PRIVACY POLICY

Version Date: October [*25 October] 2022

Welcome to SIJOY CLM Application (the “SIJOY CLM App” or “this Application>”). This Application is owned by SiBio Technology Limited (the “SiBio”, “we” or “us”). We value your interests and fundamental rights and are committed to processing personal data in a professional, lawful and ethical way.

This Privacy Policy (the “Policy”) and any other documents we mentioned in this Policy describe how we collect, store, use, share, disclose and transfer (collectively, “process”) your personal data when you use our products and services related to SIJOY CLM App (collectively, the “Services”) and tells you about your privacy rights and how the law protects you.

Please read this Policy carefully as it will help you understand what we do with the personal data that we process. Please pay special attention to the important contents of this Policy, which have been highlighted in bold form. By using or continuing to use our Services after we have updated this Policy (and we will promptly notify you of such updates), you agree to the content of this Policy (including the updated version) and to our collection, use, storage and protection of personal data about you in accordance with this Policy.

If you have any other queries regarding this Policy or our use of your personal data, please refer to our contact information at the end of this Policy.

1.Policy Statement

● The purpose of this Policy is to inform you of the means that we collect and process your personal data and the rights you have. We collect and process your personal data in compliance with the Regulation (EU) 2016/679 (General Data Protection Regulation, the “GDPR”) and other applicable data protection laws and regulations in your corresponding jurisdiction.

● The SiBio affiliates which adhere to this Policy include but are not limited to the following: [Shenzhen Sibionics Co., Ltd]、[ShenZhen Sisensing Co.,Ltd]

● Terms like “personal data”, “controller”, “processor”, “processing”, “profiling” and other terms defined by the GDPR are used in this Policy in accordance with the definitions given by the GDPR and are sanctioned in accordance with the GDPR.

● SiBio generally acts as a controller with respect to your personal data and determines the purposes and means in which your personal data is processed as described below. At times, SiBio may act as a processor and will process personal data on behalf of the controller, as further detailed in this Policy.

● The service providers we use may have access to your personal data. These third-party vendors collect, store, use, process and transfer personal data about your activity on our Service in accordance with their own Privacy Policies. This Policy does not apply to how third parties define personal data or how they process it. We suggest you to read their privacy policies and know your privacy rights before interacting with them.

2.Collection of Your Personal Data

We collect your personal data that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our Services, participate in activities on the Services, or otherwise contact us.

The personal data that we collect depends on the context of your interactions with us, the choices you make and the Services you use. More personal data about the categories and sources of information is provided below.

■ Personal data provided by you

We may collect and store email address, password you provide when you register SIJOY CLM App or create a new account.

We may collect information you provide when you fill out information online on our pages, such as your date of birth, height, weight, ages, etc., when you resolve a dispute or contact us about the Services, and information about your activities generated in the course of your use of our Services.

When you apply for our Services, we need to collect your lactate data which is collected though our sensor.

■ Personal data we collected automatically

We automatically collect certain information from you when you use SIJOY CLM App. This information does not reveal your specific identity (like your name or contact information) but may include your device models, Mac address, Wifi address, device IDs, operating system, software version, device status, network conditions, logs, IP address, location, etc.(collectively “usage data”), This information is primarily needed to maintain the security and operation of our SIJOY CLM App, and for our internal analytics and reporting purposes.

■ Personal data we received from third parties

In order to provide you with our advanced Services, we may also obtain information about you from affiliated companies and, partners and third parties that are legally established and legally retain information about you, with your prior consent. This information includes your exercise data.

■ 3.Use of Your Personal Data

For the purposes of this Policy, as explained below, we use your personal data to improve, support and administer SIJOY CLM App to allow you to use its functionalities, and to perform and fulfill Terms of Use entered into between you and SiBio. We may also use your personal data to, among other things, provide you suggestions, promote our products and services. We hereby indicate the specific processing grounds we rely on next to each purpose listed below:

● To facilitate account creation and login process.When you create a new account or you need to login to SIJOY CLM App, in this process, in order to verify your account for the purpose of login, we will collect and store your email and password for account login. If you do not provide the above data, you will not be able to log in to the App properly.

● To manage your accounts.We may use your personal data for the purpose of managing our account and keeping it in working order.

● To provide lactate profile and monitoring.In order to show you your lactate profile and provide you lactate data monitoring, while you are using SIJOY CLM App, we may collect, with your prior permission:

● Bluetooth access

● Information regarding your device’s location

● Camera access

● Pictures and other information from your device's camera and photo library

You can disable these accesses to this at any time, through [phone System Settings]，but it will affect the normal use of SIJOY CLM App.

● To provide recommended pace and heart rate during exercise.In order to provide our advanced Services, we may use the exercise data you authorized to third parties and the lactate data you provided to us. If you do not authorize, we will not be able to provide the recommendation function, but it will not affect the normal use of other functions and services of SIJOY CLM App.

● To request feedback.We may use your personal data to request feedback and to contact you about your use of our Services with your prior permission.

● To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

● To respond to legal requests and prevent harm.If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

● To respond to your inquiries/offer support.If you request our support for products deployment or operations, we will process the personal data needed for such support, such as email address, country, company, and device IDs. We may also process voice data upon your consent when support is offered via call center or remote.

● To send you marketing and promotional communications.We may process your personal data, such as email address, and other data that was either provided by you, collected from your interactions with our Services, or received from third-party sources, for the purpose of sending you marketing communications through email. We only do so based on your consent, or based on our legitimate interest, where GDPR or other applicable laws in your corresponding jurisdiction allow it.

Marketing communications include sending information about the Services you use or have shown interest in, Services similar to those you already use, new product releases, service developments, alerts, updates, terms, events, special offers and associated campaigns and promotions or prices, and may be performed either via targeted marketing e-mails or through our sales representatives, in accordance with the applicable laws.

We will seek your explicit opt-in before sending your such marketing communications, and you may at any time choose not to receive marketing communications from us by clicking on the unsubscribe link included in the email. Please note that if you opt-out from marketing communications, we may still contact you regarding your use of our Services other than marketing purposes such as to respond to your questions or requests.

● For other business purposes.We may use your personal data for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our SIJOY CLM App, the Services, products, marketing and your experience. We may use and store this personal data in aggregated and anonymized form so that it is not associated with individual end users and does not include personal data. We will not use identifiable personal data without your consent.

■ 4.Legal Bases for Processing Your Personal Data

We only process your personal data when we believe it is necessary and we have a valid legal basis to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. We may rely on the following legal bases to process your personal data:

● Consent:We may process your data if you have given us specific consent to use your personal data for a specific purpose.

● Legitimate Interests:We may process your data when it is reasonably necessary to achieve our legitimate business interests to the extent permitted by applicable laws.

● Performance of a Contract:Where we have entered into a contract with you, we may process your personal data to fulfill the terms of our contract (such as the Terms of Use of SIJOY CLM App).

● Legal Obligations:We may process your personal data where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

● Vital Interests: We may process your personal data where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

● Other legal basis permitted by applicable laws.

■ 5.Share of Your Personal Data

We may share your personal data in the following situations:

● With group of companies:We share personal data with our affiliates as necessary to provide the Services or perform usual business activities. Personal data shared within our group of companies are granted a GDPR level of protection. Access to personal data within our group of companies is restricted to those individuals who need to access the data for our business purposes.

● With service providers:We may share your personal data with Service Providers to monitor and analyze the use of our Service, to contact you.

● With business partners:We may share your personal data with our business partners to offer you certain products, services or promotions.

● With government authorities:We may provide personal data to government authorities as requested by public authorities, auditors or institutions competent to exercise inspections on SiBio, based on their legal obligations, which may ask us to provide information. In addition, we may provide personal data to comply with a legal requirement or to protect the rights and assets of SiBio or other entities or people, such as courts of law, or enforcement authorities.

● With your consent: We may disclose your personal data for any other purpose with your consent.

■ 6.Disclosure of Your Personal Data

We shall not publicly disclose your personal data unless it is expressly provided by the applicable laws.

■ 7.Retention of Your Personal Data

We will retain your personal data only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, to perform the legal agreements entered into between you and SiBio. No purpose in this Policy will require us keeping your personal data for longer than [one months] past the termination of the user’s account.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize such personal data, or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

■ 8.Transfer and Global Processing of Your Personal Data

Your personal data which you provide to us is generally stored and kept within the territory of the European Economic Area (the “EEA”).However, due to the fact that we are based in Hong Kong and our operating teams are located in Hong Kong and Mainland China, in order to provide our Services to you, your personal data may be transferred to third country outside of the EEA.

We take appropriate measures when we transfer your personal data outside the EEA to ensure your personal data remains protected and to comply with applicable data protection laws.

The bases, mechanisms, and measures we rely on include:

● Adequacy Decisions.When applicable, we may rely on EU adequacy decisions to transfer your personal data outside the EEA. When the relevant EU authority issues an adequacy decision, that means they found the third country to offer adequate protection for personal data.

● Derogations.We may transfer your personal data based on a derogation listed in Article 49 of the GDPR. We will only do so if the transfer of personal data meets specific strict conditions according to the GDPR or other applicable laws.

● Standard Contractual Clauses.We have implemented measures to protect your personal data, including by using Standard Contractual Clauses for transfers of personal data between us and our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal data that they process originating from the EEA in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and further details can be provided upon request.

● Supplementary Measures.When necessary, in addition to the Standard Contractual Clauses, we may adopt technical, contractual, and organizational supplementary measures to better ensure that the level of protection guaranteed by the GDPR is not undermined by the transfer.

■ 9.Business Transactions

If SiBio is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.

■ 10.Security of Your Personal Data

The security of your personal data is important to us, we have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we process. However, despite our safeguards and efforts to secure your personal data, no electronic transmission over the internet or data storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your personal data. In the case of a data breach, we will comply with the requirements of the GDPR and other applicable laws, including taking necessary remedy measures, notify the supervisory authorities and/or you, if required.

Although we will do our best to protect your personal data, transmission of personal data to and from our SIJOY CLM App is at your own risk. You should only use the SIJOY CLM App and our Services within a secure environment.

■ 11.Your Rights and How to Exercise Your Rights

We take your privacy seriously and provides the full suite of GDPR rights to all our users globally. Where our use of your personal data is based on your consent, you also have the right to withdraw that consent at any time (please see below for more details).

To exercise your right as data subject, please send your request to [service@sibionics.com], and , we will respond as appropriate and within [three workdays] under applicable law. We will retain your request and our response (including any supporting documentation) in compliance with applicable laws. Also, we will continue to retain and otherwise process your personal data to the extent required to comply with applicable law; or, to establish, exercise or defend our legal claims and rights.

● Be Informed.You have right to be informed about how your personal data is being used.

● Access.You have a right to access your personal data that we, or our third-parties acting on our behalf, process to the extent the information does not contain personal data of another individual.

● Correction. You have a right to correct or rectify your personal data.

● Erasure.You have a right to have your personal data erased with limited exception. Specifically, you have a right to have your personal data erased if an exception does not apply and your personal data is no longer required for the purpose(s) it was collected or otherwise processed; our processing is based on your consent and you withdraw your consent; you have objected to our processing and there are no overriding legitimate grounds for processing (including but not limited to completing a transaction with you, fulfilling a contract with you, protecting against security incidents, fraud, malicious or illegal activity); we have not lawfully processed your personal data; or erasure is required under applicable law. Your right to have your personal data erased does not apply when: applicable law requires otherwise; processing is required to exercise the right of freedom of expression and information; processing is required to comply with a legal obligation; processing is required for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes to the extent permitted by applicable law and erasure will seriously impair or prevent the achievement of such processing objectives; or, processing is required to establish, exercise, or defend legal claims and rights. With respect to your personal data that is contained in our backups and is not subject to one of the preceding exceptions, we will delete your personal data permanently and securely in accordance with our schedule for the disposition of backups.

● Restrict Processing.You have a right to limit the use or otherwise temporarily restrict our processing of your personal data for a defined period of time.

● Object to Processing. With limited exceptions, you have a right to object to our processing of your personal data where the processing is based on legitimate interests pursued by us; the processing is for the purpose of direct marketing; or the processing is for scientific, historical research or statistical purposes. However, you do not have a right to object to processing where we can demonstrate legitimate grounds that override this right; the processing is required to comply with applicable law; the processing is required to establish, exercise or defend legal claims or rights.

● Withdraw Consent.You may opt out or revoke your consent to, as applicable, receive promotional communications from us by selecting the “unsubscribe” link in the promotional email we send you, by phoning us at our phone number communicated to you in the promotional email or by contacting us at the information below. Please note that, even after you opt-out or revoke your consent to receive promotional materials from us, you will continue to receive transactional messages if you have an account with us or otherwise use our Services. We may also need to retain certain information for recordkeeping purposes.

● Portability.You have a right to request the transfer of your personal data in certain circumstances. This includes data we process in an automated way based on your consent, to perform a contract with you, or to take steps you request before entering into a contract with you.

● Right to Lodge a Complaint. If you have unresolved concerns, you also have the right to complain to data protection authorities. The relevant data protection authority will be the supervisory authority located in the EU Member State that you reside in.

Please note that where we require your personal data to comply with legal or contractual obligations, provision of such data is mandatory: If such data is not provided, then we will not be able to manage the relationship, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.

Please also be noted that, before we respond to your request, we may have to ask you to provide necessary identification data in order to verify your identity.The response to your reasonable request is generally free of charge, unless such requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either refuse to act on such request or charge a reasonable fees

■ 12.Children's Privacy

Our Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your personal data and your country requires consent from a parent, We may require your parent's consent before we collect and use that data.

■ 13.Links to Other Websites

Our Services may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

■ 14.Changes to this Privacy Policy

We may update this Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the “Version Date” at the top of this Policy.

You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.

In the case that the aforementioned changes of this Policy consist material change to your lawful right and interest or to our obligation regarding the processing of your personal data, we would obtain your consent to this Policy by reasonable means, if it is required by the applicable laws.

■ 15.Contact Us

If you have any questions about this Privacy Policy, you can contact us:

• Email us at:support@sibiolife.com