Personal Data Protection Policy

1、Personal Data

Personal data refers to any information related to an identified or identifiable natural person, recorded electronically or otherwise, excluding data that has been anonymized. When you use our websites, products, or services, or interact with us, you may voluntarily provide such data, or we may obtain it by tracking your interactions with our platforms, such as through the use of cookie technology. The types of data we collect depend on the specific resources you access or services you utilize and may include, but are not limited to, names, addresses, email addresses, phone numbers, etc. We gather this data to maintain effective communication with you, to provide the services you need, and to deliver important notifications.

2、Privacy Policy

Ningbo Sunways Technologies Co., Ltd. and its global affiliates (hereinafter collectively referred to as "Sunways", "we", or "our") fully understand the value and sensitivity of personal data for our clients and users. As such, we strongly commit and actively invest in safeguarding the security of our customers' personal data, ensuring that all business operations comply strictly with applicable personal data protection regulations, such as the GDPR.

2.1 Data Protection Officer (DPO)

To effectively implement personal data protection requirements, Sunways has officially appointed a dedicated Data Protection Officer.

2.2 Industry Standards & DPIA

• Comprehensive Assessment：We conduct thorough assessments of all personal data involved in our products and services; projects involving personal data must undergo a DPIA.
• Inventory & Data Flow Diagrams：Projects involving personal data must compile detailed inventories and data flow diagrams.
• Risk Identification & Mitigation：We identify potential risks throughout the entire data processing chain (including collection, usage, storage, sharing, deletion, etc.) and implement corresponding management, physical, and technical safeguards based on the risk level.
• Assessment Report & Approval：After completing the DPIA, we generate an assessment report, which must be approved by the Data Protection Officer.

2.3 Technical Safeguards

We deploy a comprehensive array of advanced security technologies, including intrusion detection, access control, data encryption, data leak prevention, anti-spam measures, endpoint security, vulnerability scanning, and regularly conduct penetration tests to verify the efficacy of our personal data protection measures.

2.4 Incident Response

We have established a rapid response mechanism for personal data breaches. In the event of a data breach, Sunways will immediately initiate emergency procedures to minimize potential impacts on individuals and ensure timely and appropriate notification to affected individuals.

2.5 Employee Training

We have built a continuous privacy policy training system to ensure that all employees involved in GDPR-related work have a precise understanding and strict adherence to data protection laws and internal company regulations.

2.6 Audits & Compliance

To ensure compliance, we periodically conduct technical and process audits of personal data protection.

3、External Disclosure of Personal Data

We disclose your personal data only under the following circumstances:

• Your Explicit Consent or Authorization
• Legal, Administrative, or Judicial Requirements
• Necessary for Protecting Sunways', Affiliates', Partners', Your Own, Other Users', or Public Interests, Property, or Safety
• Essential for Core Functionality of Products & Services or Provision of Required Services
• In Accordance with Agreements (Including Electronic Agreements, Platform Rules) or Other Legal Documents You Have Entered into with Us
• Academic Research Purposes
• Statutory Uses for Public Interest, Unexpected Public Health Emergencies, etc.

4、Policy Updates

Sunways reserves the right to update or revise this Privacy Policy at any time. Any changes will be published on this page. For significant policy changes, we may notify you through website announcements, separate notices, or other means.

5、Contact Information

For inquiries, concerns, complaints, reports, suggestions, or feedback regarding this Privacy Policy or the processing of your personal data, please reach out to us through the following channels:

• Email Address：service@sunways-tech.com
• Phone Number：400 9922 958
• Postal Address： Green Park No.1, Lv Yuan Er Road, Chongshou Town, Cixi City, Zhejiang Province

Ningbo Sunways Technologies Co., Ltd. remains steadfastly committed to protecting the security of your personal data and respecting your privacy rights. We appreciate your trust and support.