Last updated: July 27, 2026

Effective date: September 01, 2026

Welcome to the online platform services provided by Shenzhen SpinQ Technology Co., Ltd. (SpinQ official websites: www.spinq.cn, www.spinquanta.com, www.spinq.com; SpinQ Cloud Platform: https://cloud.spinq.com). The service provider (hereinafter referred to as “we”, “us” or “our”) understands the importance of personal information to you and will make every effort to keep your personal information secure and reliable. We are committed to maintaining your trust and processing your personal information in accordance with the principles of lawfulness, legitimacy, necessity and good faith. We have therefore formulated this Privacy Policy (hereinafter referred to as “this Policy”) so that you can fully understand how we collect, use, store, share and transfer such information when you use our services, and how we provide you with ways to access, update, delete and protect such information. Please read and understand this Privacy Policy carefully and completely before using SpinQ services, and agree to all terms of this Privacy Policy.

This service is not directed to individuals under the age of 18. We ask such individuals not to provide personal information through this service. If your child has submitted personal information and you wish to request deletion of such personal information, please contact us as described in “8. How to Contact Us” below.

This Policy will help you understand the following:

1. How we collect and use your personal information

2. How we use Cookie or similar technologies

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

4. How we store and protect your personal information

5. How you manage your personal information

6. How we process minors’ personal information

7. How this Privacy Policy is updated

8. How to contact us

1.1 Personal information refers to all kinds of information recorded electronically or otherwise that relates to an identified or identifiable natural person, excluding anonymized information. Sensitive personal information refers to personal information that, once leaked or illegally used, may easily lead to harm to the dignity of a natural person or endanger personal or property safety, including biometric identification, religious beliefs, specific identity, medical health, financial accounts, location tracking and other information, as well as personal information of minors under the age of 14.

1.2 Consultation and contact services

When you contact us for consultation, you need to provide your name, organization, telephone number, email address (optional), the products and services you are interested in (multiple selections allowed), and the information you wish to learn about or consult on, so that we can contact you and provide services.

1.3 SpinQ Cloud Platform registration and login services

When you register a SpinQ Cloud Platform account, you may register or log in by account, mobile phone number or WeChat QR code. You need to provide a mobile phone number or email address to register an account. We will verify whether your identity information is valid by sending an SMS verification code or email. When you log in to your account, we collect your mobile phone number and login password, or email address and login password, for account login. In addition to the above registration or login methods, you may also register or log in by scanning a WeChat QR code. If this is your first time registering through WeChat, in addition to collecting your WeChat openid, avatar and nickname, we also need to collect your mobile phone number or email address to complete identity authentication, and we will verify whether your identity information is valid by sending an SMS verification code or email. If you refuse to provide the above information, you may be unable to register or log in normally, or use the services normally. You may still browse and use the current page through “visitor login”.

1.4 SpinQ Cloud Platform usage services

When you use SpinQ Cloud Platform services, in order to protect your account security and system operation security, and in accordance with this Policy and legal and regulatory requirements, after you agree to this Privacy Policy when logging in to your account, we will collect your IP address to assess account risk and to prevent, detect and investigate acts that endanger system operation security or are illegal or violate our rules and agreements. Such information is basic information that must be collected to provide the services.

1.5 Exceptions to obtaining authorization and consent for collecting and using your personal information

You fully understand that, in accordance with relevant laws and regulations, we do not need to obtain your authorization and consent to collect or use personal information in the following circumstances:

1) Directly related to national security or national defense security;

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

3) Directly related to criminal investigation, prosecution, trial or enforcement of judgments;

4) Necessary to protect your or another individual’s life, property or other major lawful rights and interests where it is difficult to obtain consent;

5) The collected personal information has been disclosed to the public by you on your own;

6) The personal information is collected from legally and publicly disclosed information, such as lawful news reports or government information disclosure;

7) Necessary for concluding or performing a contract between you and us;

8) Necessary for maintaining the secure and stable operation of this product and related services, such as detecting and handling product or service faults;

9) Other circumstances provided by laws and regulations.

2.1. Cookie

To ensure the normal operation of the website, we may sometimes store small data files called Cookies on your computer or mobile device. A Cookie is a plain text file stored by a web server on a computer or mobile device. The content of a Cookie can only be retrieved or read by the server that created it. Each Cookie is unique to your web browser or mobile application. Cookies usually contain identifiers, site names and certain numbers and characters. Cookies are mainly used to help protect the security and efficient operation of products or services.

2.2 Specific purposes of Cookies

Authentication cookies are mainly used to protect the security and efficient operation of products and services, so that we can provide services and experiences suitable for you.

(1) Necessary Cookies

To ensure the normal operation of core services that you actively request, we use authentication and session Cookies (such as login credentials, CSRF security tokens and server-side routing identifiers). Such Cookies are used only to maintain your login status, prevent malicious requests and protect account security. They are strictly necessary technical measures for providing products and services and may be used without consent. If you completely disable such Cookies through your browser settings, you will be unable to log in normally or use functions that require identity authentication.

(2) Analytics and Performance Cookies

We and our cooperating statistical service providers (such as Baidu Analytics) may collect page visits, loading performance and aggregated interaction data through Cookies to identify faults and optimize product experience. When you click “Reject”, the relevant statistical scripts will not load and no analytics Cookies will be written.

We will not directly associate analytics data with your registered identity information. You may withdraw or modify your consent at any time through the Cookie preference center on this site.

2.3 If you wish to disable cookies, please click our pop-up banner when you first visit the website. Please note, however, that if you choose to reject Cookies, you may be unable to use the full functionality of the website. You may also configure your browser to “reject cookies” or “notify you when websites send cookies”. Because our services are implemented through support for cookies, after you disable cookies your access to the website may be affected or you may be unable to fully obtain our services. If you do not disable cookies, you may receive prompts, such as whether to retain Cookie information the next time you enter this website for convenience.

3.1 Entrusted processing

If we entrust a third party to process your personal information, we will agree with the entrusted party on the purpose, period, method of processing, types of personal information, protection measures, and the rights and obligations of both parties, and will supervise the entrusted party’s personal information processing activities.

3.2 Sharing

We share your personal information on the premise of complying with the principles of lawfulness, legitimacy, minimum necessity and clear purpose. We will also conduct a personal information protection impact assessment in advance for personal information sharing activities, and adopt effective technical protection measures for output form, flow and use. We will strictly require partners to fulfill information protection obligations.

3.3. We will not share your information with any third party outside our company except in the following circumstances:

1) We have obtained your explicit consent or authorization in advance.

2) We share your information externally in accordance with applicable laws and regulations, legal procedures, or mandatory administrative or judicial requirements.

3) Sharing your personal information is necessary to realize the core functions of our products and services or to provide the services you require.

4) To provide relevant products or services to you, display content that may interest you, and protect your account and transaction security, we may share your personal information with our affiliates. We will share your personal information with our affiliates in accordance with this Privacy Policy, but we will only share necessary personal information, which will be bound by the purposes stated in this Privacy Policy. If our affiliates change the processing purpose of personal information, they will again seek your authorization and consent.

5) We may share your information with partners and other third parties to ensure the smooth completion of services provided to you. However, we will only share your personal information for lawful, legitimate, necessary, specific and explicit purposes, and only the personal information necessary to provide services. Our partners have no right to use shared personal information for any other purpose.

6) The sharing is provided for in a separate service agreement or other legal document signed with you.

3.4 Transfer

Transfer refers to the transfer of control over personal information to another company, organization or individual.

We will not transfer your personal information to any third party outside our company except in the following circumstances:

We have obtained your explicit consent or authorization in advance.

As our business continues to develop, if we undergo a merger, acquisition or bankruptcy liquidation, your information may be transferred as part of such transaction. If personal information transfer is involved, we will provide a prominent notice on the homepage or notify you by other means of the recipient’s name and contact information, and require the recipient to continue fulfilling the obligations of a personal information processor. If the recipient changes the original processing purpose or processing method, we will require the recipient to seek your authorization and consent again.

3.5 Public disclosure

We will not publicly disclose your personal information to any third party outside our company except in the following circumstances:

We may publicly disclose your personal information in accordance with laws and regulations, litigation or dispute resolution needs, or as required by administrative or judicial authorities in accordance with law.

2) We disclose the information specified by you in a disclosure method to which you have explicitly consented according to your needs.

3.6 Exceptions to prior authorization and consent when sharing, transferring or publicly disclosing information

Please understand that, in accordance with laws, regulations and relevant national standards, we do not need to obtain your authorization and consent to share, transfer or publicly disclose your user information in the following circumstances:

1) Directly related to national security or national defense security;

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

3) Directly related to criminal investigation, prosecution, trial or enforcement of judgments;

4) Necessary to protect your or another individual’s life, property or other major lawful rights and interests where it is difficult to obtain consent;

5) Information that you have disclosed to the public on your own;

6) Information collected from legally and publicly disclosed information, such as lawful news reports or government information disclosure.

4.1 Storage location

In accordance with applicable data protection laws, we store your personal information collected within China in the territory of the People’s Republic of China. At present, we will not use, store, share or disclose your personal information in cross-border business, nor transmit your personal information overseas.

4.2 Storage period

We will retain your personal information only for the period necessary to provide product-related services and technical support to you, comply with applicable legal obligations, resolve disputes and enforce agreements.

After the above personal information retention period expires, we will delete or anonymize your personal information.

4.3 How we protect your personal information

We have used industry-standard security safeguards to protect the personal information you provide and prevent unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and feasible measures to protect your personal information. For example, we use specific and visible technical measures to protect your data security: your password and other core privacy fields are stored through irreversible encryption using the SHA-256 salted hash algorithm to prevent plaintext leakage risks; communications involving accounts, identity and sensitive operations are transmitted through HTTPS/TLS encrypted channels to prevent interception or tampering during transmission. At the same time, login credentials are written into Cookies with HttpOnly and Secure attributes to prevent script theft, and the backend opens the minimum necessary data access permissions only to authorized personnel and retains complete operation records. Please also keep your account and login devices safe and jointly maintain information security.

The Internet is not an absolutely secure environment. If a personal information security incident unfortunately occurs, we will inform you in a timely manner as required by laws and regulations of the basic situation and possible impact of the security incident, the handling measures we have taken or will take, suggestions for you to independently prevent and reduce risks, remedial measures for you, and contact information of the personal information protection officer and personal information protection working organization.

We will promptly inform you of the incident by email, letter, telephone, push notification or other means. Where it is difficult to notify personal information subjects one by one, we will publish an announcement in a reasonable and effective manner. At the same time, we will proactively report the handling of personal information security incidents as required by regulatory authorities.

We manage and regulate the storage and use of personal information by establishing systems such as the Data Classification and Hierarchical Management System, Data Management Measures, and Personal Information Protection Management System.

We will hold security and privacy protection training courses from time to time to strengthen employees’ security awareness and understanding of personal information protection policies and related procedures.

5.1 We attach great importance to your management of personal information and make every effort to protect your rights to access, copy, correct, delete, withdraw consent and exercise other statutory rights over your personal information, so that you have sufficient ability to maintain your privacy and personal information security.

5.2. Accessing, copying and correcting your personal information

Except as otherwise provided by laws and regulations, you have the right to access, copy and correct your personal information at any time.

If you need to access, copy or correct other personal information generated during your use of our products and services, please contact us at any time. We will respond to your request in accordance with the methods and time limits set out in this Privacy Policy.

5.3. Deleting your personal information. In the following circumstances, you may request deletion of personal information through the methods stated in this Policy and may at any time request cancellation of your previously registered account:

1) If our processing of personal information violates laws and regulations.

2) If you no longer use our products and services.

3) If we stop providing products and services, or the retention period has expired.

4) If you withdraw the relevant authorization and consent.

5) If the purpose of our processing of personal information has been achieved, cannot be achieved, or the information is no longer necessary for achieving the processing purpose.

5.4. After you delete information, the content, information, data and records you provided will be deleted or anonymized (unless otherwise provided by laws and regulations or required by regulatory authorities). Once information is destroyed, it cannot be restored.

5.5. Responding to your above requests

You may contact us using the contact methods stated in this Policy. To protect the security of your personal information, when you make the above requests, we may first require you to verify your identity before processing your request.

For your reasonable requests, we generally do not charge fees. However, for repeated requests or requests beyond reasonable limits, we may charge certain costs as appropriate. We may refuse requests that are repeatedly submitted without legitimate reasons, require substantial technical resources, harm the lawful rights and interests of others, or are obviously infeasible.

5.6 Exceptions to responses

We will be unable to respond to your request in the following circumstances:

1) Related to our performance of obligations stipulated by laws and regulations;

2) Directly related to national security or national defense security;

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

4) Directly related to criminal investigation, prosecution, trial or enforcement of judgments;

5) We have sufficient evidence that the personal information subject has subjective malice or abuses rights;

6) Necessary to protect the life, property or other major lawful rights and interests of the personal information subject or another individual where it is difficult to obtain consent;

7) Responding to the personal information subject’s request would seriously harm the lawful rights and interests of the personal information subject or other individuals or organizations;

8) The request involves trade secrets.

Our products, websites and services are only intended for adults. Minors under the age of 18 may not create accounts. If you are the guardian of a minor and have questions about the personal information of the minor under your guardianship, please contact us through the contact information disclosed in “8. Contact Us” of this Privacy Policy. We will protect the confidentiality and security of minors’ user information in accordance with relevant national laws and regulations and this Policy. If we discover that we have collected personal information of minors without prior verifiable consent from parents or legal guardians, we will try to delete the relevant data as soon as possible.

7.1 We will publish changes to this Privacy Policy on this page. For major changes, we will provide a prominent notice on the homepage or notify you by other means. If you do not agree with the updated version, please stop using the services we provide. If you continue to use our services, you are deemed to agree to be bound by the revised Privacy Policy.

7.2 “Major changes” refer to:

1) Major changes in our service model, such as the purpose of processing personal information, the type of personal information processed, or the way personal information is used;

2) Major changes in our ownership structure or organizational structure, such as owner changes caused by business adjustment, bankruptcy, merger or acquisition;

3) Changes in the main recipients of personal information sharing, transfer or public disclosure;

4) Major changes in your rights regarding personal information processing and the way you exercise them;

5) Changes in the responsible department, contact information or complaint channels for personal information security;

6) A personal information security impact assessment report indicates high risk. We will also archive old versions of this Policy for your reference.

If you have any questions, comments or suggestions about this Privacy Policy, or if you have any requests regarding personal information, you may contact us as follows:

Tel: 400 150 4472

Address: Entire 3rd Floor, Block A, Chuanglingtong Technology Building, Shihua Road, Fubao Community, Fubao Sub-district, Futian District, Shenzhen (Postal code: 518000)

Email: support@spinq.com

We have appointed a personal information protection officer. In general, we will respond within fifteen days.

If you are not satisfied with our response, especially if you believe that our personal information processing activities have harmed your lawful rights and interests, you may also seek a solution by filing a lawsuit with a court that has jurisdiction over the defendant’s domicile.