PRIVACY POLICY

PRIVACY POLICY

Issued: September 1, 2025

Welcome to use our products and services!

We (hereinafter also referred to as the "Company"), as the provider of the Software Product and Services, are aware of the importance of personal information and privacy to its users ( "you"), and have therefore formulated this Privacy Policy ("the Policy"). The aim of this Policy is to set forth the rules governing the collection, use, sharing, management and protection of your information when you use the Software Product and enjoy other Internet software products and services provided by the Company (hereinafter collectively referred to as the "Services"). We hereby specifically remind you that you are expected to read this document carefully, and thoroughly understand the relevant contents of the Policy (especially the text highlighted in bold and underlined) before you use the Services. You may only use the Services after confirming your full understanding and agreement to the Policy.

You are deemed to have agreed to this Policy when you install the Software Product. This Policy is an integral part of the Company's Service Agreement.

【Scope of Application】

• This Policy applies to：

This Policy applies to all products and services provided to you by the Company.

【Collection and Use of Information】

1. The Company shall collect and use such personal information that was provided by you voluntarily in the process of using the Services, or generated by using the Services in a proper, lawful and necessary manner, in order to provide you with better services, for the following purposes:

• [User Registration and Login]: You can register as a user of the Company using your mobile phone number and email address. When you register and log in to use the Service, the Company will store your user name, mobile phone number, email address, device attributes and other information, in order to verify whether your identity information is true. You may browse the product pages anonymously, but you are required to register as a user when you purchase the Company's Services.

• [Email Verification]: To comply with relevant laws, regulations ,and regulatory requirements, as well as to confirm your genuine purchase intention and safeguard the security of your and other users’ accounts, we will, when necessary, communicate with you via your email regarding the services you have purchased and other certification information .

• [Purchase Information]：In order to complete such basic functions as processing your payment and refund requests, and when keeping you informed of purchase order status, we will collect your identity and contact information; this includes your name, and phone number, as well as financial information or payment account information. We will also collect location data at an IP address-based level to tailor your experience in terms of displaying the appropriate local website, language, or user experience.

• [Issuance of Invoices]: When you apply to the Company to have an invoice issued, the Company will collect your name and other registration information for the purpose of verifying your payment voucher and invoicing information. You shall be responsible for ensuring the authenticity, accuracy and completeness of the invoice information submitted.

• [Transaction and After-sales Service]: In order to provide you with transaction and after-sales services, and in order to safeguard and optimize service functions and content, the Company will collect and use the order information (including but not limited to logistics information) of your store, the customer service and after-sales service information necessary for fulfilling the functions of the Software, as well as any product evaluations and other information pertaining to the operation of the store.

• In order to contact you more easily, help you solve any inquiries, complaints or suggestions in a timely manner, or to record solutions and results of related issues raised, the Company will retain communication and call records, as well as any relevant content pertaining to you and the Company (including account information, order information, other information provided by you to prove relevant facts, or the contact information provided by you).

You understand and agree that：if the information you provide contains the personal information of third parties, you shall ensure that you have obtained the required legal authorization before providing this information to the Company, and that you shall deal with any disputes arising from the use of such personal information independently.

2. In order to provide you with higher-quality, satisfactory and personalized services, and to improve your overall user experience, the Company may apply for certain permissions from you in the following scenarios, where your information may be collected and used. If you refuse to provide such information or grant the corresponding permissions, you will still be able to obtain the basic services provided by the Company, but you may not be able to obtain the higher-quality experience brought about by the additional information.

• [Camera Lens (Camera) and Photo Album (Picture Library) Information]: If you use your camera to take photos, or upload photos or pictures in your photo albums to ask for positive comments, or if you post comments through the Services, we will apply for permission to access your camera lens (camera) or photo album (picture library) and to store the picture information you have uploaded.

• [Microphone (Voice) Information]: In order to better use the Company's Services, when you use your microphone to communicate with the Company or other parties, the Company may apply for permission to access your microphone (voice) and collect your voice information to identify your requirements.

• [Calendar Information]: In order to help you keep track of your benefits, or to remind you to claim your benefits, the Company may apply for permission to access your calendar and store your calendar information.

• [Storage Permission Information]: In order to provide you with additional functions such as information distribution or local crash log information, the Company may apply for permission to read/write to your device storage, and will read or write pictures, files, crash log information and other necessary information on the storage space of your device.

3. Exceptions to Consent

• In the following circumstances, the Company shall not need to obtain your authorization or consent to collect or use your personal information:

1. In connection with the Company's performance of its obligations stipulated in relevant laws and regulations;

2. Directly related to national security and national defense security;

3. Directly related to criminal investigations, prosecution, trials or court judgments;

4. Directly related to criminal investigation, prosecution, trial and judgment execution;

5. For the purpose of protecting the life, property and other important legitimate rights and interests of the subjects of said personal information or of other individuals, but where it is difficult to obtain authorization or consent from the individual;

6. The personal information collected has been voluntarily disclosed by you to the public;

7. Necessary for signing and performing contracts at your request;

8. Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels;

9. Necessary for maintaining the safe and stable operation of the product or Services provided, such as discovering and disposing of obstacles to the product or service;

10. Providing such information as required by judicial or administrative authorities based on legal procedures;

11. The usage, sharing or transfer of the following processed personal information: Personal information that cannot be re-identified by the data receivers and cannot be recovered after the Company has taken technical and other necessary measures; or where the collected personal information being de-identified by the Company is used to improve the Company's service content and layout, to provide product or service support for business decisions, or to improve the Company's products and services;

12. If the Company obtains your information from a third party, the Company will request that third party in writing to state the source of said personal information, and whether the third party has obtained your authorization or consent for the storage, processing and provision of your personal information to the Company (if the purpose of the Company to collect and use your personal information exceeds the scope of authorization obtained by the third party, then the Company will request the third party to obtain your consent);

13. Other circumstances stipulated by relevant laws and regulations.

    【Use of Cookies】

• You understand and agree that, in order to make your user experience easier, when you visit the Company or use the Company's Services, the Company may use relevant technology to send one or more Cookies or anonymous identifiers to your device in order to collect and store information when you visit or use the Company's Services, and please see our Cookie Policy. The Company undertakes not to use Cookies for any purposes other than those stated in this Policy. The Company primarily uses Cookies and similar technology for the purpose of fulfilling the following functions or services:

• Ensuring the safe and efficient operation of products and services: The Company may set Cookies or anonymous identifiers that authenticate and ensure your security, so that the Company can verify that you have logged in safely to the Services, or identify whether you have been a victim of theft, fraud or other illegal activities. These technologies also help the Company improve the efficiency of the Services, as well as login and response times.

• Providing you with an easier access experience: Using such technologies can help you avoid repeatedly filling in personal information and entering search terms.

• Clearing Cookies: Most browsers provide the user with the option of clearing the browser cache data. You can clear the data in the settings function of your browser. If you do so, you may not be able to use the Services or corresponding functions provided by the Company that rely on Cookies.

  【Public Disclosure of Information】

The Company attaches great importance to the protection of your personal information. Without your consent, the Company will not disclose your personal information to any unrelated third party, nor will it make such information public, except for under the following circumstances:

• With your explicit consent or based on your own explicit choice;

• In the event that your personal information has to be provided in accordance with the requirements of laws, regulations, mandatory administrative enforcement, or judicial requirements, the Company may publicly disclose your personal information in accordance with the type of personal information required and the manner of disclosure;

• Other circumstances that may be disclosed in accordance with relevant laws and regulations or the agreements between the parties.

  【Information Sharing】

The Company shall not share your personal information with any individuals, companies or organizations other than the Company, except in the following circumstances:

• In accordance with this Policy or with your explicit prior consent or authorization;

• When necessary, in accordance with applicable laws, regulations, requirements of legal procedures, or mandatory administrative and judicial requirements;

• To the extent permitted by laws and regulations, in order to protect the Company, its affiliates or partners, you or other users of the Company, and the interests, property or safety of the public, from damage;

• In order to ensure the core functions of the Company's products and Services or provide you with said Services;

• When required to share information with third-party service providers, such as payment service providers, marketing and advertising service providers, fraud prevention and information security service providers, etc.;

• To deal with disputes or controversies between you and other parties at your request;

• In accordance with the relevant agreements or other legal documents signed by you;

• For the purpose of academic research;

• In cases where you have acted in breach of this Policy, and the Company is providing information to a third party for the purpose of rights protection;

• For the purpose of social public interest in accordance with relevant laws and regulations.

You fully understand and agree that if the Company needs to share your personal information with any affiliate of the Company in order to provide you with better Services, then the Company will obtain your authorization and consent. The Company does not and shall not permit any affiliate of the Company to use the information we share with you for any other purposes than those stated in this Policy, and we shall use reasonable technical measures (e.g., encrypted transmission) to protect your information when sharing it with an affiliate. If the Company shares sensitive personal information, or any affiliate of the Company changes the use or processing purpose of your personal information, your authorization and consent will be asked for again.

【Information Security】

• The Company employs industry-standard security measures to protect the personal information you have provided, and to prevent the data becoming subject to any unauthorized access, public disclosure, use, modification, damage or loss. The Company will take all reasonable and practical measures to protect your personal information.

• However, you fully understand and agree that, due to the limitations of technology and the possibility of various malicious attacks, in the Internet industry, even if we do our best to strengthen security measures, it is impossible to guarantee that the information is 100% safe all the time.

• After the occurrence of any unfortunate personal information security incident, the Company shall, in accordance with the requirements of relevant laws and regulations, inform you of the basic information and possible impact of said security incident, the disposal measures taken or to be taken, and any suggestions on risk prevention and reduction to be taken on your own initiative. We will inform you of the incident by E-mail, letter, telephone or push notice. If it is difficult to inform the affected parties one by one, we will use reasonable and effective ways to make a public announcement. In the meantime, the Company will also report the handling of personal information security incidents in accordance with the relevant requirements of the regulatory authorities.

  【Place and Period of Storage of Information】

• Your personal information will be stored on the servers belonging to the platform.

• All of your personal information will be stored in California, USA , with the following exceptions:

1. Where otherwise explicitly stipulated by relevant laws and regulations;

2. With your explicit authorization;

3. Resulting from your personal and voluntary conduct, such as cross-border transactions via the Internet.

• The Company acts solely as a processor of personal information, not as a controller. When you use this software product and its services, the Company process the relevant personal information based on your authorization. The Company will protect your personal information (and any data you have authorized us to process) in accordance with the obligations set forth in this Policy and all relevant laws and regulations. The Company will only retain such information for the purposes set forth in this Policy and during the term of the service , unless an extension of the retention period is necessary for your needs or is permitted or required by applicable laws and regulations. The Company will delete or anonymize your personal information within 30 days, in accordance with applicable laws, upon the occurrence of any of the following: (a) your withdrawal of authorization; (b) your request for deletion; (c) your closure of your account; or (d) our termination of services.

  【Rights Pertaining to Personal Information】

1. Changing the Scope of Your Authorization or Withdrawing Your Authorization

• You can check the status of each authorization on the client-side of the Company. When you open any authorization, you agree that you have authorized the Company to collect and use such information for its own purposes. Once you close any authorization, you will withdraw that authorization, and the Company will not continue to collect or use any related personal information, and accordingly, shall not achieve the purposes corresponding to the authorization. You may withdraw all authorization to collect your personal information by cancelling your account. However, your decision to close an authorization will not affect any earlier collection, processing and use of information that was based on your previous authorization.

• Please understand that each business function requires certain basic personal information to be completed. If you withdraw your consent or authorization, the Company will not be able to continue to provide you with the services for which the consent or authorization has been withdrawn, and will no longer process your personal information. However, your decision to withdraw your consent or authorization will not affect any previous collection, processing or use of information based on your earlier authorization.

2. Cancelling Account

• For instructions on how to cancel your account, and the procedures required, you may enter "Cancel" in the [Contact Us] tab on the client-side of the Company. After you successfully apply to cancel your account with the Company, the Company will complete a review within [7] business days of receiving your application. After the review, the Company will delete or anonymize your personal information in accordance with this Policy, unless otherwise stipulated by relevant laws and regulations.

3. Other Requests Regarding Personal Information

• Subject to the limitations set out in the Data Protection Laws of California, USA, you have certain rights in relation to your personal information. For example, you have the right to request access to your personal information, and to rectification and data portability. You may also have the right to review automated decision making. You can contact us via the method specified below if you want to exercise these rights, or if you wish to make a complaint regarding your personal information. The Company will complete a review within [7] business days of receiving your application. After this review has been completed, the Company will respond to your requests regarding personal information in accordance with this Policy, unless otherwise stipulated by relevant laws and regulations.

  【Protection of Minors】

• Use of our software product is intended for adults at least eighteen (18) years of age. We do not knowingly collect personally-identifying information from children under the age of eighteen (18).

  【Cross-border Data Transfer】

• Storage and Transfer of Your Personal Data. When you access or use our Services, your personal data will be stored and transferred in California, USA. This country may have data protection laws that are different in certain respects, or that provide less protection than the laws of the jurisdiction in which you reside. If you do not want to transfer your information to California, USA for processing or maintenance, you should immediately stop accessing or using the Services.

• In such cases, we will ensure the transfer is carried out in accordance with applicable laws and regulations (including by ensuring that overseas recipients are subject to confidentiality and data protection obligations where appropriate), as well as with this Privacy Policy. Appropriate safeguards and security measures reflective of good industry practice and technological development in the context of the relevant laws of Personal Data Protection of California, USA will be taken in order to protect your personal information.

  【Amendments to this Privacy Policy】

• You understand and agree that the Company has the right to amend, supplement or update this Policy from time to time, and to publish such amendments, supplements or updates related to the Services. If you choose to continue to use our Services, you are required to agree once more to the amended Policy. Please pay attention to any amendments to this Policy. If you do not agree to the amended version, you shall immediately stop using the Services provided by the Company.

【Limitation and Liability】

• EXCEPT AS STATED IN THIS AGREEMENT, THE SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE,” AND The Company EXPRESSLY DISCLAIMS ALL OTHER WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF PERFORMANCE, MERCHANTABILITY, AND FITNESS FOR A PARTICULAR PURPOSE. The Company DOES NOT WARRANT THAT THE SERVICES WILL BE UNINTERRUPTED, TIMELY, SECURE, ERROR-FREE, OR FREE FROM VIRUSES OR OTHER MALICIOUS SOFTWARE, OR WILL MEET CUSTOMER’S BUSINESS, LEGAL, OR REGULATORY REQUIREMENTS, AND NO INFORMATION OR ADVICE OBTAINED BY YOU FROM The Company OR THROUGH THE SERVICES WILL CREATE ANY WARRANTY NOT EXPRESSLY STATED IN THIS AGREEMENT.

• The Company shall have no liability with respect to the Terms, the The Company Software Product, the Services or otherwise for any direct, indirect, incidental, special, consequential, or exemplary damages, including damages for losses of profits, goodwill, use, data or other intangible losses resulting in any way from the Terms, the Services or the The Company Software Product, even if The Company has been advised of the possibility of such damages. In no event shall The Company’s total liability to you under the Terms exceed the total fees you actually paid to The Company in the 12 months preceding when the claim arose. This limitation applies to all causes of action in the aggregate, including breach of contract, breach of warranty, negligence, strict liability, misrepresentations, and other torts.

• The foregoing limitations shall apply to the fullest extent permitted by applicable law.

  【Contact Us】

• If you need to exercise your rights as described above, or if you have any questions, comments, suggestions or complaints about this Policy, or if you have other concerns for which the answers cannot be found here, you may choose one of the following methods to contact us:

• E-mail Address：contact@jolect.com

  【Miscellaneous】

• Notification of Operation Cessation

• If the Company terminates our Services or operations, the Company will notify you at least 30 days in advance, and delete or anonymize your personal information in accordance with this Policy after termination of the Services or operations.

• If any provision or any part of any provision of this Policy is deemed to be invalid, illegal or unenforceable under any applicable law, then the validity of any other provision of this Policy or any other part of such provision shall not be affected.

• This Policy is an enforceable supplement to the Service Agreement. If there is any inconsistency between the Service Agreement and this Policy on similar terms, this Privacy Policy shall prevail. Matters not covered herein shall be subject to the Service Agreement.