personal information at the same time. We will take the necessary measures to control the collection and use of your personal information by such third-party SDK to ensure that your personal information is effectively protected. For details of the identity of third parties, purpose of collection and links to third parties' privacy policies, please refer to the Third-party SDK Description in Annex I to this Policy.

2. How We Handle Children's Personal Information

Our products, website, and services are primarily aimed at adults. Children are not permitted to create their own user accounts without the consent of a parent or guardian.

In cases where we collect personal information from children with parental consent, we will only use or disclose this information when legally permitted, with the explicit consent of the parent or guardian, or as necessary to protect the child.

Although the definition of a child may vary according to local laws and customs, we consider anyone under the age of 14 to be a child.

If we discover that we have collected personal information from a child without prior verifiable parental consent, we will make efforts to delete the relevant data as soon as possible.

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

3.1 Sharing

We do not share your personal information with any company, organization, or individual outside of mentech, except in the following situations:

(i) Sharing with Explicit Consent: We will share your personal information with other parties after obtaining your explicit consent.

(ii) Legal Compliance: We may share your personal information in accordance with laws and regulations or as required by mandatory government authorities.

(iii) Sharing with Affiliates: Your personal information may be shared with our affiliates. We will only share necessary personal information and it will be subject to the purposes stated in this privacy policy. If affiliates wish to change the purpose of processing personal information, they will seek your authorization again.

(iv) Sharing with Authorized Partners: Some of our services will be provided by authorized partners to achieve the purposes stated in this policy. We may share certain personal information with partners to provide better customer service and user experience. For example, when you purchase our products online, we must share your personal information with logistics service providers to arrange delivery or with partners to provide services. We will only share your personal information for legal, legitimate, necessary, specific, and explicit purposes, and only to the extent necessary for providing the services. Our partners are not authorized to use the shared personal information for any other purposes.

Currently, mentech’s authorized partners include our suppliers, service providers, and other collaborators. We send information to suppliers, service providers, and other partners who support our business globally. This support includes providing technical infrastructure services, transaction and communication services (such as payment, logistics, SMS, email services, etc.), analyzing how our services are used, measuring the effectiveness of advertisements and services, providing customer service, facilitating payments, or conducting academic research and surveys.

We will enter into strict confidentiality agreements with the companies, organizations, and individuals with whom we share personal information, requiring them to handle the personal information in accordance with our instructions, this privacy policy, and any other relevant confidentiality and security measures.

3.2 Transfer

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

(i) Transfer with Explicit Consent: We will transfer your personal information to other parties after obtaining your explicit consent.

(ii) In the Event of Mergers, Acquisitions, or Bankruptcy Liquidation: If the transfer of personal information is involved, we will require the new company or organization holding your personal information to continue to adhere to this privacy policy. Otherwise, we will require that company or organization to seek your authorization again.

3.3 Public Disclosure

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

(i) After obtaining your explicit consent;

(ii) Legal Disclosure: We may publicly disclose your personal information in response to legal requirements, legal processes, litigation, or mandatory requests from government authorities.

4. How We Protect Your Personal Information

4.1 We have implemented security measures that meet industry standards to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable and feasible measures to safeguard your personal information. For example, data exchanged between your browser and our services (such as credit card information) is protected by SSL encryption; our official mentech website uses HTTPS for secure browsing; we employ encryption technology to ensure data confidentiality; we utilize trusted protective mechanisms to prevent malicious attacks on data; we have established a dedicated department for personal information protection; we deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we conduct security and privacy protection training sessions to raise employee awareness about the importance of protecting personal information.

4.2 We will take all reasonable and feasible measures to ensure that unrelated personal information is not collected. We will only retain your personal information for the period necessary to achieve the purposes described in this policy, unless a longer retention period is required or permitted by law.

4.3 The internet is not an absolutely secure environment, and communications via email, instant messaging, or other means with other mentech users are not encrypted. We strongly advise you not to send personal information through such means.

4.4 The internet environment is not 100% secure. We will strive to ensure or guarantee the security of any information you send to us. If our physical, technical, or managerial protective facilities are compromised, resulting in unauthorized access, public disclosure, alteration, or destruction of information, and harming your legitimate rights, we will bear the corresponding legal responsibilities.

4.5 In the unfortunate event of a personal information security incident, we will notify you in a timely manner as required by laws and regulations: we will publish announcements in a reasonable and effective manner. At the same time, we will proactively report the handling of the personal information security incident to regulatory authorities as required.

5. Your Rights

In accordance with relevant laws, regulations, and standards in China, as well as common practices in other countries and regions, we ensure that you can exercise the following rights regarding your personal information:

5.1 Access Your Personal Information

You have the right to access your personal information as provided by laws and regulations. If you wish to exercise your data access rights, you can do so in the following ways:

Account Information: If you want to access or edit your personal profile and payment information, change your password, add security information, or close your account, you can do this through the profile settings, password modification, or related pages on our website or app. However, for security and identity verification purposes, or as mandated by laws and regulations, you may not be able to modify the initial registration information provided during sign-up.

If you are unable to access your personal information through the above methods, you can always send an email to support@mentech.com or contact us through the methods provided on our website or app.

5.2 Correct Your Personal Information

If you find that any of your personal information processed by us is incorrect, you have the right to request a correction. You can do this by sending an email to support@mentech.com or contacting us through the methods provided on our website or app.

5.3 Delete Your Personal Information

You can request the deletion of your personal information under the following circumstances:

If our processing of personal information violates laws and regulations;

If we collect or use your personal information without your consent;

If our processing of personal information violates our agreement with you;

If we no longer provide you with products or services.

If we decide to respond to your deletion request, we will also notify the entity from which we obtained your personal information and request that they delete it promptly, unless otherwise stipulated by laws and regulations or unless those entities have obtained your independent authorization.

When you or we assist in deleting relevant information, applicable laws and security technologies may prevent us from immediately removing the corresponding information from backup systems. We will securely store your personal information and isolate it from any further processing until the backup can be cleared or anonymized.

5.4 Change the Scope of Your Authorized Consent

Each business function requires some basic personal information to be completed (see “Section 1” of this policy). For the collection and use of additional personal information, you can grant or withdraw your consent at any time.

You can do this by: Visiting the authorization page on our website or app to reset the status of your consent regarding your personal information.

Once you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw consent will not affect the processing of personal information that was conducted based on your authorization prior to the withdrawal.

If you do not wish to receive commercial advertisements from us, you can unsubscribe at any time using the methods provided in our emails or messages.

5.5 Restrict Automated Decision-Making by Information Systems

In certain business functions, we may make decisions solely based on non-human automated decision-making mechanisms, including information systems and algorithms. If these decisions significantly affect your legitimate rights, you have the right to request an explanation, and we will provide appropriate remedies.

5.6 Responding to Your Requests

To ensure security, you may need to submit a written request or prove your identity in another way. We may first require you to verify your identity before processing your request.

If you are not satisfied, you can also file a complaint or report to regulatory authorities such as the Cyberspace Administration, telecommunications authorities, public security, and industry and commerce departments.

For your reasonable requests, we generally do not charge fees. However, for repeated requests or those that exceed reasonable limits, we may charge a certain fee based on the circumstances. We may refuse requests that are frivolous, require excessive technical measures (e.g., developing new systems or fundamentally changing existing practices), pose a risk to the legitimate rights of others, or are extremely impractical (e.g., involving information stored on backup tapes).

We will be unable to respond to your requests under the following circumstances as required by laws and regulations:

(i) Directly related to national security and defense;

(ii) Directly related to public safety, public health, or major public interests;

(iii) Directly related to criminal investigations, prosecutions, trials, or the execution of judgments;

(iv) There is sufficient evidence to suggest that you have subjective malice or are abusing your rights;

(v) Responding to your request would seriously harm the legitimate rights of you or other individuals or organizations;

(vi) Involving commercial secrets.

6. How Your Personal Information Is Transferred Globally

In principle, the personal information we collect and generate within the People's Republic of China will be stored within the country.

Since we provide products or services through resources and servers located around the world, this means that your personal information may be transferred to jurisdictions outside the country or accessed from these jurisdictions. We will conduct a security assessment in accordance with legal requirements before such transfers.

These jurisdictions may have different data protection laws or may not have relevant laws in place. In such cases, we will ensure that your personal information receives adequate protection equivalent to that within the People's Republic of China.

7. How This Policy Is Updated

Our privacy policy may change. We will post any changes to this policy on this page. For significant changes, we will also provide more prominent notifications.

Significant changes referred to in this policy include but are not limited to:

7.1 Major changes in our service model, such as the purpose of processing personal information, the types of personal information processed, and how personal information is used;

7.2 Changes in the main parties with whom personal information is shared, transferred, or publicly disclosed;

7.3 Significant changes in your rights regarding personal information processing and how those rights are exercised.

If you continue to use mentech's products and services after the policy updates take effect, it indicates that you have fully read, understood, and accepted the updated policy and agree to be bound by it.

8. Contact Us

If you have any questions, comments, or suggestions regarding this privacy policy or matters related to your personal information, please contact us through the following:

Name: Guangdong mentech Technology Co., Ltd.

Contact Address: 504, Building D1, TCL international E City, No. 1001 Zhongshanyuan Road Nanshan District, Shenzhen Guangdong Province, China

Phone: 4000862788

To ensure security, when you contact us, we may need to verify your identity before replying within 15 days after receiving your request and confirming your identity. For your reasonable requests, we generally do not charge fees; however, for repeated requests that exceed reasonable limits, we may charge a certain fee based on the circumstances.

If you are not satisfied with our response or handling, you may seek resolution through external channels, such as filing a complaint or report with regulatory bodies like the Cyberspace Administration, Ministry of Industry and Information Technology, State Administration for Industry and Commerce, Consumer Association, or initiating a lawsuit in the competent people's court where the defendant resides.

Annex I