Zoomlion Heavy Machinery "Smart Service System" Privacy Policy

Introduction

Zoomlion Heavy Machinery Intelligent Aerial Work Platform Co., Ltd. (hereinafter referred to as "Zoomlion Heavy Machinery", "we", or "us") and its affiliates respect and protect the personal privacy rights of all customers and equipment operators using the Smart Service System services (hereinafter collectively referred to as "customers"). When you use the Smart Service System or other services provided by Zoomlion Heavy Machinery's platforms (hereinafter referred to as "services"), we will collect, use, share, and protect your personal privacy data in accordance with relevant laws and the terms of this privacy policy. Please read this privacy policy carefully to understand how we collect, store, process, use, transmit, and protect user information (including personal information) through the customer portal, how we provide information to you, and how we update, control, protect, and delete the above information. We are committed to protecting user privacy in accordance with relevant laws and this privacy policy. If you do not agree with any part of this privacy policy, you should immediately stop using the service platform software. By using any service provided by the service platform, you indicate that you have agreed to our lawful use and protection of your personal information in accordance with this privacy policy.

For users residing in relevant jurisdictions, we have also determined the legal basis for processing your data. For the purposes of this privacy policy, "relevant jurisdictions" include the United States, the European Economic Area, the United Kingdom, and other regions.

1. What Information Do We Collect About You?

To provide customers with high-quality services and a continuously optimized service experience, we may collect or receive your personal information.

Personal information refers to various information recorded electronically or otherwise that relates to an identified or identifiable natural person, excluding anonymized information. When you use our products, services, or interact with us, we may collect your personal information and device data.

If you voluntarily create a "Smart Service System" account, we will collect personal information necessary for our legitimate interests, such as providing services to you or otherwise cooperating with you, developing business (including the business of its affiliated entities), as follows:

1.1 Personal Information You Provide:

• 1.1.1 Registration and login data, including name, customer identity type (corporate customer/individual customer), address, email address or phone number, username, password, and other details (based on other agreements reached between the user and Zoomlion Heavy Machinery). This information helps us protect and provide you with access to the "Smart Service System" application.
• 1.1.2 Geolocation information, including your geolocation information collected when you use Zoomlion Heavy Machinery's construction machinery products, communication terminals (such as smartphones, tablets), or other inertial sensing units.
• 1.1.3 Support-related information, including the nature of your concerns and details about your account or transactions and services, including your purchase history of Zoomlion Heavy Machinery's products, product failure records, after-sales dispatch application records, and complaint information.

1.2 Device Data You Provide:

• 1.2.1 Mechanical product information, including product profile information (such as product name, product serial number, etc.) and equipment statistical information formed during product operation (such as equipment startup time, real-time equipment conditions, fuel consumption, equipment location, equipment operation trajectory, maintenance records, equipment abnormalities, operational abnormalities, etc.).
• 1.2.2 Mobile network information, such as Public Land Mobile Network (PLMN) provider ID, geolocation (cell ID of the area where the device is located), and Internet Protocol (IP) address.
• 1.2.3 Location information: When you access certain location-based services, we will collect, use, and process the approximate or precise location of your device. Such information may be obtained through GPS, WLAN, or service provider network ID. You can refuse to share your location by disabling the corresponding permissions in your device settings.
• 1.2.4 Application usage logs: Contains information about events that occur in the software application. These events are logged by the application and written to files, including errors and warnings as well as informational events.
• 1.2.5 Communication terminal information, including screen resolution, view resolution, device network used, device language, and device browser type.

2. How We Collect or Receive Your Information

2.1 Information You Actively Provide:

• 2.1.1 Basic information provided when creating and using the Smart Service System and other service platforms;
• 2.1.2 Documents or proof information, including those that can verify your personal identity, economic background, etc., as well as credit data provided during consultation and purchase of Zoomlion Heavy Machinery's products or services;
• 2.1.3 Transaction and service information provided when using or enjoying relevant services, such as your purchase history of Zoomlion Heavy Machinery's products, product failure records, after-sales dispatch application records, complaint information, and location information.

2.2 Information Collected About You During the Provision of Products or Services:

• 2.2.1 Information automatically collected by relevant websites or service platforms:

  To ensure platform and account security and improve service quality, during your use of products or services, we may collect log and operational data including but not limited to login behavior, operation records, search queries, software event information, IP addresses, accessed URLs, browser types, download and installation information, communication records, and access times. The collection of this information aims to optimize the service experience and ensure service stability and security.

• 2.2.2 Information collected by us through your device:

  When you use Zoomlion Heavy Machinery's products, if the device settings allow, we may also collect information about you and the equipment operator through the corresponding communication terminal.

• 2.2.3 Sometimes, we receive your data from other third parties.

  To realize the basic functions of the "Smart Service System" application, we may obtain your personal information from third parties (such as Microsoft, Google, APP STORE, Huawei Maps, Tencent Cloud, local operators, etc.) with your authorization. After your authorization, we will obtain your personal information from our affiliates and partners and confirm the legality of the information source before using your personal information. We will strictly comply with laws, regulations, and requirements of agreements with third parties to receive, process, and protect your personal information.

3. How We Use Your Information

We collect your information to provide efficient services and continuously optimize your experience, specifically for the following purposes:

• 3.1 Service Guarantee:

  We collect your information to provide efficient services and continuously optimize your experience, specifically for the following purposes:

• 3.2 Providing services and technical support;
• 3.3 Communication Notifications:

  Sending key information such as account updates, security alerts, product service information, and dispatch service contacts through the channels you provide, allowing us to interact and communicate with you.

• 3.4 Personalized Content:

  Understanding who you are and what you are seeking to correctly recommend content based on your preferences, promoting personalized recommendations. You can provide feedback to cancel if not interested.

• 3.5 Security and Compliance:

  Using information to prevent, identify, and investigate fraud, security threats, and other illegal activities to protect you, other users, and our rights.

• 3.6 Improving Service Content and Optimizing Service Quality:

  For example, statistical data generated when you access the portal, such as the time, frequency, product models involved, or when using specific services, to improve the products and/or services we provide to you.

4. Information Sharing, Transfer, and Disclosure

We will not share your information with any company, organization, or individual outside the portal platform, except in the following cases:

• 4.1 Business Transfer:

  We may share personal information with our affiliates, suppliers, distributors, and business partners, which may be used for the above purposes, and (i) we will only share necessary personal information; (ii) subject to the agreement between you and Zoomlion Heavy Machinery as well as this privacy policy; (iii) or for the legitimate interests of maintaining the portal platform, affiliates or partners, you, or other portal platform users, and (iv) for other legal reasons.

• 4.2 Legal Requirements:

  If we are required by law to do so, or if we sincerely believe that such use is reasonably necessary: (i) to comply with legal obligations, procedures, or requirements; (ii) to enforce our terms of service and other agreements, policies, and standards, including investigating any potential violations; (iii) to detect, prevent, or otherwise address security, fraud, or technical issues; or (iv) to protect our rights, property, or safety, the rights, property, or safety of our users, and third parties or the public as required or permitted by law (including exchanging information with other companies and organizations for fraud protection purposes).

• 4.3 Information Disclosure:

  In the event of a business transaction, such as when we or one of our business units or our related assets are acquired by, sold to, or merged with another company, or as part of bankruptcy proceedings or business restructuring, we may, when necessary, share the information you provide to us with certain third parties we engage, such as service providers who need to use your information to provide services to you on our behalf, including insurance companies, information technology service agencies, background investigation agencies, lawyers, translators, accountants, tax advisors, etc. We ensure that the third-party service providers we engage commit to taking appropriate security and confidentiality measures to protect your personal information.

5. How We Store Your Data

5.1 Storage Method and Location:

To fulfill our agreement with you, your personal information will be stored and processed on our cloud servers. We will take necessary measures and comply with applicable legal requirements, such as using standard contracts approved by the European Commission to regulate the transmission of your user information between us and our affiliates.

We are committed to maintaining the privacy and integrity of your user information, regardless of where it is stored. We have information security and access policies, and we deploy industry-standard firewalls and other security measures (such as access control, encryption) to prevent unauthorized access to our systems and/or your user information. However, please understand that transmitting information over the Internet is not entirely secure. Although we cannot guarantee the absolute security of information transmitted to the server, we will still make every effort to protect the security of your user information.

5.2 Storage Period:

We will store your user information from the time you start using the service until you request the cancellation of your account, for the period allowed by laws and regulations and based on the purposes described in this privacy policy. After your user information exceeds the storage period, we will delete your user information or anonymize it in accordance with legal and regulatory requirements. If you request us to destroy your user information before you request the cancellation of your account, we will destroy your user information in accordance with local laws. However, if user information needs to be continuously stored for other reasons (such as for the purpose of applicable laws and regulations), we will store and maintain the user information that needs to be continuously stored separately from other types of personal information, and we will not conduct other use or processing activities.

5.3 Additional Privacy Policy for Users in the United States, European Economic Area, and the United Kingdom:

We only process or transfer your personal information when we can rely on laws, regulations, and appropriate safeguards. We process your information for the following purposes:

• 5.3.1 Services: We process your personal information to perform services, support the use of our products, or any other functions you request or enable. For example, using your personal information to: (i) manage your account; (ii) support location-based functions; (iii) provide global customer service or technical support;
• 5.3.2 Consent: We process your personal information based on your consent. After you withdraw your consent, we will no longer process the corresponding personal information, but after you withdraw your consent, we will not be able to continue to provide you with the services or functions corresponding to the part of the consent that has been withdrawn. Your decision to withdraw consent will not affect the processing of personal information that was carried out based on your authorization before the withdrawal;
• 5.3.3 Legitimate Interests and Legal Obligations: We process your personal information when we have legitimate interests. For example, (i) debugging and improving our current and future services; (ii) allowing third-party partners and licensees to create applications and websites that benefit our users; (iii) establishing, exercising, or defending legal claims, complying with our legal obligations, or when required by a court in its judicial capacity.

6. Marketing

We are committed to providing you with information related to products and services that may be of interest to you. To this end, we and our partner companies will regularly send marketing communications and promotional information. If you choose to subscribe to our marketing communications, we may send you personalized promotional content in the application based on your preferences and interests.

When you register for our services, if you choose to accept marketing information, we will consider this as your authorization for us to send you marketing communications. You can withdraw this consent at any time. If you decide not to receive marketing information anymore, you can follow other unsubscribe instructions provided in the application.

7. Your Rights

In accordance with relevant laws, regulations, standards, and common practices in other countries and regions, we guarantee you the following rights regarding your personal information:

7.1 Accessing Your Personal Information:

You have the right to request a copy of your personal data from our company. This means that as a data subject, you can submit a request to our company to obtain detailed information about all personal data we hold about you. Our company will provide you with this information within the time specified by law after receiving your request to ensure your right to know and data transparency. In addition, we may charge a reasonable fee within the scope permitted by law to cover the costs incurred in processing the request.

7.2 Modifying or Deleting Your Personal Information:

You can delete your account, modify, or delete certain personal information by logging into your "Smart Service System" account and contacting us through the application or by sending us an email directly. After the account is deleted, for the purpose of preventing spam and system security, we will retain aggregated registration data or anonymize it.

You can request us to delete the personal information we hold about you in the following cases:

• 7.2.1 You believe that we no longer need to retain your personal information;
• 7.2.2 We process your personal information based on your consent, but you withdraw that consent (and we do not have another valid legal basis for processing your personal information);
• 7.2.3 You believe that we are illegally processing your personal information;
• 7.2.4 You can exercise your right to restrict our processing of your personal information (as described below), and we will consider your request to delete your data within a reasonable time frame.

If there is a legitimate legal basis, we may retain personal information (for example, to defend legal claims, freedom of expression, or other legal obligations), but if so, we will notify you.

If you request us to delete your publicly disclosed personal information and there is a valid legal basis for deletion, we will take reasonable steps to notify any third party to whom we have disclosed the relevant personal information so that they can also delete it.

7.3 Changing Your Authorization and Consent Scope:

Each business function requires some basic personal information to be completed. For the collection and use of additional personal information, you can give or withdraw your authorization consent at any time.

You can give or withdraw your authorization by contacting the customer service of the overseas customer portal application or changing the settings of your smart mobile device.

After you withdraw your consent, we will no longer process the corresponding personal information. However, after you withdraw your consent, we will not be able to continue to provide you with the services or functions corresponding to the part of the consent that has been withdrawn. Your decision to withdraw consent will not affect the processing of personal information that was carried out based on your authorization before the withdrawal.

7.4 Copying or Porting Your Data:

You have the right to receive a copy of some of your information in a structured, commonly used, and machine-readable format. This includes any personal information and user information we process based on your consent (for example, information provided in product or service surveys) or in accordance with our contract with you, as described in the "How We Use Your Information" section. You can exercise your right to export data by contacting us via the email address provided below.

You also have the right to request us to transfer this information to another party. If you wish us to transfer the information to a third party, please ensure that you provide the details of that party. Please note that we can only carry out such transfers when technically feasible. We are not responsible for the security of the information received by third parties or its processing.

If you make a request, we will respond to you within one month. If you wish to exercise any of these rights, please contact us in the following ways:

8. Cookies and Similar Technologies

To ensure the normal operation of the website and provide you with a more convenient access experience, we may place Cookies, Flash Cookies, or other local storage technologies (including identifiers, site names, and some numbers and characters, collectively referred to as "Cookies") on your computer or mobile device.

9. How We Use Cookies

Cookies help us quickly retrieve your personal information when you revisit the "Smart Service System", simplify the login process, or set preferences based on your previous operations, or optimize your selection and interaction with advertisements, and ensure the security of your data. We promise not to use these technologies for purposes other than those described in this privacy policy.

You can adjust the acceptance level of Cookies or refuse our Cookies according to your personal preferences through your browser or browser add-ons. For more detailed information, please refer to AboutCookies.org. However, please note that changing settings may affect your ability to securely access our website and may require you to reconfigure the user settings each time you visit our website.

We value your privacy protection and ensure compliance with applicable laws and regulations. If you have any questions about the use of Cookies or need further assistance, please feel free to contact us.

10. Types of Cookies

The types of Cookies we use include the following:

• 10.1 Necessary Cookies:

  These Cookies are essential for the operation of the website, helping you browse the website and use its basic functions;

• 10.2 Performance Cookies:

  These Cookies collect information about how visitors use our website, such as the pages visited and errors encountered. This data helps us improve the performance of the website;

• 10.3 Functional Cookies:

  These Cookies enable us to remember your choices (such as language or region), thereby providing you with a more personalized experience;

• 10.4 Targeting or Advertising Cookies:

  These Cookies are used to show you advertisements that are more relevant to you and help us evaluate the effectiveness of advertising campaigns.

Each type of Cookie has specific functions aimed at improving your user experience.

11. How to Manage Your Cookies

If you wish to see targeted service platform promotional content based on user interests in the portal, please click to accept/enable. If you do not wish to see targeted service platform promotional content based on user interests, please click to disable/turn off.

12. Updates to the Privacy Notice

We reserve the right to modify this privacy policy, so our privacy policy may change. We will not reduce your rights under this privacy policy without your explicit consent. We will post any changes to this policy on this page.

For significant changes, we will also provide more prominent notifications, such as sending notifications through the "Smart Service System" application announcements, explaining the specific changes to the privacy policy.

Your continued use of the "Smart Service System" application after the privacy policy changes are posted will indicate your acceptance of these changes.

13. Contact Information

If you have any questions, complaints, or suggestions regarding this privacy policy or matters related to your personal information, please contact us via email or postal mail, and we will respond to your questions, complaints, or suggestions within the time frame specified by laws and regulations.

If your identity needs to be verified, we may require you to provide identification documents to verify your identity, and we will respond to your request after verifying your identity. If we are unable to respond to your request, we will send you a notification within the maximum time limit required by law and explain the reasons.

15. Special Notice Based on the California Consumer Privacy Act

This special notice serves as a supplementary clause to this privacy policy and constitutes an integral part of the privacy policy, applicable to California residents (hereinafter referred to as "California residents" or "you") who access and use the Smart Service System. We adopt this notice to comply with the California Consumer Privacy Act (hereinafter referred to as "CCPA").

If you are a California resident, you have the following rights under the CCPA. To exercise these rights or if you have any concerns about how we use your information, please contact us at smartservicesystem@zoomlion.com.

15.1 Right to Access:

You can request to obtain information about the personal data we have collected from you in the past 12 months, as well as how we collect, use, and share your personal data. You have the right to request us to disclose the categories of personal data collected, the categories of sources from which personal data is collected, the purposes of collection, the categories of third parties with whom we share personal data, and the specific personal data we have about you. You can also request us to provide your personal data in an easy-to-use format;

15.2 Right to Delete or Correct:

You have the right to request us to correct or delete the personal data collected from you. However, please note that the request may be rejected, for example, if we are required by law to retain information necessary for detecting security incidents, exercising freedom of speech, protecting or defending legal proceedings, or for internal use that reasonably meets consumer expectations;

15.3 Right to Non-Discrimination:

You have the right not to be discriminated against by us for exercising these privacy rights. We will not provide you with financial incentives for providing data;

15.4 Designation of Authorized Agent:

California residents have the right to designate an authorized agent to make these requests on their behalf. We require any authorized agent to hold written proof of authorization;

15.5 Sale of Personal Information:

We do not sell your personal data. Please note that the CCPA requires us to verify the identity of the individual submitting a request to access, modify, or delete personal information before providing a response. Therefore, when you submit a request, we will ask you to verify your identity and may request specific information from you to help us confirm your identity. This is an appropriate security measure aimed at ensuring that personal data is not disclosed to unauthorized persons.