Reminders:

Your trust is of great importance to us. We deeply understand the importance of personal information to you, and will take corresponding security measures in accordance with laws and regulations and strive to protect your personal information to keep it secure and under control. NOW, THEREFORE, Qingdao KingAgroot Precision Agriculture Technology Co., Ltd. provides KingDraw Pro HD products and services (“we” or “us”) and formulates this Privacy Policy (the “Policy”) by reminding you that:

This Policy is applicable to KingDraw Pro HD products and services, including KingDraw Pro HD official website (domain name: www.KingDraw.com) and KingDraw Pro HD APP, as well as other third-party service and/or hardware that integrating of certain KingDraw Pro HD features/services. If our Affiliates (refer to the Definition hereunder) use products or services provided by KingDraw Pro HD for their own products or services but no separate privacy policy has been formulated, this Policy shall also apply to such products or services.

It should be especially noted that, this Policy shall not apply to services provided by other third parties to you via the foregoing web pages or KingDraw Pro HD APPs. For example, if you download applicable third-party APP via KingDraw Pro HD open platform or rely upon KingDraw Pro HD products for the provision of services to you, this Policy shall not apply to the information you provide to the third party.

Prior to the use of KingDraw Pro HD products or services, please carefully read and thoroughly understand this Policy and confirm that you have fully understood and agreed to this Policy before using relevant products or services. Your use of KingDraw Pro HD products or services shall be deemed as you have fully understood and agreed to this Policy. If you have any questions, comments or suggestions on the content of this Policy, you may contact us via [KingDraw Pro HD APP-Online Consultation] or [5*8 hours customer service hotline (+86-0532-67708489)].

Part 1 Definitions

KingDraw Pro HD: means a multi-terminal platform and client developed and operated by Qingdao KingAgroot Precision Agriculture Technology Co., Ltd. that is designed to develop and provide chemical structure drawing and editing services. It includes KingDraw Pro HD official website (www.KingDraw.com) and KingDraw Pro HD APP.

KingDraw Pro HD Service Provider: means Qingdao KingAgroot Precision Agriculture Technology Co., Ltd. that conducts research & develop and provides KingDraw Pro HD products and services, collectively named as “KingAgroot Precision Agriculture”.

Affiliate: means any economic entities between corporations controlled directly or indirectly by the controlling shareholders, actual controllers, directors, supervisors, senior executives of Qingdao Kingagroot Precision Agriculture Technology Co., Ltd.

Personal Information: means all information electronically or otherwise recorded that can be used to identify a natural person or reflect his/her activities, whether on its own or in combination with other information.

Sensitive Personal Information: includes without limitation mobile phone number and personal information of children under 14 years old (inclusive).

Personal Information Deletion: means the removal of personal information from the systems as involved in daily business operations so as to keep such information irretrievable and inaccessible.

Part 2 Legal Statement

I. Ownership of Rights

KingDraw Pro HD logo, “KingDraw Pro HD”, “清笔” and other texts, graphs and combinations thereof, other marks and symbols of KingDraw Pro HD and KingDraw Pro HD service names are the registered trademarks of KingAgroot Precision Agriculture and its affiliates in China and other countries. Without the written authorization of KingDraw Pro HD, no one may display, use or otherwise process (including without limitation reproduce, disseminate, show, mirror, upload and download) any of the said trademarks in any way or represent to others that he/she/it has the right to display, use or otherwise process any of the said trademarks.

The intellectual property rights in all of KingDraw Pro HD’s products, services, technologies and all applications or their components/features (“Technical Services”) shall vest in KingDraw Pro HD or their right owners.

Unless otherwise stated by KingDraw Pro HD, all rights (including but not limited to copyright, trademark right, patent right, trade secret and any other related rights) in, of and to all documents and other information (including but not limited to texts, graphs, pictures, photos, audios, videos, icons, colors, layout and electronic documents) published by KingDraw Pro HD on websites are vested in KingAgroot Precision Agriculture. Without the permission of KingAgroot Precision Agriculture, no one may use the said information (including but not limited to monitor, reproduce, rebroadcast, display, mirror, upload and download any contents in KingDraw Pro HD via programs or devices). Where any one is authorized to browse, reproduce, print or disseminate the information relating to KingDraw Pro HD products and services, such information shall not be used for commercial purposes and this statement of rights must be included in use of all information or any portion thereof.

II. Limitation of Liability
Where KingDraw Pro HD users upload, provide or publish relevant information on or in KingDraw Pro HD App, KingDraw Pro HD official website, forums, communities and open platforms, including but not limited to user name, company name, contact person and contact details, relevant pictures and information, such information shall be provided by KingDraw Pro HD users on their own and KingDraw Pro HD users must legally assume all liabilities for any information they provide.
KingDraw Pro HD hereby reminds you that you shall abide by laws of the People’s Republic of China and all other applicable domestic laws in the countries in using KingDraw Pro HD’s products and services, and you shall not endanger cyber security or utilize KingDraw Pro HD products and services to engage in activities that infringe upon others’ reputation right, privacy, intellectual property rights or other legitimate interests. Notwithstanding such reminders, KingDraw Pro HD will assume no liability for your purposes of using KingDraw Pro HD products and services.

Part 3 Privacy Policy

This part will help you understand the followings:

How we collect and use your Personal Information;

How we share, transfer and disclose your Personal Information;

How we protect your Personal Information;

How we protect and use your file information in the cloud;

How we update this Policy;

How to contact us.

I. How we collect and use your Personal Information

(I) How we collect your information

We collect and use your Personal Information for the purposes as stated below:

1. Help you become a KingDraw Pro HD user

To become a KingDraw Pro HD member, you are required to provide your cell-phone number, type of industry, company email and other basic information, and create a KingDraw Pro HD account and password, so that we are able to provide you with membership services, including cloud storage, etc.. You are not required to register to be our member or provide the above information if you only wish use the off-line drawing function of KingDraw Pro HD.

After becoming a KingDraw Pro HD user, you may modify your Personal Information, such as e-mail, type of industry, etc. The operation routine is like this: mobile phone-side toolbar-click the name or profile photo.

2. Provide you with products or services

1) Information provided by you to us

You may give your feedback of experience in using KingDraw Pro HD products and services to help us better understand your experience and demand and improve our products or services.

2) Information collected by us when you use services

In order to provide you with intelligent KingDraw Pro HD hardware and/or KingDraw Pro HD App, webpage presentations and search results that better meet your needs, understand product fitness and identify abnormalities of accounts, we will collect and connect the information relating to the product and/or services used by you and the way you use them, including:

Device information: On the basis of the specific authorizations granted by you in installation and use of the software, we will receive and record information relating to the device used by you (e.g., device model, operating system version, device settings, unique device identifier and other information of software and hardware features) and the location of such device (e.g., IP address, GPS/Beidou location information, and any Wi-Fi access point, Bluetooth, base station and other sensor information).

Log information: When you use products or services provided by our website or client, we will automatically collect detailed information relating to your use of our services and save them as network logs, such as problems affecting operations during use of the service and problems with unexpected software exit, etc.

Please note that the device information or log information alone is not sufficient to identify a certain natural person. If we combine such non-personal information with other information to identify certain natural person, or use the same in combination with Personal Information, then such non-personal information will be deemed as personal information during such combination, and we will anonymize and de-identify such personal information unless with your authorization or it is otherwise provided by laws and regulations.

When you contact us, we might keep the history and content of your communication/call or contact information given by you so as to contact you or help you solve problems, and might record solutions and results of relevant problems.

3. Provide safeguards for you

To prevent, identify and investigate in any fraud, infringement, dangerous act, illegal act or act in violation of our or our Affiliates’ agreements, policies or rules, we may collect or integrate your user information, service use information, device information, log information and information shared by our Affiliates or partners with your authorization or as required by laws.

4. Other purposes

When we collect your information for any other specific purpose not specified herein, we will obtain your consent in advance.

The purpose for KingAgroot Precision Agriculture to collect and use the aforesaid information is to better operate the KingDraw Pro HD products and services (including but not limited to provide customized service to you), and we will notify you of all new functions and new services with a notice on website, via email, by phone call or short message or otherwise, or send you business information that you may be interested in.

If we stop operating KingDraw Pro HD products or services, we will timely stop collecting your personal information, send you a notice thereof on a personal basis or in the form of announcement, and delete or anonymize the personal information held by us.

(II) How we use your information

We collect your information for the purpose of providing you with services and improving the service quality. Therefore, we will use your information for the following purposes:

Provide you with KingDraw Pro HD products or services you intend to use, and maintain, improve and optimize these services and experience with these services;

To prevent, identify and investigate in any fraud, infringement, dangerous act, illegal act or act in violation of our or our Affiliates’ agreements, policies or rules, and protect your, our, our Affiliates’, the others’ or the public’s lawful interests, we may use or integrate your user information, service use information, device information, log information and information shared by our Affiliates or partners with your authorization or as required by laws, in order to comprehensively assess the risks faced by your account and in your transaction, carry out authentication of your identity, monitor and prevent security event and take necessary recording, audit, analysis and handling measures according to laws;

We may process your information or combine your information with information from other services in order to provide more customized service to you;

Any other purpose as permitted by you.

II. How we share, transfer and disclose your Personal Information

(I) Share

We will not share your personal information with companies, organizations or individuals other than KingDraw Pro HD, except in the following circumstances:

Sharing as required by laws: We may share your personal information as required by laws, regulations, litigation, dispute resolution, or by administrative or judicial authority in accordance with laws;

When a complaint is made by others against you of infringing upon intellectual property rights or other lawful interests, we need to disclose your information as necessary to the complainer for settlement of complaint.

(II) Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

In case of any acquisition, merger or insolvency liquidation, or other circumstances involving merger, acquisition or insolvency liquidation, of KingDraw Pro HD service providers, if transfer of personal information is involved, we will require the new company, organization or individual in possession of your Personal Information to continue to be bound by this Policy, or we will require such company, organization and individual to obtain your authorization and consent again.

(III) Public disclosure

We will disclose your Personal Information to the public only under the following circumstances:

If we determine that you have violated laws and regulations, or have a material breach of the agreements with or regulations of KingDraw Pro HD, or we intend to protect KingDraw Pro HD’s and its Affiliates’ users or the general public from damages to their personal and property safety, we may disclose your Personal Information in accordance with laws and regulations, or the agreements with and regulations of KingDraw Pro HD after obtaining your consent, including the relevant violation and measures taken by KingDraw Pro HD against you.

(IV) Exceptions to obtaining prior authorization and consent for sharing, transferring and disclosing personal information

Unless otherwise stated in a country specific addendum, your Personal Information may be shared, transferred or disclosed to the public without your authorization and consent under the following circumstances:

1. National safety and national defense security are involved;

2. Public security, public health, or major public interests are involved;

3. Criminal investigation, prosecution, judgment and enforcement are involved;

4. For the purpose of protecting your or other individual’s life, property and other major lawful rights and interests, where it is hard to obtain your or such individual’s prior consent;

5. Infringement of patent rights of others;

6. The personal information is disclosed voluntarily by you to the public;

7. The personal information is collected from the information disclosed through lawful channels, such as lawful news reports or information disclosure by government.
Pursuant to laws, sharing and transfer of de-identified personal information which cannot be recovered by the recipient to re-identify the subjects of such personal information does not constitute sharing, transfer and disclosure of personal information to the public, and therefore it may be stored and processed without notice to you and without your consent.

III. How we protect your personal information

We will take various precautions to protect your personal information so as to safeguard your Personal Information from loss, misappropriation and misuse, and from being accessed, disclosed, modified or destroyed without permission. In order to ensure the safety of your personal information, we have established strict information security provisions and procedures, and have a professional information security team to implement the above precautions within the company.

We will take reasonable and practical measures to avoid collecting irrelevant Personal Information to the maximum extent. We will retain your Personal Information only for the period necessary to achieve the purposes set forth in this Policy, unless it is necessary to prolong the retention period or permitted by law.

Upon occurrence of any personal information security incident, we will, in accordance with the requirements of laws and regulations and within the period of 30 calendar days, notify you of the basic information and possible influence of such security incident, handling measures we have taken or will take, suggestions on how you may prevent and reduce risks on your own, and remedies to be taken for you. We will notify you of the relevant information of such incident through email, letter, phone, and push notification. If it is difficult to notify each personal information subject one by one, we will publish announcement in a reasonable and effective manner. In addition, we will also report the handling of personal information security incident according to the requirements of regulatory authorities.

Given the fact that Internet environment is not completely secure, although we have those security measures in place, please bear in mind that there is no “perfect security measure” on the Internet, and we will use our best efforts to ensure the security of your information.

IV. How we protect and use your file information stored in the cloud

(I) How we protect your file information in the cloud

We will take various precautions to protect your personal information so as to safeguard your personal information from loss, misappropriation and misuse, and from being accessed, disclosed, modified or destroyed without permission. In order to ensure the safety of your personal information, we have established strict information security provisions and procedures, and have a professional information security team to implement the above precautions within the company.

Given the fact that Internet environment is not completely secure, although we have those security measures in place, please bear in mind that there is no “perfect security measure” on the Internet, and we will use our best efforts to ensure the security of your information.

(II) How we use your file information in the cloud

The provider of KingDraw Pro HD service and its affiliates will not use your file information in the cloud without your explicit consent, but does not include:

1. National safety and national defense security are involved;

2. Public security, public health, or major public interests are involved;

3. Criminal investigation, prosecution, judgment and enforcement are involved;

4. For the purpose of protecting your or other individual’s life, property and other major lawful rights and interests, where it is hard to obtain your or such individual’s prior consent;

5. The personal information is disclosed voluntarily by you to the public;

V. Protection of minors

We attach great importance to the protection of information of minors. If you are a minor, we suggest that you ask your parents or guardian to read this Policy carefully, and to use our KingDraw Pro HD services with the consent of your parents or guardian or provide us your parent or guardian’s consent information. When you register and use the products and services provided by KingDraw Pro HD, we default that you have obtained the consent of your guardian. We will protect the personal information of minors in accordance with relevant national laws and regulations and this Policy.

VI. How we update this Policy

Our private policy maybe updated from time to time.

Without your explicit consent, we will not reduce and/or restrict the rights you are entitled to under this Policy. We will publish any change to this Policy on KingDraw Pro HD official website at www.KingDraw Pro HD.cn and, if changes are significant, prominent, we will also provide a more prominent notice (including using KingDraw Pro HD to collect opinions and make publicity, or by providing you notice with popup window within KingDraw Pro HD official website).

Significant changes to this Policy are included but not limited to the follows:

1. Our service pattern changes greatly, such as the purpose of dealing with KingDraw Pro HD user’s personal information, information processing method, etc.;

2. Our control and organization structure changed greatly, such as the business adjustment, bankruptcy, merger and acquisition, etc.;

3. Our KingDraw Pro HD user’s personal information sharing, transfer or public disclosure main target change;

4. Our internal department charging the security, its contact information, and complaints channels change;

5. Any KingDraw Pro HD user information security impact assessment indicates that there is a high risk.

Vll. Instructions for types of permissions

If you have any questions or concerns about this Policy and/or data processing of KingDraw Pro HD, you may contact us via [KingDraw Pro HD APP–Feedback] or [5*12 hours customer service hotline (+86-0532-67708489)], or we can be reached within following contact:

Qingdao KingAgroot Precision Agriculture Technology Co., Ltd.

Address: No.53, Qinglonghe Road, Huangdao District, Qingdao

Post code: 266000

E-mail: qyngapp@kingagroot.com

Generally, we will revert to you upon the receipt of your query within thirty (30) calendar days.