User Privacy Agreement

Version Effective Date:2022.01

The User Privacy Agreement applies to all products and services of Reading Pen (hereinafter referred to as "Reading Pen" or "Platform") under Fun to Read Investment Company Limited and other third-party products and services that you access through the platform's products and services.  Except for the other third products or services. Please read carefully and fully understand the content of each clause, especially the clauses of exemption or limitation of liability, and choose whether to accept it or not. Restrictions and disclaimers will be highlighted in bold.

When you confirm and agree to this policy, it means that you have fully read, understood and accepted all the content of this policy. You have reached an agreement with the Reading Pen. This policy is both legally binding on you and the Reading Pen.

一、 Service Content

The products and services provided by our company include, but are not limited to, the Reading Pen websites, mobile applications, clients, relevant WeChat open platform accounts or applets, and the Reading Pen Software Development Kit (SDK) and Application Programming Interface (API) for the third-party websites and applications, as well as the products and services provided without independent privacy policies by the company associated with Reading Pen.

App Installation and Use

You understand and agree: In order to provide you with effective services, the software will use the network resources of your mobile communication terminal which may incur data traffic charges. Users need to obtain relevant tariff information from the operator and bear the corresponding expenses.

You are permitted to install, use, display, run, and update the Reading Pen App on a single terminal device for non-commercial purposes. This license is non-transferable and non-exclusive. You can download it directly from the official website, or from a third party authorized by the company. If you obtain the APP or an installation program with the same name as it from a third party that is not authorized by the company, we cannot guarantee the normal use of the APP, and will not be responsible for the losses caused to you. 

The company has developed different App versions for different mobile terminal devices, and you should choose to download the appropriate version for installation according to the actual situation. The company does not assume any responsibility for the risks and losses caused by incorrectly installing the appropriate version.

You fully understand and agree that you will use the App in a legal way and will not use it to engage in acts that violates laws, regulations, policies, public order and good morals and social ethics. The company has the right to punish the acts in violation of relevant laws and regulations or the provisions of this Agreement based on reasonable judgments (including but not limited to disable and cancel account, delete comments, etc.) , and to take appropriate legal actions against any user who violates laws and regulations, and in accordance with the law Regarding the preservation of relevant information and reporting to relevant departments. The user shall solely bear all legal responsibilities arising from this.

二、 User Rights and Obligations

1. You understand and agree that in the process of enjoying the Reading Pen service, you need to prepare relevant devices by yourself and bear the following expenses:

1.1 Internet Devices: including but not limited to computers or other Internet terminals, modems and other necessary Internet devices

1.2 Internet Expenses: including but not limited to network access fee, Internet equipment rental cost and mobile phone traffic charge;

1.3 The user or you mentioned in this Agreement shall have the ability to enjoy civil acts and liabilities related to the Reading Pen service. If you are a minor (including children under the age of 14) or a person with limited capacity for civil conduct, or a person without civil capacity, please be sure to read this agreement with your guardian or legal representative, and they shall click to confirm and agree on behalf of you. When the platform collects the operation record of clicking to confirm and agreeing to this policy, it is deemed that the consent was made by your guardian or legal representative and you and your guardian or legal representative have fully read, understood and accepted all the contents. It is agreed that this policy is legally binding on you, your guardian or legal representative, and the Reading Pen.

1.4 You understand and guarantee that the information you provided during the use of this service is authentic, accurate and complete and effective. If the information changes, it should be updated in time. If the personal or property of you or a third party is damaged due to the aforementioned reasons, the reading pen will not be liable.

2. You understand and guarantee that you will not violate the relevant laws and regulations of the mainland of the People's Republic of China in the process of enjoying the relevant services of the Reading Pen, and will not use it to engage in illegal activities. You will bear all responsibilities for all the information and remarks you publish in the Reading Pen.

 

三、 Platform Responsibility

 

1.The Reading Pen collects, uses, stores and shares your personal information in strict accordance with this policy, the "Network Security Law of the People's Republic of China" and "Personal Information Security Regulations". If there is no explicit agreement on the relevant contents of personal information protection in this policy, the relevant laws and regulations of the "Network Security Law" and the "Personal Information Security Regulations" shall prevail. Except for the fault of the Reading Pen, you shall bear the risks arising from the use of the service. If you suffer personal injury or property damage due to your own fault or behavior, causing a third party's personal injury or property damage, or a third party causing your personal or property damage, you shall pursue legal liabilities from the responsible party in accordance with the law. The Reading Pen will not bear relevant responsibility.

 

2.The Reading Pen will make its commercially reasonable efforts to ensure the security of your data storage in the Reading Pen and services. However, the reading pen does not provide a complete guarantee that your personal information will not be infringed in any way. The Reading Pen is not responsible for the deletion or storage failure of relevant data in the Reading Pen and service. You can back up it and relevant data in the service according to your own needs.

3. If you violate this policy, the Reading Pen reserves the right to suspend or terminate the provision of services to you. At the same time, it has the right to refuse to provide services, close personal accounts, clear or edit content, cancel orders, and delete all kinds of non-conforming or untrue information without notifying users.

4. You understand and agree that the personal information protection measures provided in this policy are only applicable to the Reading Pen App and related services. Once you leave the reading pen and related services, browse or use other websites, services and content resources, we have no ability and obligation to protect any personal information submitted by you in software and websites other than the Reading Pen App and related services. Regardless of whether you log in, browse or use the above software or website, please refer to the link or guide of the Reading Pen as the standard.

5. You understand and agree that you may encounter force majeure and technical risk factors, which will cause the interruption of this service in the process of using this service. For contract performance obstacles, performance defects, delays in performance or changes in performance content, or data loss caused by the following reasons, the Reading Pen is exempt from liability to the maximum extent permitted by law:

5.1 Force majeure due to natural disasters, strikes, riots, wars, government actions and judicial administrative orders.

5.2 You or the computer software, system and hardware of the Reading Pen fail or you cannot use the Reading Pen for other reasons.

5.3  Due to power supply failures, communication network failures (including but not limited to the failure or delay of electronic communications, the interception or manipulation of electronic communications by computer programs used for electronic communications), public service factors or your own factors  (including but not limited to your improper operation and the use of this service through unauthorized way) or third-person factors (including but not limited to damage by computer viruses, Trojans or other malicious programs, hacker attacks, wrong orders by customers).

5.4   Under the condition that the Reading Pen has been managed in good faith, due to regular or emergency equipment and system maintenance, equipment and system failures, defects, network information and data security, and technical risk factors.

5.5 You know and understand that the Reading Pen will perform reasonable duty of care to the greatest extent and maintain the accuracy of the data. However, due to the objective reasons of Internet technology, the Reading Pen may have the phenomenon of lagging or errors in the information displayed on the web page. Will be repaired as soon as possible after discovery.

5.6 Other situations that cannot be controlled or reasonably foreseen by the Reading Pen.

6. In the following circumstances, the platform will not bear any responsibility except for intentional or negligent acts of the it

6.1 Any personal data disclosure caused by telling others your user password or sharing your registered account with others.

6.2 Any personal information leakage, loss, embezzlement or alteration caused by hacking, computer virus intrusion or attack, temporary shutdown caused by government control and force majeure affecting the normal operation of the network.

6.3 Personal data leakage caused by other third-party products or services related to the reading pen and any legal disputes and consequences caused thereby.

7. The Reading Pen shall only be liable for the direct and actual losses caused to the user due to it, and shall not be liable for any indirect losses and punitive damages.

 

四、 Personal Information Protection

This policy will help you understand the following

1. How the platform collects and uses your personal information

2. How the platform uses cookies and similar technologies

3. How the platform shares, transfers, and publicly discloses your personal information

4. How the platform protects your personal information

5. How the platform handles the personal information of minors

6. How to transfer your personal information globally

7. Your rights

8. How to update this policy

 

(1) How the platform collects and uses your personal information

1. Collection of information types and uses

The platform will collect and use your personal information for the following purposes described in this policy. Unless it is necessary to collect in order to realize basic business functions or in accordance with relevant laws and regulations. Refusing to provide the following information will only make you unable to use relevant specific functions, but will not affect your normal use of other functions of Reading Pen:

1.1 In order to provide you with the corresponding functions of the platform, the information that the platform needs to collect includes:

1.1.1 Account Information: In order to become a Reading Pen APP user and facilitate the platform to provide you with services, you need to provide basic registration or login information, including mobile phone number, email address, and create your account, user name and password.

1.1.2 Personal Data and Service Item Information: During the registration and login of some individual services, if you provide other additional information (region, nickname, date of birth, avatar), it will help the platform to provide you with a better service experience. Even though you do not provide, it will not affect your basic functions of using the App. 

1.1.3 Verification Information: Before using specific functions and services, you may need to provide other information (name, phone number and other identity), in accordance with the requirements of relevant laws and regulations or the needs of specific functions and services. In order to avoid ambiguity, if you only need to browse, search and view the official homepage of APP and the basic services and introduction of the official open platform of the APP, you do not need to register as a member of the platform and provide the above information.

1.2 We strengthen the security capabilities of the software installed on your device through continuous improvement of technical means to prevent your personal information from leaking. In order to ensure the safe and stable operation of the services provided to you, and to prevent viruses, Trojans and other malicious programs and websites, we will collect and correlate the information about your products, services and ways of use. This information includes:                                                                          

1.2.1 Device InformationThe platform will receive and record the device related information (device model, operating system version, device setting, the unique device identifier software and hardware feature information) you use according to the specific permissions you grant during software installation and use Information about the location of the equipment (IP address, GPS / BeiDou location information and WiFi access point, Bluetooth and base station sensor information that can provide relevant information).

1.2.2 Log InformationWhen you use the products or services provided by the platform's website or client, the platform will automatically collect your detailed usage of the platform's services and save them as relevant network logs. The content of your search query, IP address, browser type, telecom operator, language used, date and time of access, webpage records you visit, call status information.

Please note that separate equipment and log information cannot identify a specific natural person. If the platform combines this type of non-personal information with other information to identify a specific natural person, or combines it with personal information. Then during the combined use, this type of non-personal information will be treated as personal information. Unless otherwise authorized by you or stipulated by laws and regulations, the platform will anonymize such personal information.

1.2.3 Information related to your transaction and payment provided by a third partyIn order to provide you with better services, as well as to confirm the status of the transaction and provide you with after-sales and dispute resolution services. After your authorization, the platform will collect your transaction and payment-related information related to the progress of the transaction through the transaction object you selected and the third-party information system and payment institution directly involved in the transaction, so that the platform can process your order and ensure the smooth completion of the service, or better prevent fraud and malicious behavior.

1.2.4 Your identity and account information provided by a third partyIn accordance with the requirements of laws and regulations and the agreement with a third party, the platform will obtain your relevant information from the affiliated companies and partners of the Reading Pen after being authorized by you in the form of pop-up window. And it will use your information after confirming the legitimacy of its source. If you are authorized to log in with a third-party account, the platform will obtain your shared account information (such as avatar, nickname and phone) from the third party, and bind your third-party account with the App account when you use relevant functions after you agree to this privacy policy.

1.3 In order to provide you with the corresponding functions of the platform, the permissions required by the platform include the following:

1.3.1 Network PermissionIn order to provide you with user login function, registration function, display and download of Reading Pen resources, user information display and sending and receiving chat messages, the platform needs to obtain your network permissions. If it is not enabled, the platform will not be able to display information or provide services normally.

1.3.2 Bluetooth PermissionIn order to provide you with Bluetooth mode WiFi network configuration, the platform needs to obtain your Bluetooth permission. If it is not enabled, the platform will not be able to provide Bluetooth mode WiFi network configuration or services. 

1.3.3 Location PermissionWhen the Reading Pen is connected, in order to connect the WiFi, the platform needs to obtain your location permission. If you do not enable it, the platform will not be able to automatically obtain the WiFi name used by the current device.

1.3.4 Microphone PermissionIn order to provide you with the function of sending chat message, the platform needs to obtain your microphone permission. If it is not turned on, the user will not be able to use the chat function normally.

1.3.5 Storage PermissionIn order to provide you with a better user experience, the platform needs to obtain your file storage permissions to implement the App upgrade installation package, image cache, and voice file cache. If it is not turned on, the platform will not be able to provide corresponding services, but it will not affect your use of other functions of the platform.

1.4 Provide security

In order to prevent, discover and investigate fraud, infringement, endangering security, illegal or violation of agreements, policies or rules with the platform or its associated companies, the platform may collect or integrate your user information, service use information, equipment information, log information and information authorized by you or shared by the platform's associated companies and partners in accordance with the law.

1.5 Others

The purpose of collecting and using the above information by the App is to better operate the products and services of the Reading Pen. The platform will seek your consent in advance when collecting your information for other specific purposes not specified in this privacy policy. If the platform ceases to operate the Reading Pen products or services, it will promptly stop continuing to collect your personal information, and will notify you of the suspension of operations in the form of one - by - one delivery or announcement, and delete or anonymize the personal information held.

1.6 Exceptions with authorized consent

According to relevant laws and regulations and national standards, in the following situations, we may collect and use your personal information in accordance with the law without your consent:

(1) Directly related to national security and national defense security;

(2) Directly related to public safety, public health and major public interests;

(3) Directly related to criminal investigation, prosecution, trial and sentence execution;

(4) For the purpose of safeguarding your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain your own consent;

(5) The personal information collected is disclosed to the public by yourself;

(6) Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

(7) Necessary for signing and fulfilling the contract according to your requirements;

(8) Used to maintain the safe and stable operation of the products or services provided, and to detect or deal with the faults of the products or services;

(9) When conducting statistics or academic research based on news reports and public interests for news organizations or academic research institutions, and providing academic research or description results externally, the personal information contained in the results is de-identified. And the data receiver cannot recover and re identify the personal information;

(10) Other circumstances stipulated by laws and regulations.

2. Information Usage

The purpose of collecting your information is to provide you with services and improve the quality. In order to achieve it, your information will be used for the following purposes. For example, if the platform needs to use the collected information for a new purpose, scope or actual transmission method that is inconsistent with this agreement, it will notify you by phone, email, SMS, system information and obtain your express consent

2.1 Provide you with the Reading Pen products or services you used, and maintain, improve and optimize these services and experience

2.2 In order to prevent, detect, investigate fraud, infringement, endangering safety, illegality or violations of agreements, policies or rules with the platform or with the platform's affiliates, and to protect the legitimate rights and interests of you, other users , the public and  platform or affiliates, the platform may use or integrate your user information, service usage information, device information, log information, and the information that platform affiliates and partners have obtained your authorization or shared in accordance with the law. It is used to comprehensively determine your account and transaction risks, conduct identity verification, detection and prevention of  security events and to take necessary record, audit, analysis, and disposal measures in accordance with the law

3.Storage of Information

The platform will store the collected personal information in the following formsServer storage in mainland China. At the same time, your personal information will only be retained for the period required to achieve the purpose stated in the policy, unless there is a mandatory retention requirement by law. The "E-commerce Law of the People's Republic of China" requires that the storage period of commodity and service information and transaction information shall not be less than three years from the date of completion of the transaction; The "Implementation Opinions of the Six Departments of the Ministry of Education on Regulating Off-campus Online Training" stipulates that the user behavior logs involved in the platform services must be kept for more than 1 year. We will anonymize user behavior logs involved in the platform services. The criteria for the platform to judge the aforementioned period include:

3.1 Complete the transaction purpose related to you, maintain corresponding transaction and business records, and respond to your possible inquiries or complaints;

3.2 Ensure the safety and quality of the service provided by the platform;

3.3 If you agree to a longer retention period or not;

3.4 If there is any other special agreement on the retention period or not.

After your personal information exceeds the retention period, the platform will delete your personal information or make it anonymized in accordance with the requirements of applicable laws (If you are a minor, after your personal information exceeds the retention period, the platform will process your personal information accordingly in accordance with relevant laws and regulations). If it cannot be deleted in accordance with relevant requirements due to special circumstances, the platform will explain this part of the matter to you.

(二) How the platform uses cookies and similar technologies.

1. In order to make your access experience easier, when you use the Reading Pen product or service, the platform may collect and store the data files of your access to the Reading Pen service by adopting various technologies. When you visit or re-visit the service, the platform can identify you and provide you with better and more services through data analysis. Including using small data files to identify your identity. It is to understand your usage habits, help you avoid the steps of repeatedly entering account information, or help judge the security of your account. These data files may be cookies, Flash cookies, or other local storage provided by your browser or associated applications (collectively referred to as "cookies").

2. Please understand that certain services of the platform can only be achieved through the use of cookies. If your browser or additional services allow, you can modify the acceptance of cookies or reject the cookies of the Reading Pen. But you may not be able to use some functions of the Reading Pen service that rely on the cookies in some cases.

(三)How the platform shares, transfers, and publicly discloses your personal information

1. Share

The platform will not share your personal information with companies, organizations and individuals other than the Reading Pen service provider;

2. Transfer

The platform will not transfer your personal information to any company, organization or individual;

3. Public Disclosure

The platform will only publicly disclose your personal information under the following circumstances:

3.1With your explicit consent or based on your active choice, the platform may publicly disclose your personal information;

3.2 If the platform determines that you have violated laws and regulations or seriously violated the relevant agreement and rules of the Reading  Pen, or in order to protect the personal and property safety of the Reading Pen and its affiliated company users or the public from infringement, the platform may disclose your personal information with your consent in accordance with laws and regulations or the relevant agreement rules of the Reading Pen, Including relevant violations and measures that it has taken against you.

4. Exceptions to prior authorization and consent for sharing, transferring and publicly disclosing personal information;

In the following situations, sharing, transferring and publicly disclosing your personal information does not require your prior authorization and consent:

4.1 Related to personal information controllers fulfilling their obligations under laws and regulations;

4.2 Directly related to national security and national defense security;

4.3 Directly related to public safety, public health and major public interests;

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

4.5 For the purpose of safeguarding the life, property and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the person;

4.6 Personal information disclosed to the public by the subject of personal information;

4.7 Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

(三) How the platform protects your personal information

1. The platform will take various preventive measures to protect your personal information from loss, embezzlement and misuse, as well as unauthorized access, disclosure, alteration or destruction. In order to ensure the security of your personal information, the platform has strict information security regulations and processes, and a special information security team strictly implements the above measures within the company.

2. The Reading Pen has an advanced data security management system centered on the data life cycle, which improves the security of the whole system in multiple dimensions from organization construction, system design, personnel management and product technology.

3.The platform will take reasonable and feasible measures to try its best to avoid collecting irrelevant personal information and retain your personal information within the period limited to the purpose stated in the cost policy, unless the retention period needs to be extended or within the period allowed by law.

4. If a personal information security incident occurs, the platform will notify you in accordance with the requirements of laws and regulations and no later than 30 natural days: The basic situation and possible impact of the security incident, the disposal measures that the platform has taken or will take, the suggestions you can independently prevent and reduce risks and the remedial measures for you. he platform will inform you about the event by email, letter, telephone, and push notification. When it is difficult to inform the personal information subjects one by one, the platform will adopt a reasonable and effective way to publish an announcement. At the same time, the platform will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

5. Due to technical limitations and various malicious methods that may exist, even if we try our best to strengthen security measures, It is impossible to guarantee information security at all times in the internet industry. We will do our best to ensure the security of the personal information you provide to us. Please be aware and understand that the system and communication network you use to access our services may have problems due to factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of your personal information, including but not limited to using complex passwords, changing passwords regularly, and not disclosing your account password and personal information to others.

(五) How the platform handles the personal information of minors

1. The platform attaches importance to the information protection of minors. If you are a minor, it is recommended that you ask your parents or guardians to carefully read this Privacy Policy and use the services of the platform or provide information to the platform with the consent of your parents or guardians. For the collection of personal information of minors by using the products or services of the platform with the consent of parents or guardians. For the collection of personal information of minors by using the products or services of the platform with the consent of parents or guardians, the platform will use, share, transfer or disclose this information only when laws and regulations permit, parents or guardians explicitly agree or it is necessary to protect minors.

2. In particular, if you are a child under the age of 14, please inform your parents or guardians to read this policy carefully and seek the consent and guidance of them before you use platform services or submit personal information. After your parents or guardians agree to this policy, children under 14 can use the functions or services provided by the platform. In order to strengthen the protection of children’s personal information, in addition to other provisions under this policy, the platform will follow the principles of justification and necessity, informed consent, clear purpose, safety control and legal utilizationin accordance with relevant national laws and regulations and the provisions of this policy to protect children’s personal information. The specific content is as follows:

2.1 The platform separately stores the collected children’s information and the personal information of users other than children. The platform will adopt encryption measures not lower than the industry level to store children’s information to ensure the safety of children’s information.

2.2 The platform will designate a dedicated person to be responsible for the protection of children's information. Any staff who accesses to children's information must obtain written approval from the child's information protection personnel (including electronic information interaction methods such as e-mail, SMS, WeChat, etc.), and form a written record of the access; At the same time, technical measures not lower than the level of the same industry shall be taken  to avoid illegal copying and downloading of children’s information.

2.3 If the platform transfers children’s information to a third party, in addition to obtaining the consent of the child’s parents or guardians again and meeting the above principles, it will conduct a security assessment on its own or entrust a third-party organization and form a written assessment report.

2.4 If children's information is collected and used without the consent of their parents or guardians, the platform will delete the relevant information as soon as possible after receiving the notice from their parents or guardians.

(七)Your Rights

1.Access your informationYou can view your existing registration and other provided information through the personal center of the App.

    1After entering the App, click "Personal Center";

    2Click "My Information";

    3Information inquiry visit.

2.Correct your information: You can change your personal information (including name, avatar, address information) through the personal center of the App. If you have any questions, you can contact the platform through the online service or telephone service channel to help you.

    1After entering the App, click "Personal Center";

    2Click "My Information";

    3Information inquiry visit.

3.Delete your information: You can contact the platform through the customer service. After providing relevant information, the platform will help you delete user information. If the platform is out of service, it will promptly stop continuing to collect your personal information and notify you of the suspension of operations in the form of one-by-one delivery or announcement.

4. You withdraw your consent or authorization: Each business function of the platform requires some basic personal information to be completed (See Privacy Policy). Besides

4.1 You can withdraw part of the authorization by unbinding, modifying personal settings and deleting related information, or you can withdraw authorization by turning off the function.

4.2 After you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawal of consent or authorization, and will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the previous personal information processing based on your consent or authorization.

5. Log out of your user account: You can log out of your user account by clicking the Personal Center - More Infor of the App, or you can contact the platform by calling the After-Sales. After providing relevant information, the platform will help you cancel your account. Before you shut down your account, we will ask you to perform necessary identity verification, including personal identity, security status and device information. For the process and content of log off, please refer to the instructions. You know and understand that the cancellation of your account is irreversible. After you shut down your account, we will stop providing services to you and delete all information about your account or anonymize the relevant information. However, laws and regulations Unless otherwise specified.

    1After entering the App, click "Personal Center";

    2Click "More Information";

    3Click "log off Account";

    3Log off User Account.

6. Get a copy of your personal information: You can contact the platform through the online service or telephone service channel of the App to obtain a copy of your personal information.

7. Constraint Information System Automatic Decision: In some business functions, we may only make decisions based on non-manual automatic decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will also provide appropriate remedies.

8. Respond to your above request

To ensure safety, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request.

We will reply within fifteen working days. If you are not satisfied, you can also contact the platform through the online service or telephone service channel of the App to help you solve the problem.

For your reasonable requests, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost as appropriate. For requests that are unreasonably repeated, require too many technical means (need to develop new systems or fundamentally change current practice), bring risks to the legitimate rights and interests of others, or are very unrealistic (involving information stored on backup tapes), we may Reject.

We will not be able to respond to your request in the following cases:

1Related to the personal information controller's performance of obligations under laws and regulations;

2Directly related to national security and national defense security;

3Directly related to public safety, public health and major public interests;

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

5The personal information controller has sufficient evidence to show that the subject of personal information has subjective malice or abuse of rights;

6For the purpose of safeguarding the life, property and other major legitimate rights and interests of personal information subjects or other individuals, but it is difficult to obtain the consent of the person;

7Responding to the request of the personal information subject will cause serious damage to the legal rights and interests of the subject or other individuals or organizations;

8Involving trade secrets.

(八)How to update the Privacy Policy

The Reading Pen reserves the right to modify the terms of this policy if necessary, and notify you in the form of a notification from the message center. You can view the latest version of the revised policy on the platform at any time. If you do not agree with the revised policy, you have the right to terminate the authorization to the platform. After the policy updating, if you continue to use the corresponding platform functions, you will be deemed to have accepted the revised policy.

For major changes, the platform will also provide more significant notices (includes soliciting opinions, announcing notices and even providing pop-up prompts to you by phone and SMS).

The major changes referred to in this policy include but are not limited to:

1. The service mode of the platform has changed significantly. Such as the use and purpose of processing user information;

2. The platform has undergone major changes in terms of control and organizational structure. Such as business adjustment or change of owner caused by bankruptcy mergers and acquisitions;

3. The main objects of user information sharing, transfer or public disclosure have changed;

4. The responsible department, contact information and complaint channels of the platform responsible for handling user information security have changed;

5. The User information security impact assessment report shows that there is a high risk.

We will also archive the old version of this policy for your reference.

六、Intellectual Property

1. The Reading Pen and its affiliates are the obligee of intellectual property rights on this platform. All copyrights, trademark rights, patent rights, trade secrets and intellectual property rights of the platform, as well as all information content (including but not limited to words, pictures, audio, video, charts, interface design, layout framework, relevant data or electronic documents) are protected by the laws and regulations of the mainland of the People's Republic of China and corresponding international treaties. The Reading Pen or its affiliates enjoy the above intellectual property rights, except for the rights that relevant obligee should enjoy in accordance with the law.

2. Without the written consent of the platform, the above materials shall not be directly or indirectly published, broadcast, rewritten or redistributed for broadcast or publication purposes, or used for any other commercial purposes. All the above information or any part of it can only be kept for private and non-commercial use.

七、Others

1. The headings of all clauses in this policy are for reading convenience only, and are not used as the basis for the interpretation or restriction of the meaning of it.

2.Any clause of this policy is deemed to be repealed, invalid or unenforceable, and the clause shall be deemed to be divisible and does not affect the validity and enforceability of the remaining clauses of this policy.

3.This policy may have multiple language versions including Chinese and English. If there is a conflict between the Chinese version and the version in other languages, the Chinese version shall prevail.

4.For certain specific products and services, the platform will also formulate specific privacy policies and explain them before providing these specific products and services to you. If the relevant specific privacy policy is inconsistent with this privacy policy, the specific privacy policy shall apply.

八、Application of Law and Jurisdiction

1.The formulation, effectiveness, interpretation, amendment, supplement, termination, implementation and dispute resolution of this policy shall be governed by the laws of the Mainland of the People's Republic of China. If there are no relevant provisions in the law, refer to business practices and / or industry practices.

2.Disputes arising from your use of the point-reading pen service and related to the point-reading pen service shall be settled by the point-reading pen through negotiation with you. If the negotiation fails, either party can bring a lawsuit to the Peoples Court where the defendant is located.

九、Contact the platform

When you have personal information related questions or other complaints and suggestions, you can contact the platform in the following ways. It will review the contents involved as soon as possible and reply to your questions, complaints and suggestions within 15 working days:

Name of Platform OperationFun to Read Investment Company Limited

Registered Address: Room 806, 8th Floor, Great Lee Centre, 54 Hoi Yuen Road, Kwun Tong, Kowloon, Hong Kong

Contact AddressRoom 806, 8th Floor, Great Lee Centre, 54 Hoi Yuen Road, Kwun Tong, Kowloon, Hong Kong

Contact Number+852 31053588