Please read carefully this Privacy Policy as it affects your obligations and legal rights.This Privacy Policy is an independent legal document. Your rights and obligations when you use any of Our Applications are also defined (may be defined) by the following documents (agreements): Terms of Use; any other terms we let you know about. This Privacy Policy may contain links to any document listed above. The absence of one document or all of the listed documents doesn¡¯t affect the validity of this Privacy Policy.

SECTION 1 – GENERAL CONDITIONS

Our Privacy Policy governs the privacy terms of using Our Applications, general rules of User¡¯s Personal Data collection, processing, distribution, usage and keeping by ZHANGYONG (¡°Applications Owner¡± or ¡°Owner¡±, or ¡°Operator¡±, or ¡°we¡±/¡°us¡±/¡°our¡±).

We follow all the legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains what information of yours we will collect when you use the Applications, how the information will be used, and how we will share and protect the information.

EACH USER MUST CAREFULLY READ AND COMPLY WITH THIS POLICY.

By using Our Applications you confirm that you agree to these Terms of Our Privacy Policy. If you do not agree with this Privacy Policy in general or any part of it, you should withhold from using Our Applications. You also agree that any information about you collected by us is transferred with your consent.

You provide and guarantee to us the right to process your personal data, including the right to perform the following actions to process your personal data (fully or partially in an automated system): storing, registration, changing, restoring and removing. Also you agree that your personal data is included in the personal data base and any additional notification is not required.

SECTION 2 – INFORMATION WE COLLECT AND PROCESS

1. The User hereby expressly consents to provide Us, immediately upon Our notice of the request, the information (including Personal Data) that is required to maintain compliance with any law, regulation or policy.

2. Personally Identifiable Information that is provided directly by you or via the third parties. Technical (programmatic) means of Our Applications can collect such Personal Data: first name (maintained only if the user agreed to receive information on a new products release and special offers), email, messages to technical support, data entered to the Applications when working with them (it is stored on our servers only for synchronization between user¡¯s devices and it is not being used by us, in request for removing an account data are also removed with it). We may also obtain information about you from the third parties such as identity verification services. You (as a user) give your voluntary and undoubted consent for the collection and processing specified Personal Data and its transfer to the third parties in order to ensure the functioning of the Applications and their appropriate work.

3. You (as a user) hereby expressly consent, represent and warrant that any and all information provided to Us by you is valid, current, complete and accurate.

4. Information relating to your usage of the Applications. We may track, collect, process and compile the Information, when you use the Applications, and use information, provided to Us by you, sent to Us by your computer, mobile phone or other access device, which may include: your IP address, device information including device model, identifier, version and type of operating system, the application installation ID, title and version number of the application, date of the installation and date when the application was last launched, ¡°Pro¡± or ¡°Lite¡± version of the application is used, data about the user behavior in the application, mobile network information, region and locale data. You (as a user) give your voluntary and undoubted consent for the collection and processing specified information relating to your usage of the Applications and its transfer to the third parties in order to implement functioning of the Applications and their appropriate work.

5. We also collect and store such information as: User requests to support regarding the work of the Applications and their related services, and other issues as well as similar texts of the User requests.

6. YOU AGREE THAT YOUR PERSONAL DATA MAY BE PROCESSED AND STORED BY US OR OUR COUNTERPARTIES DURING THE PERIOD OF TIME THAT IS PRACTICALLY NECESSARY TO FULFILL THE AIMS AND PURPOSES THAT IMPACT WITH FUNCTIONAL PURPOSE OF THE APPLICATIONS.

SECTION 3 – HOW WE USE YOUR INFORMATION

We use the information we receive from you as follows:

1. We collect and process the User¡¯s Personal Data and Information relating to your usage of the Applications in order to ensure proper functioning of the Applications. In particular we use such Information in order to:

• administer Applications and or provide services;

• develop new products and services;

• personalize Applications for you;

• send you technical notices and support and administrative messages;

• communicate with you about products, services, promotions, events and other news and information which we think will be interested to you;

• information relating to your usage of the Applications is used to monitor and analyze trends, usage and activities in connection with the Applications and or services, including the maintenance of analytics concerning: usage of the Applications across regions, users ¡°retention¡±, number of the installation, behavior of users in the Applications;

• provide to the third parties with statistical information about Our Users (but those third parties will not be able to identify any individual User from that information);

• link or combine Personal Data We collect from or about You.

2. Such Your Personal Data as name, email and messages to technical support are processed (used) as follows:

• Name and email are used to dispatch information about a new products release and special offers (only if the user gave his consent at the data entering).

• We also use email of a user to create user's account, reset the password to account and authorize user in the account.

• Messages that came to technical support service are used directly to respond to them. After reply to the message that came to technical support service, we save it in order to solve the problems more quickly in case of repeated requests. For the reply to a user's request to technical support, we can use his email.

3. The Applications Owner is the data controller and processor, except for the cases when there is an objective Owner¡¯s need to process or store information at the Applications Owner¡¯s counterparties or agents.

SECTION 4 - PERSONAL DATA PROTECTION AND STORAGE; APPLICABLE LAW

1. The Applications Owner will do any and all efforts and actions prescribed by Applicable Law (Chinese law) to store any of Your Personal Data in secrecy by means of, including but not limited to use of secure data transfer protocols, physical access controls to Our data storages, information access authorization controls (which are designed to comply with Applicable Law and regulations), authorization of access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities.

2. We reserve the right to store, process and transfer Your Personal Data to our servers in various jurisdictions, where our facilities or our service providers are located. It may also be processed by staff operating who work for Us or for one of Our service providers. Staff may be engaged in the fulfillment of Our services and or the processing of Your details and the provision of support services. By submitting Your Personal Data, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Policy. Third parties may be located in other countries where the laws on the processing of Personal Data may be less stringent than in Your country.

SECTION 5 – THIRD PARTIES

1. We may share your personal information with:

• service providers under contract who help with parts of our business operations;

• companies that We plan to merge with or be acquired by (should such a combination occur, We will require that the newly combined entity follow these terms with respect to Your Personal Data);

• third-party identity verification services for fraud prevention purposes;

• law enforcement, government officials, or other third parties when We are compelled to do so by a subpoena, court order, or similar legal procedure; or We believe in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of Our policies;

• Our Personal Data processing counterparties or agents, hired by or cooperating with Us, whose services are required by Us from the practical point of view;

• other third parties only with Your prior consent or direction to do so.

2. We will not provide Your Personal Data to any other Users without Your consent or direction.

SECTION 6 - INTEGRATING THIRD PARTY SERVICES

Our Applications may contain links to third-party websites, applications or services. Our Applications also may have integration with third party websites, applications or services. If You follow one of these links or use integration with any of these websites, applications and or services, please note that they and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites, applications or services. Please check these policies before You submit any Personal Data to these websites or use these applications or services.

SECTION 7 – PROTECTING YOUR CHILD'S PRIVACY

1. We expect parents or guardians to guide minors in using our services. We will protect the confidentiality and security of personal information of minors in accordance with the relevant laws and regulations of the country.

2. If you are a minor, it is recommended that your parent or guardian read this policy and use our services or provide us with your information with the consent of your parent or guardian. For the collection of your information with the consent of the parent or guardian, we will only use or publicly disclose this information if it is necessary by law if the parent or guardian expressly agrees or protects your rights. If your guardian does not agree that you use our services or provide information to us in accordance with this policy, please terminate your use of our services immediately and notify us in time so that we can take appropriate action.

3. If you are a parent or guardian of a minor, please email us: zy@cngct.com when you have questions about the personal information processing of the minor you are monitoring.

SECTION 8 – RETAIN INFORMATION

In accordance with applicable laws and as needed to provide services to our Users, we may hold your Personal Data. This requirement is conditioned by the need of complying with legal obligations and resolving possible disputes. We may retain Your Personal Data for as long as Your account is active. Moreover, Your Personal Data may be hold beyond the abovementioned period till it is indispensable for Us to have relevant information to respond to any issues that may arise later.

SECTION 9 – SECURITY

1. We use relevant electronic and procedural safeguards to protect the privacy of the information you provide to Us from loss, misuse, disclosure, alteration and destruction.

2. All the data is transmitted under the protected protocol https.

SECTION 10 – PRIVACY POLICY UPDATES AND AMENDMENTS

We reserve the right to modify or amend this Privacy Policy at any time. You should review this Privacy Policy frequently. Your continued usage of Our Applications shall mean your acceptance of those amendments and updates.

SECTION 11 – CONTACT US

1. You have right to require correction of Your Personal Data, updating, complete removal or removal of incorrect and or inaccurate data by sending Us an email to zy@cngct.com . Nevertheless, this request must comply with the aim of using Our Applications and Our legal obligations.

2. If you have any questions or concerns regarding privacy, please send us a detailed message to zy@cngct.com . We will make every effort to resolve your concerns.