Privacy Policy

Privacy Policy

We (CZ ROBOTS PTE. LTD., Hangzhou Cenozoic Robotics Co., Ltd., hereinafter referred to as “we”, “us”, “our” or “Cenobots” ) fully understand the importance of Personal Information to you and are committed to protecting your privacy, in particular in compliance with the EU General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”), and California Privacy Rights Act (“CPRA”) (collectively, the “CA Privacy Acts”)[1]of California and the Personal Information Protection Law of the People’s Republic of China (“PIPL”). This Privacy Policy (hereinafter referred to as “this Policy”) describes how we collect, receive, use, store, share, transfer, and process your Personal Information ( defined in Section 1: What Information We Collect About You) through Cenobots websites. It also describes your choices regarding use, as well as the rights of your Personal Information.

We endeavor to introduce to you how we process your Personal Information in this Policy, please be sure to read carefully and thoroughly understand this Policy, especially the bold terms which you should pay more attention to, and then start using it after confirming that you fully understand it. If you do not agree with the practice described in this Policy, you may still browse our websites, but may not use certain functions on our websites.

This Policy does not apply to the data Cenobots processes on behalf of our customers (hereinafter referred to as “Customer Data”) in our capacity as a processor. In such a circumstance, a separate privacy policy shall be applied. We periodically update this Policy. We will post any changes to this Policy on this page and encourage you to review this Policy periodically.

If you have any questions, comments, or suggestions about the content of this Policy, you can contact our Data Compliance Officer by emailing [email protected].

This Policy will help you understand the following information:

1. What Information We Collect About You
2. How We Collect and Use Your Personal Information
3. Where We Store and Process Your Personal Information
4. How We Transfer or Disclose Your Personal Information
5. How We Protect Your Personal Information
6. How We Use Cookies and Similar Technologies
7. How You Access and Control Your Personal Information
8. Third-Party Websites and Applications
9. Specific Issues to Users in the EU
10. Specific Issues to Users in California
11. Specific Issues to Users in the People’s Republic of China
12. How We Update Our Privacy Policy
13. How You Contact Our Data Compliance Officer

1. What Information We Collect About You

When you visit our website (www.cenobots.com、www.cz-robots.com, hereinafter referred to as “Cenobots Website”) or register for any services on Cenobots Website, we request that you provide Personal Information about yourself, and we collect Navigational Information. You are also free to explore Cenobots Website without providing any Personal Information about yourself.

This Policy applies to all services at Cenobots Website, which includes, in particular:

• webpage browsing;
• mail-listing newsletter (“Mailchimp”);
• whitepaper downloading;
• “online message” services and instant chat services; and
• phone or hotline service.

“Personal Information” refers to any information that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information may include Navigational Information which refers to information about your computer/device (such as device model, operating system version, device settings like browser type, referral sources like unique device identifiers, and other software and hardware characteristics information), relevant information about your location (such as IP address) and Log Data about your usage (such as telecom or network operator, the language used, date and time of access, length of web visitors, and records of web pages you visit as well as other Log Data). For details about Log Data, please refer to our Cookie Policy. Such Navigational Information is automatically linked to certain Personal Information such as name, email address, address, and phone number and will be used by us to provide general statistics regarding the use of the Cenobots Website.

Generally, we don’t collect the so-called “Sensitive Information” which refers to credit or debit card numbers, financial account numbers or wire instructions, government-issued identification numbers (such as Social Security numbers, passport numbers), biometric information, personal health information (or other information protected under any applicable health data protection laws), personal information of children protected under any child data protection laws, and any other information or combinations of information that falls within the definition of “special categories of data” under the GDPR, “Sensitive Personal Information” under the CA Privacy Acts,[2] or any other applicable law relating to privacy and data protection. Cenobots Website is not intended for or targeted at children under 16 or minors under applicable laws, and we do not knowingly or intentionally collect personal information about children under 16 or minors under applicable laws. In case you claim to delete any personal information about children under 16 or minors that might be collected by us, please contact our Data Compliance Officer.

This Policy does not apply to services provided to you by other third parties.

Below is a list of our Cenobots affiliates within which the data collected via the Cenobots Website will be processed.

2.How We Collect and Use Your Personal Information

The Circumstances Under Which You Provide Your Personal Information

When you browse Cenobots Website, leave messages online, apply to download whitepapers or any documents, or use live chat on the Cenobots Website, you may provide us with your basic information, including Category (1): your name, your country or region, the name of your organization (business duration, enterprise scale, main business, major products), your position, the industry you are engaged in, your specific ideas and needs; and Category (2) contact information (e-mail, contact phone number).

The e-mail address you submitted is used as one of the contact methods specified between you and the Cenobots Website to receive relevant business notifications (such as new products launch, service changes, sending regular email direct marketing advertisements, etc.).

The information you provide in Category (1) of this article will help us better understand your service requirements for the Cenobots Website so that the Cenobots Website can promote and introduce products to you in a targeted manner. Cenobots Website may use the above methods you provide in Category (2) of this article is used to send you marketing materials and conduct business communications with you or follow up for business contact.

You are free to explore Cenobots Website without providing any Personal Information about yourself. If you only need to use basic services such as page browsing on the Cenobots Website, you do not need to provide the above information. In respect of such marketing advertisements as stated in Category (2) above, you also have the right to change the scope of your authorization and consent under this Policy (see Section 7: How You Access and Control Your Personal Information).

Log Data and Cookies

We use cookies and collect Log Data to analyze trends, administer our websites, track users’ movements around our websites, and gather demographic information about our user base as a whole. To find out more about how we use cookies on our websites and how to manage your cookie preferences please see our Cookie Policy.

When we provide you with specific services, we will collect, use, store, and protect your Personal Information in accordance with this Policy. In case we have collected your Personal Information beyond the provisions of this Policy and/or the scope of the respective agreement on products or services, we will separately explain to you the scope and purpose of the information collection and obtain your express consent before collecting your information necessary to provide the corresponding services. If you choose not to provide the aforementioned information, it will not affect your use of the basic functions of the Cenobots Website. For more information, please refer to Section 6 of this Policy and our Cookie Policy.

Purpose and Methods for Use of Your Personal Information

Your Personal Information provided by you and/or collected by us will be used by us for the following purposes:

• To provide functionality, analyze performance, fix errors, and improve usability and effectiveness of Cenobots services;
• To send you information, and notifications or conduct business communications with you, including but not limited to push notifications necessary to use the services;
• To adopt or improve our technical safety protection measures;
• In order to maintain and improve services and provide you with information displays that better meet your personalized needs, we may use the Personal Information collected from certain services on the Cenobots Website, to enhance your productivity and enjoyment, and then present, push information and potential commercials, including but not limited to, news about Cenobots products, market events, and promotional offers, or other contents that may interest you to you;
• We may design, develop, and promote brand-new products and services based on Personal Information statistics;
• we will make statistics on our service usage and may share these statistics with the public or third parties, but these statistics do not contain any of your identification information or organization name;
• We will inform you again and obtain your explicit consent before using the Personal Information beyond the stated purpose when collecting the Personal Information, or before using the Personal Information beyond the scope that is directly or reasonably related.

3. Where We Store and Process Your Personal Information

Personal Information collected by Cenobots via Website will be stored first in the United States by default and may be stored and processed in your region or in any other country where Cenobots or its affiliates, subsidiaries, or service providers operate facilities based on your choice.

Cenobots maintains major data centers in the United States and Germany. Typically, the primary storage location is in the customer’s region or the United States or Germany, often with a backup to a data center in another region. The storage location(s) are chosen to operate efficiently, improve performance, and create redundancies to protect the data in the event of an outage or other problem. We take steps to process the data that we collect under this Policy according to this Policy’s provisions and the requirements of applicable law.

4. How We Share or Transfer Your Personal Information

Sharing Personal Information within CenoBots Entities

We may share Personal Information within Cenobots-controlled affiliates and subsidiaries for the purposes we described under Section 2.

For example, a customer leaves an inquiry via our website to Cenobots and may need technical support from certain subsidiaries of Cenobots. The contact of the inquiry will be shared with certain subsidiaries of Cenobots.

When we share information about you within and among Cenobots Entities, we will use Standard Contractual Data Protection Clauses, which have been approved by the European Commission besides technical safety measures described under Section 5 of this Policy.

Share Personal Information with Service Providers to Cenobots

We also share Personal Information with vendors or agents working on our behalf for the purposes described under Section 2 in this Policy. For example, companies we’ve hired to provide customer service support may need access to Personal Information to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use the Personal Information they receive from us for any other purpose.

Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information about customers in the EEA or Switzerland, we make use of a variety of legal mechanisms to safeguard the transfer, including the European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms. For transfers to or from the United Kingdom, we make use of the standard contractual clauses. Please contact us if you need more information about the legal mechanisms we rely on to transfer Personal Information outside the EEA, Switzerland, and the United Kingdom.

We will only share your Personal Information for legitimate, proper, necessary, specific, and clear purposes, and we will only share Personal Information necessary to provide the service. Our partners are not authorized to use shared Personal Information for any other purpose.

Currently, our authorized partners include the following types: customers, suppliers, service providers, and other partners. We will send information to suppliers, service providers, and other partners who provide support for our business. Such support includes providing basic technical services, providing consultations, analyses based on anonymized data, and other professional services. For companies, organizations, and individuals with whom we share Personal Information, we will sign strict confidentiality agreements and information protection agreements with them, requiring them to process Personal Information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures.

[Hyperlinked URL titled “List of Involved Third Parties (Customers, Suppliers, Service Providers, and Other Partners)”

International Privacy Shield Notice

Cenobots adheres to the principles of the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all Personal Information received from European Union (EU) member countries, the United Kingdom and Switzerland, in reliance on the Privacy Shield Frameworks and to the Framework’s applicable Principles, while we are aware that the EU-U.S. Privacy Shield Framework as a legal basis for transfers of Personal Information has been challenged and struck down in light of the judgment of the Court of Justice of the EU in Case C-311/18.

As regards, the complaint and remedies approach you may be entitled to under the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework, please refer to the U.S. Department of Commerce’s Privacy Shield website at https://www.privacyshield.gov.

We may disclose your Personal Information to comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies.

Personal Information Transfer

In principle, your Personal Information collected via Cenobots Website will be stored in the regions of your choice for this Policy.

In Principle, Cenobots will not conduct cross-border transfer unless it satisfies the following conditions:

• The transfer is necessary
• Your prior explicit consent
• Meet legal requirements of the export and import region’s applicable laws
• Meet the security measures regulated by applicable laws and this Policy

The European Commission has determined that certain countries outside of the European Economic Area (EEA) adequately protect Personal Information. You can review current European Commission adequacy decisions [ https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en]. To transfer data from the EEA to other countries, such as the United States, we comply with legal frameworks that establish an equivalent level of protection with EU law. Please refer to Sections 9, 10, and 11 for specific issues including data transfer in different jurisdictions and regions.

5. How We Protect Your Personal Information

We attach much significance to safeguarding and security of your Personal Information. We strive to take all reasonable and feasible measures to protect your Personal Information by deploying industry-standard security measures, to protect the Personal Information provide and prevent data breaches, data leaks, unauthorized access or public disclosure, misuse, unauthorized modification, damage, or loss.

We will take reasonable and feasible measures to try to avoid collecting irrelevant Personal Information. We will only retain your Personal Information for the time as long as necessary to achieve the purpose stated in this Policy unless an extension of the retention period is required or permitted by law. We are aware that the Internet environment is not 100% secure, and we will do our best to ensure the security of any information you provided to us.

Cenobots use the following security measures endeavoring to secure your Personal Information in rest, transit, and storage including but not limited to

• Website services are secured with SSL/TLS;
• Stored Personal Information will use secrets stored in the directory which are encrypted;
• Uses encryption measures in transit such as firewalls, HTTP endpoints, and IP packet filtering.

The “Personal Information Breach” is defined as “a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored, or otherwise processed”. If a Personal Information Breach happens, we will promptly inform you of the requirements of laws and regulations:

• the actual situation and the possible impact of the security event;
• the security or remedy measures we have taken or will take;
• the recommendations to prevent and mitigate risks by yourself and remedies for you.

We will promptly inform you about the event by email, letter, phone, push notification, etc. When it is difficult to inform users of the information one by one, we will announce a reasonable and effective way.

At the same time, we will proactively report the disposition of the Personal Information breach in accordance with the requirements of regulatory authorities.

6. How We Use Cookies and Similar Technologies

In order to ensure the normal operation of the Cenobots Website, get an easier access experience for you, and make recommendations that may interest you to you, we store small data files called Cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. We can only read Cookies provided on the Cenobots Website.

With Cookies, data such as your preferences can be stored. When you visit again, we will display the information you need; or the Cenobots Website will use Cookies to identify your source website so that we can track the advertising effectiveness of Cenobots Website.

You can manage Cookies according to your preferences, or you can clear all Cookies saved on your computer. Most web browsers have a function that blocks Cookies. But if you do this, you need to change user settings every time you visit Cenobots Website. To learn more about changing your browser settings, visit the settings page for your browser.

In addition to Cookies, we use other similar technologies such as web beacons and pixel tags on the Cenobots Website. For example, the email we send you may contain an address link to the content of the Cenobots Website. If you click on the link, we will track the click to help us understand your product or service preferences so that we can proactively improve the customer service experience. A web beacon is usually a transparent image embedded in a website or email. With the help of the pixel tags in the email, we can know whether the email is opened. If you do not want your activity to be tracked in this way, you can unsubscribe from our mailing list at any time.

To learn more about how we use cookies and similar technologies, please refer to our Cookie Policy.

7. How You Access and Control Your Personal Information

You have certain rights in relation to the Personal Information we hold about you. Some of these rights only apply in certain circumstances as set out in more detail below. We set out how you can exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights. Please send your request to our Data Compliance Officer at [email protected] as stated in Section 13.

Reviewing, Correcting, and Removing Your Personal Information

You have the right to request access, correction, updates, or deletion of your Personal Information. You can object to the processing of your Personal Information, ask us to restrict the processing of your Personal Information, or request portability of your Personal Information. If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

In respect of your deletion request, the following aspects shall be considered:

• the Personal Information is no longer necessary in relation to the purposes for which they were collected or otherwise processed, for instance, un-subscription to newsletters or advertisement notifications;
• you withdraw consent on which the processing is based (and we have no other grounds for processing the Personal Information);
• you exercised rights to object to the processing of your Personal Information;
• the Personal Information has been unlawfully processed;
• the erasure is compliant with a legal obligation;
• the Personal Information has been collected in relation to the offer of information society services to a minor.

Please note, however, that we may retain the Personal Information when processing is necessary. In such case, we will inform you accordingly, in particular, when:

• exercising the right of freedom of expression and information;
• keeping compliance with a legal requirement or statutory obligation to which we as controllers are subject or for the performance of a task carried out in the public interest or the exercise of official authority vested in the controller;
• for reasons of public interest in the area of the public;
• for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in so far as the right is likely to render impossible or seriously impair the achievement of the objectives of that processing;
• for the establishment, exercise, or defense of legal claims.

Where you have requested that we delete your Personal Information that we have made public and there are grounds for deletion, we will use reasonable steps and try to inform others that are displaying the Personal Information or providing links to the Personal Information to erase it too.

Constrain the Automatic Decision of the Information System

In some business functions, we may only make decisions based on non-manual automatic decision-making mechanisms including information systems, algorithms, etc. If these decisions significantly affect your legal rights, you can ask us to explain.

Respond to Your Above Request

For security reasons, you may need to provide a written request or prove your identity otherwise. We may ask you to verify your identity before processing your request.

For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed a reasonable limit, we will charge a certain cost depending on the conditions. For those requests that are unreasonably repetitive, require excessive technical means (for example, need to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on backup tapes), those requests may be rejected by us.

We will not be able to respond to your request in the following situations:

• Related to the fulfillment of the obligations stipulated by applicable laws and regulations on controllers of related Personal Information;
• Directly related to national security and national defense security;
• Directly related to public safety, public health, and significant public interests;
• Directly related to the criminal investigation, prosecution, trial, and enforcement of judgments;
• For the purpose of protecting your or other individual’s significant legitimate rights and interests;
• Responding to the request of the subject of the Personal Information will cause serious damage to the legitimate rights and interests of the subject of the Personal Information or other individuals and organizations.

In the event that we are unable to respond to your request, we will give you an appropriate explanation.

8. Third-Party Websites and Applications

The Cenobots Website may link to other websites or applications that we do not own or control (such as YouTube, LinkedIn, Facebook, and Twitter, collectively referred to as “external websites”). Such links do not constitute our endorsement of these external sites. We provide these links to you only for your convenience and are not responsible for the content of such external websites.

Your use of external sites is governed by the terms of use and privacy policies applicable to such external websites. We recommend that you read the privacy policies of these external websites that collect your personal information when you leave our website and link to external websites.

9. Specific Issues to Users in the EU

If you are an individual in the European Union (EU) whose Personal Information we process in relation to either our offer of goods or services to you or our monitoring of your behavior in the EU (“EU Users”), the following additional provisions may also apply to you.

Transfers of Your Personal Information Outside of the European Economic Area

Your Personal Information may be processed by us, and our trusted third-party suppliers outside of the European Economic Area (EEA), including in countries where data protection and privacy laws or regulations may not be equivalent to, or as protective as, the data protection and privacy laws and regulations in the EEA.

In accordance with applicable data protection and privacy laws and regulations, we will implement appropriate measures to ensure that your Personal Information remains protected and secure when it is transferred outside of the EEA to a jurisdiction other than one that is recognized by the European Commission as having an adequate level of protection of Personal Information. These measures include (where applicable) transferring pursuant to data transfer agreements implementing Standard Contractual Clauses (SCC) recommended by the European Commission. If you would like further information, you can contact us by sending an email to our Data Compliance Officer at [email protected].

We may also transfer your Personal Information outside of the EEA. Examples include where we need to transfer your Personal Information: (a) to perform a contract with you (or to take steps before the contract at your request); (b) perform a contract in your interests; or © in relation to legal claims.

Your Rights Besides the Rights Specified in Section 7 of This Policy

• Your right to data portability

You have the right to receive a copy of certain Personal Information we collect from you. This comprises any Personal Information we process on the basis of your consent (e.g., your profile). You have the right to receive this information in a structured, commonly used, and machine-readable format. You also have the right to request that we transfer that Personal Information to another party. You can exercise your right to export your data by using our web form or send an email to [email protected], stating at least your first and last name and your request.

If you wish for us to transfer the Personal Information to a third party, please ensure to provide the contacts detail of that third party. Note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Information or its processing once received by a third party. We also may not provide you with certain Personal Information if providing it would interfere with another’s rights (e.g. where providing the Personal Information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Please note for other matters not covered in this Policy, we will protect your legitimate rights in regard to your Personal Information according to relevant provisions of applicable laws and regulations in the EU, e.g. the General Data Protection Regulation for EEA.

• Your right to restriction of processing

You have the right to ask us to restrict the processing of your personal information in certain circumstances. For example, you can request that we limit the way in which we use your “Personal Data” (as defined by the GDPR) if you are concerned about the accuracy of the Personal Information or how it is being used. You can exercise your right by using our web form or sending an email to [email protected], stating at least your first and last name and your request.

• Your right to object to processing

You have the right to object to the processing of your personal information in certain circumstances. Where it is appropriate that we comply with your request, we will stop processing your information for the use you have objected to. You can exercise your right by using our web form or sending an email to [email protected], stating at least your first and last name and your request.

• Your right to withdraw consent

You have the right to withdraw your consent at any time. However, the withdrawal of your consent shall not affect our lawfulness of processing based on consent before your withdrawal. You can exercise your right by using our web form or sending an email to [email protected], stating at least your first and last name and your request.

• Your right to lodge a complaint at the supervisory authority

We work to high standards when it comes to processing your personal information. If you have queries or concerns, please contact us and we’ll respond. You can exercise your right by using our web form or send email to [email protected], stating at least your first and last name and your request.

If you remain dissatisfied, you have the right to lodge a complaint with a competent data protection supervisory authority.

10. Specific issues for users in California

If you are a California resident whose Personal Information we process in relation to either our offer of goods or services to you or our monitoring of your behavior in California (“CA Users”), the following additional provisions also apply to you. To comply with our obligations under the [CCPA]/[CA Privacy Acts], we are providing you with this notice of our practices and your rights for your Personal Information. If you are a CA User, in the event any of our practices or your rights in this Section 10 conflict with any other parts of this Policy, this Section 10 shall control. If you have any questions about our practices and your rights with respect to the [CCPA]/[CA Privacy Acts], please contact our Data Compliance Officer by mailing [email protected].

Categories of Personal Information We Collect

We collect Personal Information, which for CA Users means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably link, directly or indirectly, with CA Users. Personal Information for CA Users does not include (i) publicly available information from government records, (ii) anonymized or aggregated consumer information, or (iii) information excluded from the [CCPA]/[CA Privacy Act]’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 and the California Confidentiality of Medical Information Act or information covered by certain sector-specific privacy laws including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.

For the detailed Personal Information categories we collect and process please refer to Section 2 of this Policy.

Our Use of Your Personal Information

In addition to our uses outlined in Section 2 of this Policy, we may use or disclose the Personal Information we collect from CA Users for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery;
• To process CA User requests, purchases, transactions, and payments and prevent transactional fraud;
• To provide CA Users with support and to respond to inquiries, including investigating and addressing CA User concerns and monitoring and improving our responses;
• For testing, research, analysis, and product development, including to develop and improving our website, products, and services;
• To respond to law enforcement requests as required by applicable law, court order, or other governmental regulations;
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA;[3] and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings, in which Personal Information held by us about our website or CA Users is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

How Long Do We Keep Your Personal Information

We will not retain your personal information for longer than reasonably necessary for the purposes described above. Our standard retention practices with respect to your Personal Information are outlined below.

• Identifiers: we will retain identifiers for [12] months from the date on which we collect or receive such data.
• Internet or other similar network activity: we will retain Internet or other similar network activity information for [12] months from the date on which we collect or receive such data.
• Commercial information: we will retain commercial information for [24] months from the date on which we collect or receive such data.
• Geolocation data: we will retain geolocation data for [12] months from the date on which we collect or receive such data.

Disclosure of your Personal Information

We may disclose your Personal Information to our service providers for our business purposes. When we disclose your Personal Information for a business purpose, we enter into a contract with the recipient to safeguard your Personal Information in compliance with the [CCPA]/[CA Privacy Acts]. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to our service providers for our business purposes:

• [Identifiers;]
• [Internet or other similar network activity;]
• Commercial information;
• [Geolocation data;]
• Professional or employment-related information; and
• [OTHER][4].

In the preceding twelve (12) months, we have not sold any Personal Information or shared any Personal Information with third parties for cross-context behavior advertising.

Your Rights and Choices in Addition to the Rights Specified in Section 7 of This Policy

The CCPA provides CA Users with specific rights regarding their Personal Information. An authorized agent may exercise these rights on a CA User’s behalf. If an authorized agent submits a request with respect to your Personal Information, we require you to:

• Provide your authorized agent with signed permission to exercise your rights and choices on your behalf;
• Verify your own identity directly with us; and
• Directly confirm with us your authorized agent has permission to submit this request.

Your Access and Data Portability Rights Besides the Rights Specified in Section 7 of This Policy[5]

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your request in accordance with Section 7© of this Policy, we will disclose to you:

• The categories of Personal Information we collected about you;
• Our business or commercial purpose for collecting the Personal Information;
• The categories of third parties with whom we have shared that Personal Information;
• The specific pieces of Personal Information we collected about you in a structured, commonly used, machine-readable format (also called a data portability request); and
• A list identifying the disclosures of your Personal Information for our business purposes and identifying the Personal Information categories that each category of recipient obtained.

Your Rights to Opt-out Besides the Rights Specified in Section 7 of This Policy

We do not sell your Personal Information [or share your Personal Information for cross-context behavior advertising][6]. Thus, we do not offer opt-outs to the sale [and sharing] of Personal Information. However, we provide you with the right to access and control your Personal Information specified in Section 7 of this Policy.

You have the right to restrict us from providing your Personal Information to third parties for cross-context behavioral advertising. Cross-context behavioral advertising is the targeting of advertising to you based on your Personal Information obtained from your activity across businesses, distinctly branded websites, applications, or services other than our own. To restrict us from sharing your Personal Information with third parties for cross-context behavioral advertising, you or an authorized agent may submit a request to us by visiting the following link:

[Hyperlink URL titled “DO NOT SHARE MY PERSONAL INFORMATION FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING”]

Once you request, we do not share your Personal Information for cross-context behavioral advertising, we will stop providing your Personal Information to third parties for the purpose of cross-context behavioral advertising.

You do not need an account with us to request we do not share your Personal Information for cross-context behavioral advertising. We will only use the Personal Information provided in such a request to comply with the request.[7]

Your Right to Limit the Use or Disclosure of Your Sensitive Personal Information Besides the Rights Specified in Section 7 of This Policy

You have the right to limit the use or disclosure of your Sensitive Personal Information, as defined under the CA Privacy Acts and including such information outlined in Section 1 of this Policy, to only those necessary to provide our goods or services at any time. To exercise the right to limit the use and disclosure of your Sensitive Personal Information, you or an authorized agent may submit a request to us by visiting the following link:

[Hyperlinked URL titled “LIMIT THE USE AND DISCLOSURE OF MY SENSITIVE PERSONAL INFORMATION”]

Once you request that we limit the use and disclosure of your Sensitive Personal Information, we shall not use or disclose your Sensitive Personal Information for any other purposes without first receiving your consent.

You do not need an account with us to request we limit the use and disclosure of your Sensitive Personal Information. We will only use Personal Information provided in a limitation request to review and comply with the request.[8]

Your Right to Equal Service and Price (Non-Discrimination) Besides the Rights Specified in Section 7 of This Policy

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you with a different level of quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Response Timing and Format

We endeavor to respond to a request in accordance with Section 7© of this Policy within forty-five (45) calendar days of its receipt. If we require more time (up to forty-five (45) days), we will inform you of the reason and extension period in writing. We will send you confirmation of receipt of any request in accordance with Section 7© of this Policy within ten (10) business days of its receipt.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically at your option.

Any disclosures we provide will only cover the twelve (12) month period preceding the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from us to another entity without hindrance.

We do not charge a fee to process or respond to your request in accordance with Section 7© of this policy unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

11. Specific Issues to Users in the People’s Republic of China

Provided you use Cenobots Website in the People’s Republic of China, pursuant to the Personal Information Protection Law of the People’s Republic of China (“PIPL”), Cenobots will undertake the following additional responsibilities as Data Controller or Data Processor:

• Cenobots will collect and process your Personal Information pursuant to PIPL if you use Cenobots Website within the geographic scope of P.R. China.
• Cenobotss will NOT collect Sensitive Data as regulated by Article 20 of PIPL.
• Cenobots will store Personal Information collected from P.R. China within P. R. China.
• Cenobots will NOT supply Personal Information overseas unless it satisfies the conditions regulated under Article 38 and Article 39 of PIPL.
• Cenobots will meet the requirements regulated by PIPL as Data Controllers and Data processors in accordance with Chapter 5.
• Cenobots will ensure and facilitate Data Subject to perform his or her rights in accordance with Chapter 4 of PIPL.

12. How We Update Our Privacy Policy

Our Privacy Policy is subject to amendments of applicable laws and regulations as well as changes in our business practice from time to time. We reserve the right to supplement and modify the content of this Policy. Significant changes referred to in this Policy may include, for instance:

• significant changes to our service model, such as the purpose of processing Personal Information, the type of Personal Information processed, and the manner in which Personal Information is used;
• significant changes in terms of ownership structure and organizational structure, such as business adjustments, bankruptcy mergers, and acquisitions, etc.;
• significant changes to the main objects of sharing, transferring, or publicly disclosing Personal Information;
• significant changes to your right to participate in the processing of Personal Information and its exercise methods;
• significant changes to our responsible department, contact method, and complaint channel for processing the safeguard and security of Personal Information.

For significant changes, we will also provide more prominent notifications (including for certain services, we will send notifications via email explaining the specific changes to the Privacy Policy).

The updated Privacy Policy applies from the time, in which it was published on our websites. We recommend that you review this Policy regularly.

13. How You Exercise Your Protection Rights

If you have any questions, comments, or suggestions regarding this Policy, please contact our Data Compliance Officer by mailing at [email protected]. We will respond to your request to change, correct, or delete your Personal Information within a reasonable timeframe and notify you of the action we have taken.

You also have the right to complain to a national or international data protection authority about our collection and use of your Personal Information. Please refer to the contact details of such data protection authorities accordingly.