Privacy PolicyEffective as of May 4, 2022

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

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

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

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

Part 1 Definitions

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

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

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

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

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

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

Part 2 Legal Statement

I. Ownership of Rights

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

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

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

II. Limitation of Liability

Where KingDraw users upload, provide or publish relevant information on or in KingDraw App, KingDraw official website, forums, communities and open platforms, including but not limited to user name, company name, contact person and contact details, relevant pictures and information, such information shall be provided by KingDraw users on their own and KingDraw users must legally assume all liabilities for any information they provide.

KingDraw hereby reminds you that you shall abide by laws of the People’s Republic of China and all other applicable domestic laws in the countries in using KingDraw’s products and services, and you shall not endanger cyber security or utilize KingDraw products and services to engage in activities that infringe upon others’ reputation right, privacy, intellectual property rights or other legitimate interests. Notwithstanding such reminders, KingDraw will assume no liability for your purposes of using KingDraw products and services.

Part 3 Privacy Policy

This part will help you understand the followings:

➢ How we collect and use your Personal Information; ➢ How we share, transfer and disclose your Personal Information; ➢ How we protect your Personal Information; ➢ How we protect and use your file information in the cloud; ➢ Additional privacy information for EEA residents; ➢ Additional privacy information for California residents; ➢ How we update this Policy; ➢ How to contact us.

I. How we collect and use your Personal Information

(I) How we collect your information

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

1. Help you become a KingDraw user

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

After becoming a KingDraw user, you may modify your Personal Information, such as phone number, E-mail type of industry, etc. The operation routine is like this: mobile phone-down toolbar—Me- clickprofile.

2. Provide you with products or services

1) Information provided by you to us

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

Payment information: In connection with the facilitation of transactions, purchases, and payments over the KingDraw, you will be asked to provide certain payment information. This might include bank account numbers, billing information, credit/debit card numbers, and security code to facilitate the purchase as well as the settlement of the products or services transacted on or procured through the KingDraw.

2) Information collected by us when you use services

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

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

Log information. When you use products or services provided by our website or client, we will automatically collect detailed information relating to your use of our services and save them as network logs, such as problems affecting operations during use of the service and problems with unexpected software exit, etc. Please note that the device information or log information alone is not sufficient to identify a certain natural person. If we combine such non-personal information with other information to identify certain natural person, or use the same in combination with Personal Information, then such non-personal information will be deemed as personal information during such combination, and we will anonymize and de-identify such personal information unless with your authorization or it is otherwise provided by laws and regulations.

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

Information collected using cookies and other web technologies. Like many website owners and operators, we use automated data collection tools such as Cookies to collect certain information. “Cookies” are small text files that are placed on your hard drive by a Web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and Web traffic routing on our Services, and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your hard drive on the basis of related arrangement. Please note that this Privacy Policy covers only our use of Cookies but not use of Cookies by such third parties.

3. Provide safeguards for you

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

4. Other purposes

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

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

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

(II) How we use your information

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

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

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

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

Any other purpose as permitted by you.

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

(I) Share

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

Payment service providers: We may disclose (or provide access to) Personal Information to the payment service providers, such as Google Play, and Apple App Store ​who collect and process personal information to assist with settling the payments for transactions. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy;

Cloud providers, who may receive the information you choose to provide, and the information we collect automatically.

Parties you authorize, access or authenticate: Third parties you access through the services. You can choose to send the files and pictures you created in our applications to several third party backup services (such as Dropbox, Google Drive, Box, OneDrive, etc.) available through our Services. You can also choose to sync up the files and pictures you created in our applications across your devices through Apple’s iCloud services.

Other individuals to whom you, directly or indirectly, shared a link to your shared files through the Services.

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

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

(II) Transfer

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

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

(III) Public disclosure

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

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

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

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

1. National safety and national defense security are involved;
2. Public security, public health, or major public interests are involved;
3. Criminal investigation, prosecution, judgment and enforcement are involved;
4. For the purpose of protecting your or other individual’s life, property and other major lawful rights and interests, where it is hard to obtain your or such individual’s prior consent;
5. Infringement of patent rights of others;
6. The personal information is disclosed voluntarily by you to the public;
7. The personal information is collected from the information disclosed through lawful channels, such as lawful news reports or information disclosure by government.

Pursuant to laws, sharing and transfer of de-identified personal information which cannot be recovered by the recipient to re-identify the subjects of such personal information does not constitute sharing, transfer and disclosure of personal information to the public, and therefore it may be stored and processed without notice to you and without your consent.

III. How we protect your personal information

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

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

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

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

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

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

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

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

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

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

1. National safety and national defense security are involved;
2. Public security, public health, or major public interests are involved;
3. Criminal investigation, prosecution, judgment and enforcement are involved;
4. For the purpose of protecting your or other individual’s life, property and other major lawful rights and interests, where it is hard to obtain your or such individual’s prior consent;
5. The personal information is disclosed voluntarily by you to the public;

V. Protection of minors

We attach great importance to the protection of information of minors. To protect children’s privacy and safety, we provide specific protection with regard to children’s personal data. Our Services are not directed to children under the age of 16 years (or otherwise provided by the related jurisdiction) and we do not knowingly collect, store, share or use personal data from children. If you are a child under 16(or otherwise provided by the related jurisdiction), you are not permitted to use and install our products or create your own KingDraw IDs, unless your parent provides verifiable consent. If we learn that we have collected personal data of a child under 16, unless we have first obtained verifiable, explicit parental permission for collecting personal data of such child, we will take steps to delete the information as soon as we can.

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

VI. Additional privacy information for EEA residents

In this section, we provide additional information to European Economic Area (EEA) residents, as required under EU privacy laws, including the General Data Protection Regulation (“GDPR”).

(I) Legal basis of processing information

We process information if one of the following applies:

1. Necessary for entry into, or performance of, any contract(s) with you (Art 6(1)(b) of the GDPR). This applies to section 5(1) to provide the Services, which include troubleshooting, customizing, identifying, supporting.
2. Necessary for the legitimate interests of us, where these are not overridden by your interests or fundamental rights and freedoms (Art 6(1)(f) of the GDPR). This applies to section 5(2) to improve and develop our Services, 5(3) to protect the security and prevent criminal activity.
3. Necessary for compliance with a legal obligation to which we are subject (Art 6(1)(c) of the GDPR). This applies to section 5(4) to comply with our legal obligations.

(II) Cross-border transfer of information

If you are based within EEA, please note that where necessary to deliver the services, we will transfer personal information to countries/territories outside the EEA (e.g., China). Countries/territories outside the EEA may not provide an adequate level of protection to your personal information; however, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. The safeguard we primarily rely upon is the European Commission-approved standard contractual data protection clauses.

(III) GDPR rights

In general, EEA residents have the following rights with respect to their personal information:

1. Right to object. You have the right to object to the processing of your information. If you object, we will no longer process your information unless we can prove compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims on our part.
2. Right to restriction of processing. You have the right to request us to process your information only to a restricted extent under the following conditions:
the accuracy of your information is contested;
you request limited processing instead of deletion under the conditions of a justified right of erasure;
the data is no longer required for the purposes pursued by us, but you need the information to assert, exercise or defend legal claims; or
the success of an objection is still disputed.
3. Right to data portability. You have the right to receive from us information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, as well as the right to request us to forward this information to another controller under the following conditions:
the processing is based on consent or the contract, or
the processing is carried out by automated means.

VII. Additional privacy information for California residents

In this section, we provide additional information to California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”). This section does not apply to publicly available information lawfully made available by state or federal government records, deidentified information, aggregate consumer information, or other personal information that is exempt under the CCPA (such as information covered by the Health Insurance Portability and Accountability Act).

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about California residents in the prior 12 months (from the Last Updated date above), and the rights California residents have under the CCPA regarding this personal information.

CCPA Rights

In general, California residents have the following rights with respect to their personal information:

Do-not-sell (opt-out): to opt-out of our sale of their personal information, including those we have actual knowledge are younger than 16.

Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies.

Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):

1. categories of personal information collected;
2. categories of sources of personal information;
3. categories of personal information about them we have disclosed for a business purpose or sold;
4. categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
5. the business or commercial purposes for collecting or selling their personal information;
6. a copy of the specific pieces of personal information we have collected about them
Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA requests

California residents may submit CCPA requests to exercise their “Right to know (access)” and “Right of deletion” to kingdraw@kingagroot.com.

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must provide your name and contact information to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us by email; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

VIII. How we update this Policy

Our private policy maybe updated from time to time.

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

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

1. Our service pattern changes greatly, such as the purpose of dealing with KingDraw user’s personal information, information processing method, etc.;
2. Our control and organization structure changed greatly, such as the business adjustment, bankruptcy, merger and acquisition, etc.;
3. Our KingDraw user’s personal information sharing, transfer or public disclosure main target change;
4. Our internal department charging the security, its contact information, and complaints channels change;
5. Any KingDraw user information security impact assessment indicates that there is a high risk.

IX. How to contact us

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

Qingdao KingAgroot Precision Agriculture Technology Co., Ltd.
Address: No.53, Qinglonghe Road, Huangdao District, Qingdao
Post code: 266000
E-mail: kingdraw@kingagroot.com

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