Wisdom Account Privacy Policy

Our privacy policy was updated on February 1, 2023.

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

Introduction

Wisdom Account and its related services, including account creation, sign-in, and management, are provided by Wisdom, Inc. and its affiliated companies (hereinafter referred to as "Wisdom", "we", "our", or "us").

We are committed to protecting your personal information and privacy. The Wisdom Account Privacy Policy (hereinafter "this Privacy Policy") sets out the principles on which Wisdom Account operates, and constitutes an important part of Wisdom Privacy Policy. In the event of inconsistency between this Privacy Policy and Wisdom Privacy Policy with respect to Wisdom Account, the former shall prevail. For the terms and conditions not stipulated in this Privacy Policy, Wisdom Privacy Policy shall prevail. Terms and conditions regarding security measures and cross-border data transmission can be found in the Wisdom Privacy Policy.

This Privacy Policy is designed with your needs in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, while ensuring that ultimately, you have control of your personal information provided to us. This Privacy Policy explains how we collect, use, disclose, process, and store any information that you give us when you use Wisdom Account.

Ultimately, what we want is the best for all our users. Should you have any questions about our data handling practices as summarized in this Privacy Policy, please contact us via https://www.wisdomindustry.com/en/contact to address your specific concerns. We will be happy to hear from you.

1. What information we collect and how we use it

1.1 Personal information that we collect and use with your authorization

The purpose of collecting personal information is to provide you with Wisdom Account products and/or services, and to ensure that we comply with applicable laws, regulations, and other regulatory requirements. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our products or services or respond to your queries.

1.1.1 Basic features

A.Creating accounts and signing in

When creating a new Wisdom Account, you'll need to provide a phone number or email address to use as an account name and create a password. Your account and password will be encrypted and stored to our servers. We strongly advise you not to share your password information to prevent theft of your Wisdom Account by others.

In order to avoid your manual input, we will automatically obtain your mobile phone number and fill it for you when registering and logging in. To do this, we need to obtain your SIM card IMSI, ICCID, device model, system version information, and networking status. The above functions may require you to open your network permissions and Wi-Fi status permissions to us in your device to realize the collection and use of the information involved in these functions.

B. Completing account information

While using various Wisdom services, you may receive better service quality and user experience by adding basic information to your Wisdom Account profile, including profile photo, nickname, and gender, as well as setting up a secret question for security purposes. If you choose not to provide this information, this will not affect your use of the basic services and features of Wisdom Account.

1.1.2 Features necessary for ensuring account creation and sign-in security

In order to enhance system security when you use our products and/or services, prevent phishing website fraud, and protect account security, we will verify your identity through your account password as well as SMS and email verification.

To ensure the security of your account creation and sign-in environment, we will also collect your account creation or sign-in time, device-related info (such as device IMEI or OAID for Android Q and later, device model, and OS version), device sensor info (such as accelerometer and angular velocity), Bluetooth address, network info (such as MAC address, WLAN SSID, and frequently used IP addresses). To be able to collect your device IMEI/OAID, we'll need permission to access device info. We will also provide your phone number to a third party (such as the phone number risk level database and the carrier's recycled number assessment service) for verification to ensure the security of your account.

1.2、You are fully informed that we may collect and use personal information without your consent if:

1.2.1、The personal information is vital to national security and defense;

1.2.2、The personal information is vital to public safety, public health, and major public interests;

1.2.3、The personal information is related to criminal investigations, prosecutions, trials, or execution of judgments;

1.2.4、The personal information is essential for protecting major legitimate rights (including life and property) and interests of the personal information subject or other people, but it is hard to obtain the subject's consent;

1.2.5、The personal information collected is made public by the subject at their own discretion;

1.2.6、 The personal information is collected from public sources, such as news reports or government announcements;

1.2.7、The personal information is necessary for us to sign the contract as required by you;

1.2.8、The personal information is necessary to maintain the safe and steady operation of products and/or services provided, such as for discovering and handling faults of products and/or services;

1.2.9、The personal information is required for legal news releases;

1.2.10、The personal information is de-identified in the results of statistical or academic research based on public interest.

1.3、Collection of the personal information from third-party sources

When permitted by law, we will collect information about you from third-party sources. For example, you may authorize the pairing of a third-party account with your Wisdom account, sign in to the third-party account to use Wisdom services, or authorize your profile photo, nickname, or other information to be imported to the third-party platform; for risk management purposes, we may receive information regarding the security of your account creation/sign-in environment (such as from phone number risk level databases and your carrier's recycled number assessment service) via a third party; we may obtain your phone number from the carrier when you use quick sign-in services; or your family or friends may enter your Wisdom Account ID or phone number when they invite you to use sharing-related services.

1.4、Non-personally identifiable information

We may also collect other types of information which are not directly or indirectly linked to an individual (and which may not be defined as personal information). This information may include statistical data generated when you use a specific service, such as sign-in/sign-out records, interaction records, and error records when you use Wisdom Account services. The purpose of such collection is to improve the services we provide to you. The type and amount of information collected depends on how you use our products and/or services. We aggregate this information. In its aggregated form, data is not personal information and cannot be used to identify you. However, if we combine non-personally identifiable information with personal information, such combined information will be treated as personal information for as long as it remains combined.

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

In order to provide you with the services described in the purpose of this privacy policy, we may share necessary personal information with partners and other third parties, including:

2.1 We guarantee that only for the legitimate, legal, necessary, specific and clear purpose of sharing and providing you with personal information necessary for the service. In addition, we will take encryption and other means to ensure your information security. We will stipulate the practices and obligations of the third party through the contract to ensure that the third party service provider complies with the applicable privacy standards in your jurisdiction. You should understand that our authorization includes sub-processors for third-party service providers.

2.2 Secondary number check service: The secondary number check service of mobile phone number in this business is provided by the third party China Telecom operator, China Unicom operator and China Mobile operator. For this purpose, we may provide your mobile phone number and the binding time of your mobile phone number in WISDOM (accurate to days) to such service providers.

2.3 When you log in with WISDOM account on a third-party website/application, and after your authorization and consent, we will send your nickname, avatar and other information (depending on the nature of the third-party's service and product) to the third-party. If you do not agree with the third party to obtain your personal information, please do not agree with the authorization.

3. Retention policy

We retain personal information for the period necessary for the purpose of the information collection described in this Privacy Policy or as required by applicable laws. We will cease to retain, and thus delete or anonymize personal information once the purpose of collection is fulfilled, or after we confirm your request for erasure, or after we terminate the operation of the corresponding product or service. An exception to this is personal information that we are processing for public interest, scientific or historical research, or statistical purposes. We will continue to retain this type of information for longer than its standard retention period, where permitted based on applicable laws, even if further data processing is not related to the original purpose of collection.

4. Your rights

4.1 Controlling settings

We recognize that everyone has different concerns about privacy. Therefore, we have provided some examples to illustrate the various ways provided by the WISDOM account for you to choose, to limit the collection, use, disclosure or processing of your personal information, and to control your privacy settings;

4.2 Your rights to your personal information

Depending on applicable laws and regulations, you have the right to access, copy, rectification, and erasure of any other personal information that we hold about you (hereinafter referred to as "the request"). We also provide you with the option to withdraw your consent to our processing of your personal information and cancel services.

The request should meet the requirements of applicable laws and the following conditions:

• The request is submitted through Wisdom's exclusive request channel detailed above and for the protection of your information security, your request should be in writing (unless the local law explicitly recognizes the oral request);

• You provide sufficient information to enable Wisdom to verify your identity and ensure that you are the data subject or legally authorized to act on the data subject's behalf.

Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws. In detail:

• Based on the requirements of applicable laws, a copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests for relevant information, we may charge a reasonable fee based on actual administrative costs according to and if permitted by the applicable laws.

• If any information we are holding on you is incorrect or incomplete, you are entitled to have your personal information corrected or completed based on the purpose of use.

• Based on the requirements of applicable laws, you have the right to request the deletion or removal of your personal information where there is no compelling reason for us to keep using it. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures. Please note that we may not be able to immediately remove the information from the backup system due to applicable law and/or technological limitations. If this is the case, we will securely store your personal information and isolate it from any further processing until the backup can be deleted or be made anonymous.

We have the right to refuse to process requests that are not meaningful, manifestly unfounded or excessive, requests that damage others' right to privacy, extremely unrealistic requests, and requests that require disproportionate technical work, as well as requests not required under local law, regarding information that has been made public, and regarding information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, the request may also be rejected.

4.3 Withdrawal of consent

• Please note that your withdrawal of consent may result in certain legal consequences. Additionally, you may not be able to continue receiving the full benefit of Wisdom's products and services, depending on how much authority you grant us to process your information. The withdrawal of your consent or authorization will not affect the validity of our processing carried out on the basis of the consent up until the point of withdrawal.

4.4 Canceling a service or account

To protect your or others' legitimate rights and interests, we will judge whether or not to support your request for cancellation based on your use of various Wisdom products and services. Before canceling services, please confirm that you have completed all necessary actions related to other services connected to your Wisdom Account, otherwise we will not be able to immediately support your cancellation request. We may verify your identity by asking for information such as the mobile phone number associated with your Wisdom Account. We strictly abide by the laws and administrative regulations on the protection of personal information and will only use this information for the purpose stated above.

Please note that the cancellation of your Wisdom Account is irreversible. We will delete or anonymize all the information associated with your Wisdom Account. After cancellation, you won't be able to use some Wisdom products and services.

5. Contact us

If you have any comments or questions about this privacy policy, or if you have any questions about our collection, use or disclosure of your personal information, please visit https://www.wisdomindustry.com/en/contact Contact us and mention the Privacy Policy. We have a professional team to solve your problems when you ask for personal information and ask questions. If your question itself involves more important matters, We may ask you for more information. If you are not satisfied with the response received, you can refer the complaint to the relevant regulatory authority in your jurisdiction. If you consult us, we will provide information about the relevant complaint channels that may be applicable according to your actual situation.

Address:

Floor 1 and 4, No. 9, Zhangbei Road, Longcheng Street, Longgang District, Shenzhen

Postal Code 518172

New Wisdom Investment Limited

Telephone 400 886 9058

Email info@wisdom.hk