PRIVACY POLICY

VO2 Asia Pacific (hereafter “VO2 APAC”, “we”, “us” or “our”) is committed, to protecting the privacy of individuals who visit our website (“Visitors”) and individuals who register to contact VO2 APAC (hereafter “you” or “your”). This Privacy Policy describes the types of information we may collect form you or that you may provide when you visit our website at www.vo2asiapacific.cn or any subdomain thereof (our “Website”), as well as our practice for collection, use, share, maintain, protect, and disclose of that information.

Depending on where you are located, this Privacy Policy may also be subject to additional local data protection laws, such as the General Data Protection Regulation (“GDPR”) in the European Union, the Personal Information Protection Law (“PIPL”) in China, and the California Privacy Rights Act (“CPRA”) in California, USA.

The following details our Privacy Policy (the “Policy”) for the Website and describes the types of information we gather from those persons visiting the Website and how we use such information. We understand the importance of privacy and, accordingly, treat all information received in a responsible manner. This Policy applies to all the services offered by VO2 APAC, and affiliated entities (the “services”) on the Website.

Please contact us using the details below if you have any doubt, comment, or suggestions: pipl@vo2-group.com.

1. What Personal Information do we collect and how do we use it

VO2 APAC may collect your Personal Information (hereafter “PI”) of our Website. We use this information in an effort to communicate with you about information that you request. We may also use this information to help us target specific services or offers to you, and to contact you to verify your identity, reply to your inquiry, and provide you with advertising or marketing information.

1.1 Categories of Sources

We obtain the categories of PI directly from activity on our Website, Visitors would submit their PI through our website portal to obtain our resources and connect with us.

1.2 Collecting and Using Your Personal Information for Business Purposes

VO2 APAC collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of PI from consumers within the last twelve months:

As a Visitor agreeing to the Privacy Policy when filling in your PI on our Website, you explicitly consent to the access and collection of PI. You have the option to change these choices made at registration, at any time, or request deletion of this PI per this Privacy Policy and applicable data protection laws.

2. How we use your PI

VO2 APAC uses collected PI for its primary business purpose of providing marketing and sales activities, and all related purposes.

We may wish to send you notifications, messages or, special offers, news on VO2 APAC and on our services, events, webinars, etc. which may be of interest to you. If you have consented to such notifications, we will contact you only with information about our services, events, or webinars by notifications or messages. You can opt out at any time from such notifications, by following the corresponding instructions (clicking on the unsubscribe link in our emails). You can also contact us directly by email.

3. How we are sharing, transfer and publicly disclosure of your PI

3.1 Sharing

Your PI may be shared through different departments within VO2 APAC for business reasons. We will not share your PI with any company, organization or individual other than our Company, unless with your explicit consent.

3.2 Transfer

We will not transfer your PI to any company, organization, or individual except under the following circumstances:

a) Transfer with explicit and separate consent: after acquiring your explicit consent, we will transfer your PI to other parties.

b) When the transfer of PI is involved in a(n) merger, acquisition, or bankruptcy liquidation, we will require the new company or organization to which your PI is transferred to continue to be bound by this PI Protection Policy, otherwise we will require the new company or organization to seek your consent again.

3.3 Public Disclosure

We will only publicly disclose your PI under the following circumstances:

a) After we obtain your explicit and separate consent.

b) Statutory disclosure: we might publicly disclose your PI as stipulated by laws, regulations, or the mandatory requirements of government agencies.

4. How we protect your PI

We are committed to protecting your PI against theft, improper use, unauthorized access, or leakage. We will use our efforts with no less than a reasonable degree of care to protect the security of your PI.

We shall always maintain appropriate physical, electronic, managerial, and organizational measures to safeguard and secure your PI against accidental, unauthorized, or unlawful loss, unauthorized modification, disclosure, or access that is determined to be appropriate to the risk. All our employees and third-party partners and/or service providers who have access to, and are associated with the processing of PI, are required to respect the confidentiality, and ensure the security of the PI of all our users. We will delete your PI when we have no further legitimate use for it in line with our storage policy and as specified above.

In the event of leakage or any other incident related to PI security, we will take immediate action as to such incident to avoid the worsening of the incident and prevent it from further affecting more users and, where appropriate and in accordance with laws and regulations, we will notify you of the incident by sending you a notification or posting an announcement.

We are compliant with the requirements of applicable data protection laws and regulations.

We will take all possible technical measures to protect your PI but make no guarantee or warranty that our technical measures will eliminate all security risks.

5. How to exercise your rights

The PIPL provides consumers with specific rights regarding their PI.

5.1 Access your PI

You have the right to request that VO2 APAC disclose certain information to you about our collection and use of your PI. Once VO2 APAC receives and confirms your verifiable request, we will disclose to you:

• The categories of PI we collected about you.
• The categories of sources for the PI we collected about you.
• The categories of third parties (if any) with whom we share that PI.
• The specific pieces of PI we collected about you.

Your right of access to your PI in the possession of VO2 APAC is not an absolute right. Under certain circumstances, applicable laws and regulations may permit us or require us to refuse to provide you with all or a part of your PI. Moreover, your PI may have been destroyed or deleted in accordance with applicable laws or regulations or VO2 APAC’s archive policies. If VO2 APAC is unable to provide you with access to your PI due to the limitation of any laws, regulations, VO2 APAC will strive to inform you of the relevant reasons.

5.2 Rectify your PI

If any PI is incomplete or has been changed, you may require VO2 APAC to update or correct the relevant PI.

5.3 Delete your PI

You can submit a request to delete your PI to us under the following circumstances:

• If our processing of PI violates laws or regulations.
• If we collected and used your PI without your consent.
• If our processing of PI breaches our agreement with you.
• If you no longer use our products or services or you have canceled your account.
• If we no longer provide you with products or services.

When we decide to respond to your deletion request, we will also inform the entity that acquires your PI from us (if any) and ask it to delete your PI without delay, unless otherwise specified in laws and regulations, or the entity has acquired specific authorization from you.

When you delete the information from our services, we might not immediately delete the corresponding information from our backup system but will delete it when the backup system is updated.

5.4 Withdraw or change the scope of your consent

You may change the scope of your consent or withdraw your authorization by contacting us or as set out in this Privacy Policy.

Please understand that it may be necessary to enable some of the permissions and collect the necessary PI to enable the Website. When you withdraw your consent, we will not be able to continue to provide you with the services for which you have withdrawn your consent, but it will not affect the PI processing services previously carried out based on your authorization.

5.5 Non-Discrimination

VO2 APAC will not discriminate against you for exercising any of your data subject rights. Unless permitted by the laws or regulations, we will not:

• Deny your services.
• Charge you different prices or rates for services.
• Provide you with a different level or quality of services.
• Suggest that you may receive a different price or rate for services or a different level or quality of service.

5.6 Respond to your above-mentioned requests

VO2 APAC endeavors to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We will deliver our written response by email. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your PI that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication. We will not be able to respond to your request under the following circumstances:

• Related to our compliance with the obligations under the laws and regulations.
• Directly related to national security or defense security.
• Directly related to public security, public health, or major public interests.
• Directly related to criminal investigations, prosecutions, trials, and enforcement of court decisions, etc.
• We have sufficient proof that you have subjective malice or abuse of rights.
• For the purpose of safeguarding your life, property and other important legal rights and interests or those of other individuals but it is difficult to obtain consent.
• Responding to your request will cause serious harm to your legitimate rights and interests, or those of other individuals or organizations.
• Involving trade secrets.

VO2 APAC does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

6. How we process children’s PI

If you are under the age of 14, please do not use our Website and/or VO2 APAC services. We place great value on the protection of minors' PI. We do not knowingly collect PI from children. If we find that a child’s PI has been collected, we will delete relevant data as soon as possible.

7. How your PI is transmitted worldwide

PI collected via our Website will be stored in a location within the People’s Republic of China in accordance with applicable laws and regulations. Thus, we would not transfer your PI outside of Mainland China generally. If required, VO2 APAC will contact you rapidly and achieve a separate consent, we promise to provide appropriate safeguards for such transfers and the transfer will be conducted in accordance with applicable laws, including the Standard Contractual Clauses, where applicable.

8. Where do we store and how long do we keep your PI

PI collected via our Website will be stored in a location within the People’s Republic of China in accordance with applicable laws and regulations. If it is necessary to change the location where your PI is stored to another location outside the People's Republic of China, the transfer will be conducted in strict accordance with applicable laws.

We will only keep your PI as long as necessary to fulfill the corresponding purpose for which it was collected. When we no longer need your PI or when the legal retention period has expired, we will delete or anonymize your PI.

9. How this Policy will be updated

This Privacy Policy may be updated, revised, amended, or modified as appropriate from time to time. VO2 APAC reserves the right to amend or alter this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated version on our Website and update the effective date. If changes are made to any part not requiring your consent, the Privacy Policy is considered applicable upon publication.

10. How to contact us

If you have any questions about the way in which your Personal Information is being collected or used which are not answered by this Privacy Policy and/or any request or complaint, please contact us by writing to: pipl@vo2-group.com.

This Policy was last reviewed and updated in March 2024.