Dear user,

The SmartUps APP ("this app") is released by START POINT INTERACTION Co., Ltd. ("START POINT INTERACTION", "we", "us", or "our"). We may collect your personal information during your use of this app. We understand the importance of privacy and are committed to protecting your personal information. Please read and understand this Privacy Statement ("this Statement") before submitting your personal information.

Please note that whether to use this app on your personal device is completely based on your own will. Selecting Agree indicates that you have fully understood and accepted all terms of this Statement. Otherwise, select Cancel and do not use this app.

Please take a moment to familiarize yourself with the following privacy practices:

1. How We Collect and Use Your Personal Information

2. How We Disclose Your Personal Information

3. Your Rights over Personal Information Processing

4. How We Protect Your Personal Information

5. How We Process Children's Personal Information

6. Updates to This Statement

7. Contact START POINT INTERACTION

1. How We Collect and Use Your Personal Information

1.1. How We Collect Your Personal Information

Personal information refers to information that is recorded electronically or in other forms and related to identified or identifiable natural persons, excluding information after anonymization. We may collect your personal information when you interact with us on this app. Different types of data will be collected based on the service you use and our interactions. You are not required to provide personal information to enjoy this app. Please note that certain services may not be available without the requested information. This app will collect and use the following personal information only for the purposes described in this Statement with your consent:

1.1.1 Information Obtained in the Course of Your Interaction with Us or Use of Our Services

(1) Device information. When you connect to a device through WLAN or Bluetooth, the WLAN name or Bluetooth name will be obtained, as well as the device location granted by the location permission.

(2) Log information. While in use, this app will record the run logs, which may include the app fault information. This app will not collect other logs on your mobile phone without your authorization.

(3) Local network device permissions. When you use the WLAN connection function, you can enable this permission so that the app can discover and connect to all your network devices. If you do not need such a service, you can disable the permission at any time. This does not affect the use of other services. You can access the system settings at any time to manage the permissions of the application/service.

1.1.2 Functions Invoked and Data Accessed for Certain Services

(1) Camera. This app provides rich media functions and supports QR code scanning. When you use these functions, this app will ask for your permission to use the camera.

(2) Access the storage medium of the mobile device. This app provides the log download function and exports logs to your mobile device. When you export logs from this app, it will ask for your permission to store the logs on your mobile device.

1.2 How We Use the Information Collected

To provide secure, smooth, effective, and personal user experience, this app uses the collected information or data as necessary to:

● Provide the app registration function.

● Provide the app automatic update service.

● Verify your identity.

● Record your login time and number of logins for fault locating, improving system stability and security.

● Improve user experience and service quality.

● Comply with applicable laws and regulations and respond to relevant legal proceedings.

● Protect the intellectual property rights, information assets, and other property and rights of this app.

2. How We Disclose Your Personal Information

We will not provide your personal information to third parties (companies other than START POINT INTERACTION Co., Ltd. and its affiliates) through selling, leasing, or trading, or by other means, without your consent, except in the following scenarios or as required by applicable laws. We may disclose your personal information within the scope of applicable laws for the following purposes:

● Comply with applicable laws or respond to effective legal processes of authorities (including law enforcement agencies and other government agencies).

● Protect the security and availability of START POINT INTERACTION communication systems. For example, prevent spam or fraud attempts, help avoid any personal injury or serious injury, and prevent or stop attacks launched against our computer systems or networks.

● Protect the intellectual property rights, information assets, and other property and rights of START POINT INTERACTION.

3. Your Rights over Personal Information Processing

Please ensure that all the personal information you submit is accurate. START POINT INTERACTION works to keep your personal information accurate, complete, and up-to-date.

To the extent required by applicable laws, you have the rights to (i) access and receive a copy of certain personal information we maintain about you, (ii) request that we update or correct inaccuracies in that information, (iii) object or restrict to our use of your personal information, (iv) ask us to delete your personal information, and (v) request interpretation for the rules of personal information processing. If you want to exercise these rights, please click here to give us your feedback online. For security reasons, you may need to provide a written request. We may decline the request if we have reasonable grounds to believe that the request is fraudulent or unfeasible or may jeopardize the privacy of others.

As stipulated by applicable laws, you are entitled to withdraw your consent at any time when we process your personal information based on your consent. However, the withdrawal neither affects the legitimacy and effectiveness of our processing of your personal information based on your consent before the withdrawal is made nor affects any data processing based on another justification other than your consent.

4. How We Protect Your Personal Information

The security of your personal information is important to us. We use appropriate physical, management, and technical measures to protect your personal information from unauthorized access, disclosure, use, modification, damage, or loss. For example, we use cryptographic technologies to ensure data confidentiality; we use trusted protection mechanisms to prevent malicious data attacks; we deploy access control mechanisms to ensure that personal information can only be accessed by authorized personnel; we offer security and privacy protection training courses to raise employees' awareness of personal information protection. While we take the utmost care to your personal information, please note that no security measures are infallible.

We will retain your personal information within the period necessary to achieve the purposes stated in this Statement, unless an extension of the retention period is required or permitted by laws. The data storage period may vary with scenario and service. The standards we use to determine the retention period are as follows: the time required to retain personal information to fulfill business purposes, including providing services; maintaining corresponding transaction and business records; controlling and improving the performance and quality of services; ensuring the security of systems and services; handling possible user queries or complaints and locating problems; whether the user agrees to a longer retention period; and whether the laws, contracts, and other equivalences have special requirements for data retention. We will maintain your registration information as long as your account is necessary for service provision. You can choose to deregister your account, at which point, we will stop providing you with services through your account and delete or anonymize your personal information, provided that it is not otherwise stipulated by special legal requirements.

5. How We Process Children's Personal Information

This app is for adult use only. Minors must obtain the consent from parents or legal guardians for using this app, as well as their agreement to the applicable terms and conditions. Parents or legal guardians should take appropriate precautions to protect minors, including monitoring their use of this app.

6. Updates to This Statement

We reserve the right to update or change this Statement at any time. The latest Statement will be released here. If major changes are made to the Statement, we may notify you through different channels, for example, posting a notice on our website or sending you direct notification.

You are encouraged to access this Statement anytime to learn about the latest changes. This Statement is available under Select Applications > Privacy Statement of the main screen. You can also choose Disable in the lower right corner of the Select Applications > Privacy Statement screen to withdraw your consent to this Statement. Please note that all the app services will be stopped after consent withdrawal.

7. Contact START POINT INTERACTION

If you have any complaints , suggestions or questions about the protection of personal information , or if you have any questions about this Privacy Statement , you may contact us in the following ways . We will review the issues as soon as possible and respond to you within 15 working days after verifying your identity : Email:[email protected]

This Statement takes effect as of the date of the update.

Last updated on: November 2, 2023