Introduction

Welcome to use our products and services! We understand the importance of personal information to you, and your trust is very important to us. We will strictly comply with legal and regulatory requirements, adhering to the principles of lawful, proper, and minimum necessity, while taking appropriate security measures to protect the safety and controllability of your personal information. Based on this, the HuoPan service provider (or simply "we") has developed this "HuoPan Basic Function Privacy Policy" (hereinafter referred to as "this Policy"/"this Privacy Policy") to help you fully understand how we collect, use, share, store, and protect your personal information, and how you can manage your personal information while using our products and services, so that you can make better and appropriate choices.

Before you start using our products and services, please make sure to carefully read and understand this Policy, especially the terms marked in bold or bold underline. Ensure you fully understand and agree before starting to use our services. For any professional terms involved in this Policy, we have tried to explain them in simple and understandable language. If you have any questions, opinions, or suggestions about the content of this Policy, you can contact us using the contact information at the end of this Policy.

This Policy applies to the various online shopping basic functions, products, and services provided to you by HuoPan service providers through websites, clients, and other new forms of technology development.

Except for the information collection and use activities described in this Policy, this Policy does not apply to other services provided to you by third parties. For those services, their respective personal information collection and use rules will apply.

2. Information Collection and Use

To provide you with the basic functions of our products and/or services, you need to authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services properly.

We provide the following specific functional scenarios for you:

(1) Help you become our member and manage your account

1. HuoPan Platform Account Service

We provide services based on your HuoPan platform account. To create a HuoPan platform account (also known as "HuoPan account" or "HuoPan account"), you need to provide at least your mobile phone number, the username you wish to use, and a password. If you refuse to provide this information, you will not be able to register for a HuoPan platform account, and you will only be able to browse and search. Based on your usage of the HuoPan platform account and the account level calculation rules set by the platform, we will determine your current level and provide the corresponding basic rights associated with your account level.

You can use the services provided by us and/or affiliated companies through your HuoPan platform account via links provided on our website or client, or other product/service entrances. To help you manage your HuoPan platform account, we will synchronize and display your registration information, as well as the operations you perform on the HuoPan platform or with services related to your HuoPan platform account. These will include your personal profile, discounts, and transaction orders. The information linked to your HuoPan platform account will be used to provide customer services, identify account security risks, and recommend products or services that may interest you.

You can set your nickname, gender, and avatar, and this information will be displayed publicly in evaluation, sharing, and other interactive scenarios. You can also set your birth month and day. HuoPan may display birthday-related benefits based on your month and day information. This information is considered non-essential personal information, and not providing it will not affect your ability to use HuoPan platform services.

2. Identity Verification

To comply with legal regulations and regulatory requirements, ensure user identity authenticity, prevent fraud, and ensure system and service security, we need to collect your relevant information for identity verification when you use certain services/functions, such as:

【Account Recovery】When you use functions like "Recover HuoPan Account" or "Recover Password," we may collect your identity information, including your real name or other information that can verify your identity (such as email) to help you recover your HuoPan platform account.

【Real Name/Real Person Authentication】To facilitate special product or service transactions, verify identities for specific membership roles, or meet other legal requirements (including protecting minors' rights, fighting telecom fraud, collecting personal income tax, administrative or judicial recognition in related cases), you need to undergo real-name or real-person authentication. To complete the verification, you need to provide relevant real identity information (such as name, ID card number, etc.) or facial recognition information, as per the page prompt. You also authorize us to verify this information through national authoritative identity verification institutions or acquire necessary authentication information from your payment account company. We will record and store this information for authentication purposes only, or for other legally required purposes. We will not use it for other purposes without your explicit authorization. Furthermore, when you participate in promotions or interactive activities on the platform, we may query the real-name status of your payment account to verify your participation conditions and ensure a better experience.

(2) Display Product or Service Information to You

1. Browsing

When you browse HuoPan site, you can choose to collect/add/share products you are interested in. We will collect your operation records for the above functions and other purposes we have clearly notified you about.

You can view and manage your operation records in "My HuoPan"—"Favorites"/"Shopping Cart" and other sections.

2. Search

When you use the search function (including image, voice search), we will collect your search records, including search content (search terms, images, voice information), browsing records/time, and search times. We may request microphone permission, camera permission, or images you provide.

To provide efficient search services, some of the above information will be temporarily stored on your local device and show you the search history.

3. Personalized Recommendations

To recommend products or services you may be interested in, we will collect and use your browsing, search, add-to-cart, and transaction records while using HuoPan platform websites or clients. We will combine this with device information, service logs, and other information you have authorized us to collect to predict your preference features. Based on your preferences, we will push advertisements and other relevant information to you on HuoPan and other third-party applications or terminals. We will also send you commercial messages. We will also use statistical analysis on the hot trends of products or services browsed and searched on HuoPan platform, and recommend selected lists of related products or services.

Personalized recommendations and search algorithms will predict your preference features based on models, matching products, services, or other information that may interest you, and sort the displayed information accordingly. We will continuously adjust and optimize the recommendations based on your browsing behavior during the use of the product. To meet your diverse needs, we will introduce diversified recommendation technologies during the sorting process, expanding the content recommended to avoid over-concentration of similar content.

At the same time, we take the following measures to ensure your privacy experience:

1. If you do not want to receive advertisements or commercial messages from us, you can unsubscribe via SMS, email, or phone, or use other unsubscribe methods provided by our customer service;

2. If you want to view results that are not tailored to your personal characteristics while using our site search services, you can click "Filter" on the search result page and select "General Sorting";

3. If you do not want to see products or services recommended on the Home Page or Payment Completion Page, you can long press the recommended product or service image and choose to block similar products or categories in the pop-up window;

4. If you want to manage personalized advertisements sent by us, you can do so in "My HuoPan - Settings - Privacy Settings - Advertisement Management." If you set this when logged out, please set it again after logging in.

5. If you want to manage personalized content pushed by us, you can do so in "My HuoPan - Settings - Privacy Settings - Recommendation Management." If you set this while logged out, please set it again after logging in.

(3) Helping You Complete Transactions

1. Shopping Cart

When you use the shopping cart function, we collect the information about the products you have added to the cart and use your order information to optimize your shopping experience (such as price drop/discount reminders, screening of frequently purchased items, recommendations of specific shopping cart sharing links, etc.).

2. Placing Orders and Order Management

When you order specific goods and/or services from our products and/or services, we generate an order for the purchase of those goods and/or services through the system. During the ordering process, you are required to provide at least your recipient's name, delivery address, and contact number. For certain special types of goods and services, you may also need to provide additional information necessary for that item or service, such as identity document information for cross-border transactions to complete customs clearance. You may also choose to provide or select additional information such as other contact numbers and preferred delivery times to ensure the accurate delivery of goods or services. If you need an invoice, you will also need to provide the invoice title, taxpayer identification number, and the email address to receive the invoice.

The order will include the details of the goods and/or services you have purchased, the specific order number, the order creation time, the discounts you have used, the amount you need to pay, and any notes you have made. We collect this information to help you successfully complete the transaction, ensure transaction security, allow you to query order information, provide customer service and after-sales support, conduct reconciliation, and for tax declarations related to discount information (if required) and other purposes we explicitly inform you of.

You can also place orders for goods and/or services for others via HuoPan. You will need to provide the recipient’s personal information mentioned above and ensure that you have obtained the recipient’s consent.

To help you understand, query, and manage order information, we collect the order information generated when you use our services to display it and facilitate your order management.

You can view and manage your order information through "My HuoPan" — "My Orders".

3. Payment and Delivery of Goods or Services

When you purchase goods or services, in order to help you complete the order payment or assist others in completing it, and ensure smooth receipt of the purchased goods or services, we or the third-party service provider may collect your order and delivery information. Please refer to the section "3. Cooperation Partners and Transfer of Personal Information in Data Usage" — "(A) Data Usage Partners" — "5. Cooperation Scenarios — 1) Business Function — A. Payment Service / B. Logistics Service" for more details.

(4) Providing Information Publishing Functions

1. Reviews and Comments

When you leave a review for a purchased item or service, we will collect and publicly display your review and shared content (including text, images, videos, etc.), avatar, and nickname on pages within and outside the store. If you choose to post anonymously, your avatar and nickname will not be displayed to other users, except when you choose to publicly share the review. If you post anonymously and later choose to publicly share, your avatar and nickname will be displayed in the shared channels.

When you comment on a review or content posted by another user, your avatar, nickname, and comment will be publicly displayed.

You can ask questions to users who have already made a purchase. When you are a buyer, you may receive an invitation to answer questions posted by others. If you choose to ask or answer questions, your question and answer content, along with your avatar and nickname, will be publicly displayed.

2. Personal Profile

The personal profile displays your avatar, nickname, published content, and related interaction information (followers, following, comments/likes, reviews, Q&A, favorites, etc.). Other users can view your profile by searching your HuoPan nickname (you can turn off this feature through "My HuoPan" — "Settings"). You can access your "Personal Profile" by clicking the avatar in the top-right corner of "My HuoPan", where you can view and manage your profile information and published content, as well as adjust privacy settings for your profile.

Please note that using the information publishing functions may involve sharing personal or sensitive personal information about yourself or others. Please consider carefully whether to share or publicly share such information when using our services. If the information you share involves the personal information of others, you must obtain their consent before posting.

(5) Notifications and Interactive Communication

1. Message Notifications

During our operations, we may send one or more types of notifications to your provided contact information (such as phone number, email) while using our products and/or services, such as service notifications, identity verification, security checks, user experience surveys, etc. We may also send commercial messages and other product or service information you may be interested in via SMS or popup notifications. If you do not wish to receive our commercial messages and other product or service information, you can unsubscribe or close the notifications using the unsubscribe options in the SMS, phone call, or email, or consult our customer service. If you wish to turn off popup notifications, you can go to the notification settings in "My HuoPan — Settings — Message Notifications", or use the "Skip" button or related buttons in the popup to close them.

Additionally, when you initiate customer service inquiries or interact with a store (e.g., subscribing to the store, joining store membership), you will receive customer service messages in "Messages". You can enter the store's chat page to set Do Not Disturb.

2. Activity Participation

When you participate in marketing or interactive activities hosted by us, we may need to collect and use your personal information (including but not limited to your nickname, avatar, contact details, delivery information, order details, browsing history, account level) to help you register for the activity, participate, enjoy the activity benefits, enter lotteries, redeem prizes, etc. Please pay attention to the specific personal information collection and usage scope that will be notified to you separately in the relevant scenarios, and participate only after agreeing to it.

If the activity is jointly organized by us and affiliated or third-party companies, we will share necessary information with these parties after obtaining your consent, or link your HuoPan account to the third-party platform account, and/or synchronize your account participation status, progress, and specific benefits across multiple platforms to ensure consistent and complete service in the activity.

3. Sharing and Interaction

When you share or receive shared information, or participate in activities, we may read the contents of your clipboard to check for related codes, sharing links, or instructions to achieve redirection, sharing, or activity linkage. However, we only upload clipboard content to our server when it matches HuoPan instructions, and we do not collect or store other clipboard information. The clipboard data cannot identify your personal identity. Additionally, we may need to access your photo album to facilitate sharing or receiving shared images or videos.

(6) Customer Service and Dispute Resolution

When you contact us or request assistance for pre-sale, post-sale, or dispute resolution, we may need to collect necessary personal information to verify your membership identity.

To facilitate communication with you, resolve issues promptly, or document related resolutions, we may store your communication records, including account information, order information, other information you provide to verify relevant facts, or your contact details. If you inquire, complain, or provide suggestions regarding a specific order, we will use your account and order details.

For the reasonable need to provide services and improve service quality, we may also use other information, including details you provide during customer service interactions and responses from surveys you participate in.

We use deep learning techniques to provide intelligent Q&A and voice-based customer service. The communication records are anonymized and used to train our intelligent customer service algorithms. We will notify you clearly when using intelligent customer services. Based on your interaction with the intelligent customer service, we continuously improve the service quality.

(7) Providing Security Protection

We are committed to providing a secure and trusted e-commerce transaction environment. To ensure the order and transaction security, prevent and handle telecom fraud, maintain the stability of the network, protect personal and property safety, and better identify violations of laws or HuoPan rules, we collect device identifiers (Android ID), variable identifiers (IDFA, IDFV, OAID, GAID), app information (app crash reports, notification switch status, app runtime processes, etc.), system and device information (device type, model, OS, hardware details), network environment information (IP address, WLAN-related protocols excluding Wi-Fi Mac address, Bluetooth data, device sensor data, and other network info), operator information, broadcast communication data. To prevent phishing sites, fraud, and network attacks, we only process software installation data locally and do not upload it to the server.

We may use the above information and HuoPan account data, service logs, and other information authorized or legally provided by our affiliates and partners to assess account and transaction security, perform identity verification, detect and prevent security incidents, and take necessary actions.

(8) Other Additional Services

1. Additional Services Based on System Permissions

We may collect and use your personal information by requesting system permissions for certain basic features. For example, to help you quickly fill in shipping addresses, recommend nearby products or services, or add locations to your posts, we may request location permissions and collect your location information. If you disagree with granting these permissions, it will not affect your use of HuoPan's basic services. You can manage these permissions anytime in your device settings or in "My HuoPan — Settings — Privacy — System Permissions".

2. Cookies and Similar Technology Services

Cookies and similar technologies are commonly used on the internet. When you use our services, we may use such technologies to send one or more cookies or anonymous identifiers (collectively referred to as "Cookies") to collect, identify, and store information about your access and usage of this product. We promise not to use cookies for any other purposes not covered in this privacy policy. We mainly use cookies to ensure the security and efficient operation of products and services, confirm the safety of your account and transactions, identify and troubleshoot issues, and assist you in filling out forms and inputting search content more efficiently.

We may also use cookies to display information or functions that may interest you and optimize your advertisement preferences. Most browsers offer a feature to clear browser cache data, and you can modify your cookie acceptance settings or reject our cookies. Please note that such changes may affect your ability to use services or features that rely on cookies.

(9) Other Rules for Collecting and Using Personal Information

1. If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing this personal information to HuoPan.

2. If we use the information for purposes not specified in this policy, or if we use information collected for a specific purpose for other purposes, we will obtain your consent in advance.

3. Under the premise of being processed using secure encryption technology and strictly de-identified, we will use the collected data for machine learning, algorithm model training, or other data analysis and mining to better protect our product experience, assist business decision-making analysis, and model optimization.

3. Cooperation Partners Involved in Data Use and Transfer, Disclosure of Personal Information

(1) Cooperation Partners Involved in Data Use

1. Basic Principles

When cooperating with partners, we will adhere to the following principles:

(1) Legality, Justice, and Minimum Necessity Principle: Data processing should be legally grounded, with legitimate purposes, and limited to the minimum necessary scope to achieve the purpose.

(2) Maximizing Users' Right to Know and Decide: During data processing, we will fully respect users' right to be informed and decide how their personal information is processed.

(3) Strengthening Security Assurance Principle: We will take necessary measures to ensure the security of the personal information processed, carefully assess the purpose of data usage by partners, conduct a comprehensive security capability evaluation of these partners, and require them to follow the relevant provisions of the cooperation agreement.

2. Scope of Cooperation Partners

If a specific function or scenario involves services provided by our affiliates or third parties, the scope of cooperation partners includes our affiliates and third parties.

3. Entrusted Processing

We may entrust authorized partners to process your personal information to provide certain services or perform functions on our behalf. We will only entrust them with processing your information for legal, legitimate, necessary, specific, and explicit purposes as stated in this policy. Authorized partners may only access the information necessary to perform their duties, and we will require them through an agreement not to use this information for any purposes outside the scope of the entrusted task. If the authorized partner uses your information for purposes not entrusted by us, they will obtain your separate consent.

4. Joint Processing

For scenarios involving joint processing of personal information, we will sign relevant agreements with partners according to legal requirements, specifying each party’s rights and obligations to ensure compliance with relevant laws and protection of data security during the use of personal information.

5. Cooperation Scenarios

(1) Achieving Business Functions

A. Payment Services

To complete an order payment, you can pay through services provided by institutions cooperating with us (including Paypal, OTTPAY payment, and other payment methods provided on the page). We will collect your account information, order payment-related information, and other legally required information during the payment process and share it with the payment institutions to confirm your payment instructions and assist you in completing the payment. Payment institutions may also independently or entrust us to collect or verify your bank card (including debit and credit cards) information and other necessary payment information. If the information is collected by us, we will share it with the relevant payment institution you choose.

To enable us to timely learn and confirm your payment progress and status, and provide after-sales and dispute resolution services, you agree that we may collect payment progress information from the transaction party or payment institution you have chosen.

You may request someone else to make a payment on your behalf, in which case you need to provide the payer’s payment account and/or phone number. You can view or request to change the payment account bound to your HuoPan platform account in "My HuoPan-Settings."

B. Logistics Services

To ensure that the goods and/or services you purchase are delivered smoothly, safely, and accurately, we will disclose the order's delivery information to【Shanghai Youdilian Technology Co., Ltd.】, which provides logistics information systems and technical services for the HuoPan platform. They will share the related delivery information with the corresponding logistics delivery provider based on the choice of the product and/or service provider. You acknowledge and agree that the logistics delivery provider may inevitably access and use your delivery information for the purpose of completing delivery.

To provide after-sales and dispute resolution services, we need to timely learn and confirm delivery progress and status, and you agree that we may collect delivery progress-related information from the logistics service provider.

(2) Security and Statistical Analysis

A. Ensuring Usage Security: We highly value the security of our products and/or services. To protect users' legitimate rights from unlawful infringements, the entrusted processing partners may use strictly de-identified and non-reversible necessary device, account, and log information.

B. Analyzing Product Status: To analyze the stability of the product and/or service, partners providing analytical services may need to use service status, device identifiers, overall app installation and usage information, etc.

C. Academic Research: To improve research capabilities in relevant fields and promote technological development, we may share de-identified or anonymized data with partners (such as research institutes, universities, etc.) under the premise of ensuring data security and legitimate purposes.

(3) Other Cooperation Scenarios

In addition to the cooperation scenarios mentioned above, we may also entrust other partners supporting our business to process information, including those providing technical infrastructure services, analyzing how our services are used, or offering membership services or other customer services.

To ensure the stable operation and functionality of our client applications, and to allow you to use and enjoy more services and functions, we may embed SDKs or other similar applications from authorized partners in our application. We will conduct strict security checks on the API and SDKs used by authorized partners to acquire relevant information, and will agree on strict data protection measures with them, ensuring they process personal information according to this policy and any other relevant confidentiality and security measures, except where the authorized partners have separately obtained your consent.

(2) Transfer

If we need to transfer personal information due to mergers, divisions, dissolution, or bankruptcy, we will notify you of the name or contact details of the receiving party. The receiving party will continue to fulfill the obligations of this policy and other legal obligations. If the receiving party changes the original processing purpose or method, your consent will be obtained again.

(3) Public Disclosure

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

1. Based on your active choice and other separate consent, we may disclose your personal information;

2. If we determine that you have violated laws or regulations, or severely violated HuoPan platform agreements and rules, or to protect the personal and property safety of HuoPan platform users or the public from infringement, we may disclose your personal information, including the relevant violations and the measures HuoPan platform has taken against you.

(4) Discontinuation of Operations

If we discontinue the operation of products and/or services, we will stop collecting your personal information. We will notify you individually or via an announcement regarding the cessation of operations, and delete or anonymize the personal information related to the discontinued products and/or services according to the methods outlined in the privacy policy【Information Storage-Storage Period】 and 【Your Rights-Deletion】.

(5) Legal Exemption from Obtaining Your Authorization and Consent

Please understand that in the following circumstances, according to laws, regulations, and national standards, partners may use, or we may transfer or disclose your personal information without obtaining your authorization and consent:

1. Necessary for fulfilling a contract or performing an agreement: When you purchase goods or services through the HuoPan platform, we will share the necessary order-related information with the relevant product or service provider or operators in the relevant service market on the HuoPan platform to fulfill your transaction, delivery, and after-sales service requirements.

2. Necessary to fulfill legal duties or obligations: We may share your personal information according to laws, regulations, litigation, dispute resolution requirements, or according to administrative, judicial, or supervisory authorities’ legal requests, as well as other necessary legal obligations.

3. Necessary to respond to public health emergencies, or to protect life, health, and property safety in emergency situations.

4. To implement public interests such as news reporting, public opinion supervision, etc., processing personal information within a reasonable scope.

5. Processing personal information you have disclosed or other legally disclosed personal information (such as legally disclosed personal information in news reports, government information disclosure, etc.).

6. Other circumstances specified by laws and regulations.

4. Your Rights

You can access and manage your information in the following ways, we will respond to your requests in accordance with applicable laws and regulations:

(1) Access, Correction, and Supplementation

You have the right to access, correct, and supplement your information through the following ways:

1. Log into HuoPan website, go to "My HuoPan", and select "Account Settings";

2. Log into HuoPan client, go to "My HuoPan - Settings";

3. Log into HuoPan and select "Contact Customer Service".

(2) Copy

You can copy your information through the following ways:

1. Log into HuoPan client, go to "My HuoPan - Settings - Privacy - Download Personal Information";

2. You can query and then copy your personal information through the paths listed in "(1) Access, Correction, and Supplementation".

(3) Deletion

You can delete some of your information through the paths listed in "(1) Access, Correction, and Supplementation", or apply to cancel your account and delete all your information.

In the following situations, you can request the deletion of your personal information by contacting customer service:

1. If we process personal information in violation of laws and regulations;

2. If we collect and use your personal information without your explicit consent;

3. If our processing of personal information seriously violates agreements with you;

4. If our processing purpose has been achieved, is impossible to achieve, or is no longer necessary to achieve;

5. If we stop providing products or services, or the retention period has expired.

If we decide to respond to your deletion request, we will also notify the entities that obtained your personal information from us, requesting them to delete it in a timely manner (unless otherwise required by laws and regulations, or those entities have independently obtained your authorization).

If you or we assist in deleting relevant information, due to applicable legal and security technology restrictions, we may not be able to immediately delete the corresponding information from backup systems. We will securely store your personal information and limit any further processing of it until the backup can be cleared or anonymized.

(4) Change Authorization Scope

You can change or withdraw the scope of your authorization for us to collect and process your personal information in the following ways:

1. Manage authorization in "My HuoPan - Settings - Privacy - Find My Way".

2. Manage authorization in "My HuoPan - Settings - Privacy - Personal Homepage".

3. Manage system permissions in "My HuoPan - Settings - Privacy - System Permission Management".

4. Manage authorized applications in "My HuoPan - Settings - Privacy - Authorization Management".

For authorizations that cannot be directly set through the above methods, you can modify them by contacting customer service, but please note that for some types of personal information, such as information necessary for the basic functionality of HuoPan or information required to fulfill legal obligations, we may not be able to respond to your request to change the scope of authorization. After you withdraw your authorization, we will no longer process the corresponding personal information. However, your decision to withdraw authorization will not affect the processing of personal information we carried out based on your prior authorization.

(5) Account Cancellation

You can apply for account cancellation through the following ways:

1. Submit an account cancellation request in "My HuoPan - Settings - Account & Security - Cancel Account";

2. Apply for account cancellation by contacting customer service.

To protect the rights of platform users and the security of orders, HuoPan account cancellation requires meeting certain conditions. After you voluntarily cancel your account, we will stop providing products or services to you and, in accordance with applicable laws, delete or anonymize your personal information.

(6) Restrict Automated Decision-Making

In some business functions, we may make decisions based solely on algorithms or other non-human automated decision-making mechanisms. If these decisions affect your legal rights, you can contact customer service to reach us.

(7) Response to Your Requests

For requests made by you, your guardian, close relatives, or other authorized individuals regarding the rights related to your personal information, as well as the rights defined by the laws of the People's Republic of China or your country's laws and other applicable laws, you can contact customer service or directly file a complaint with our personal information protection department. We will respond within 15 days.

To ensure your account and personal information security, we may verify your identity before processing your request (such as adding account verification, requiring you to provide a written request, or other reasonable methods).

For reasonable requests, we generally do not charge fees. However, for repeated requests that exceed reasonable limits, we may charge a fee at our discretion. We may refuse requests that are not directly related to your identity, lack reasonable grounds, are repeated without valid reasons, or require excessive technical efforts (e.g., developing new systems or fundamentally changing existing practices), cause risks to the legitimate rights of others, or are unrealistic.

5. Information Storage

(1) Retention Period

We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless required by law for mandatory retention, such as the requirement under the "Electronic Commerce Law of the People's Republic of China" that requires the retention of product and service information and transaction information for no less than three years from the completion of the transaction.

We determine the storage period of personal information based on the following criteria:

1. Completing the transaction purpose related to you, maintaining corresponding transaction and business records, to respond to possible queries or complaints;

2. Ensuring the security and quality of the services we provide to you;

3. Whether you agree to a longer retention period;

4. According to the statute of limitations requirements;

5. Whether there are other special agreements or legal provisions regarding the retention period.

After the retention period expires, we will delete or anonymize your personal information in accordance with applicable laws.

(2) Storage Location

In principle, we store the personal information collected and generated according to applicable laws abroad. We will only provide your personal information abroad for purposes necessary to fulfill our contract with you or other legitimate processing reasons. For example, to fulfill your cross-border transactions, cross-border logistics delivery, receipt, customs clearance, and after-sales service needs, we or our affiliates may transfer necessary information related to your order, including the recipient's address, abroad. Such foreign countries or regions may have different data protection laws or may not have relevant laws. In such cases, we will assess and make every effort to ensure that your personal information is protected with sufficient security, similar to the protection in China, such as de-identifying the shipment information, encrypting transmissions, regularly evaluating the security capability of the recipients, and signing data processing agreements/terms. If we need to transfer your personal information abroad due to business needs, we will comply with laws, regulations, and the requirements of relevant regulatory authorities, inform you of the name, contact details, processing purpose, processing methods, categories of personal information, and how you can exercise your rights with the overseas recipient in the relevant service agreements or specific functional pages, and obtain your separate consent (if applicable). Specific seller information can be found on the individual store page. Before providing your personal information abroad, we will take measures such as security assessments, professional institution certifications for personal information protection, or signing standard contracts with overseas recipients in accordance with the legal conditions for providing personal information abroad.

(3) Storage Security

1. Data Protection Technical Measures

We have adopted security measures that meet industry standards and are reasonably feasible to protect your information from unauthorized access, disclosure, use, modification, damage, or loss. For example, we use encryption technology to enhance the security of personal information, SSL protocol is used to protect the data exchanged between your browser and the server, we provide HTTPS protocol for secure browsing, use trusted protection mechanisms to prevent personal information from malicious attacks, and deploy access control mechanisms to ensure that only authorized personnel can access personal information.

2. Data Protection Management Organizational Measures

We have established an industry-leading data security management system focused on data, covering data lifecycle management from organizational construction, system design, personnel management, and product technology dimensions to improve the security of personal information. We have set up a personal information protection department and designated specific personnel responsible for children's personal information protection. We continuously strengthen employees' awareness of the importance of protecting personal information through training courses and exams.

3. Response to Personal Information Security Incidents

If our physical, technical, or management protective measures are damaged, resulting in unauthorized access, disclosure, alteration, or destruction of information, and causing harm to your legitimate rights, we will promptly initiate an emergency plan and take reasonable and necessary measures to minimize the impact on you. In case of a personal information security incident, we will also inform you of the basic situation of the security incident and its possible impact, the actions we have taken or will take, suggestions for you to prevent and reduce risks, and remedial measures through SMS, phone, push notifications, or other reasonable channels. If we cannot individually notify you, we will publish an announcement in a reasonable and effective way. We will also report the handling of the personal information security incident to the regulatory authorities as required.

4. Prevention of Account Security Risks

When using HuoPan network services for online transactions, you inevitably need to disclose your personal information, such as contact details or address, to the transaction counterparty or potential counterparties. Additionally, you can also communicate, exchange information, or analyze content through our services with third parties. Please protect your personal information properly and only provide it to others when necessary, and be cautious about conducting transactions through other transaction tools to avoid information theft or telecommunications fraud.

If you are concerned that your personal information, especially your account or password, has been leaked, please contact HuoPan customer service immediately so we can take appropriate measures based on your application. You can also independently manage "Device Management", "Account Maintenance", and "Account Locking" in "My HuoPan - Settings - Account & Security - Security Center", as well as report fraud.

6. Policy Updates

To bring you better products and services, we are continuously improving our products, services, and technology. When new services and business processes change, we may update our privacy policy to notify you of specific changes. However, without your explicit consent, we will not limit your rights under this policy. Any changes to this policy will be published on a dedicated page.

For significant changes, we will also provide more prominent notifications (including notifying you through HuoPan network announcements or providing pop-up prompts).

Significant changes refer to, but are not limited to:

1. Major changes in the business model of the product. For example, the purpose of processing personal information, the types of personal information processed, or the ways in which personal information is used;

2. Privacy policy changes due to business adjustments, mergers, or acquisitions, with new recipients of personal information changing the processing purpose and method;

3. Major changes in the main recipients of shared or publicly disclosed personal information;

4. Major changes in user personal information rights and the way they can be exercised;

5. Changes in the contact details or complaint channels for the person responsible for personal information protection;

6. Personal information protection impact assessments indicate that the product has a significant impact on personal rights.

We will also archive the previous versions of this policy on HuoPan network for your review.

7. Protection of Minors

In the course of e-commerce activities, we assume that you have the corresponding civil capacity. If you are a minor, we ask that you carefully read this policy with your parents or other guardians and use our services or provide us with information only after obtaining the consent of your parents or other guardians.

If you are a child under the age of 14, you and your guardian must carefully read the "Children's Personal Information Protection Rules and Guardian Instructions" we have specially formulated before you use our services. Ensure that you can use our services under the guidance of your guardian only after obtaining their consent to the "Children's Personal Information Protection Rules and Guardian Instructions," ensuring your safety when using our services and engaging in transactions.

If you are the parent or other guardian of a child, please ensure that the child is using our services only after obtaining your authorization and consent. If you have any questions about the child's personal information, please contact our personal information protection department.

8. Contact Us

You can contact us in the following ways, and we will reply to your request within 15 days:

1. If you have any questions, comments, or suggestions about this policy, you can contact us through HuoPan online customer service or the HuoPan service center.

2. We also have a dedicated personal information protection department, which you can contact via service@huopan.com (please specify that it is related to "HuoPan" and provide specific details). Office address: [Shenzhen Longhua District Guanghao International Center, Building A]. Please note that we may not respond to questions unrelated to this policy or your personal information rights.

If you are dissatisfied with our reply, especially if you believe that our personal information processing behavior harms your legal rights, you can seek a solution by submitting an arbitration request to the Shenzhen International Arbitration Court.

Appendix: Related Definitions

HuoPan Network: Refers to the HuoPan website (domain name www.huopan.com) and HuoPan app.

HuoPan Network Service Provider: Refers to HuoPan Network's internet information and software technology service provider, HuoPan eCommerce (Hong Kong) Limited.

Payment Account Company: Refers to the entity providing payment account services.

Personal Information: Various information related to an identified or identifiable natural person recorded in electronic or other forms, excluding anonymized information.

Sensitive Personal Information: Sensitive personal information refers to personal information that, if leaked or illegally used, may harm a natural person's dignity or endanger their personal or property safety. This includes biometric data, religious beliefs, specific identities, medical and health information, financial accounts, tracking information, and personal information of minors under the age of fourteen.

Child: Refers to a minor under the age of fourteen.

Device Information: Includes device identifiers (Android), ID, IMEI (only in versions of HuoPanApp before 27.40), variable identifiers (IDFA, OAID, GAID), application information (app crash reports, notification settings, active processes, and other app-related information), device parameters and system information (device type, model, operating system, device sensors, hardware serial numbers, and other hardware-related information), device network environment information (IP address, WLAN (Wi-Fi) information, Bluetooth information, base station information, and other network-related information; WLAN-MAC only collected after location permissions are granted), carrier information, and broadcast component communication information.

Service Log Information: Includes browsing history, click/view records, search queries, favorites, adding to shopping cart, transactions, after-sales information, sharing details, and IP address, browser type, telecom operators, language used, and date and time of access.

De-identification: Refers to the process by which personal information is processed so that it cannot identify a specific natural person without additional information.

Anonymization: Refers to the process by which personal information is processed in a way that it cannot identify a specific natural person and cannot be restored.