PRIVACY POLICY

Our Privacy Policy was updated on 12.27 2021

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

ABOUT US

Super Creativity Limited (hereinafter refer to as “ Emotn ”, “we”, “our” or “us”) take your privacy very seriously. This Privacy Policy is designed with your needs in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, while ensuring that ultimately, you have control of your personal information provided to us .

ABOUT THIS PRIVACY POLICY

This Privacy Policy explains how Emotn collects, uses, discloses, processes and protects any personal information that you give us or that we collect from you. Should we ask you to provide certain information by which you can be identified when you use the services on our platform, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users. Under this Privacy Policy, “personal information” means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information Emotn has access to about that individual, except as otherwise specifically provided by applicable laws in your region. We will use your personal information strictly in accordance with this Privacy Policy.

HOW WE CAN HELP YOU

Ultimately, what we want is the best for all our users. Should you have any questions with our data handling practices as summarized in this Privacy Policy, please contact us at https://www.emotn.com to address your specific concerns. We will be happy to hear from you.

1 WHAT INFORMATION IS COLLECTED BY US AND HOW DO WE USE IT?

In order to provide you with services, we will ask you to provide the necessary personal information related to these services. We will only collect the information necessary for its specific, specific, clear and legitimate purpose, and will not further process it in a way that is inconsistent with these purposes. You have the right to choose whether to provide the information we request. Depending on the service you choose, we may collect the following types of information:

(1) Provide, process, maintain, improve and develop our services to you;

(2) To deal with your questions or requests for our services, such as sending notifications.

2 COOKIES AND OTHER TECHNOLOGIES

Technologies such as cookies, tags, and scripts are used by Emotn and our third party service providers and business partners (for more information see “How we share, transfer, and publicly disclose your personal information” below). These technologies are used in analyzing trends, administering the site, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. These technologies help us better understand users’ behavior, tell us which parts of our websites people have visited, as well as facilitate and measure the effectiveness of web searches. We treat information collected by cookies and other technologies as non personal information, except where Internet Protocol (IP) addresses or similar identifiers are considered personal information by local laws.

· Log files: As true of most websites, we gather certain information and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we gather about you.

· Local storage – HTML5/Flash: We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content and preferences. Third parties with whom we partner to provide certain features on our sites also use HTML5 or Flash cookies to collect and store information. Various browsers may offer their own management tool for removing HTML5 LSOs.

3 HOW WE SHARE, TRANSFER, AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION

3.1 SHARING

We do not sell any personal information to third parties.

We may sometimes share your personal information with third parties (as described below) in order to provide or improve our services, including offering services based on your requirements. If you no longer wish to allow us sharing this information, please contact us at https://www.emotn.com 。

3.1.1 SHARING THAT YOU ACTIVELY CHOOSE OR REQUEST

With your explicit consent or at your request, we will share your personal information within the scope of your consent/request with specific third parties designated by you.

3.1.2 SHARING INFORMATION WITH OUR GROUP

In order to successfully conduct business operations and to provide you with all the functions of our services, we may share your personal information from time to time to other Emotn affiliates.

3.1. 3 SHARING WITH THIRD PARTY SERVICE PROVIDERS AND BUSINESS PARTNERS

To help us provide you with services described in this Privacy Policy, we may, where necessary, share your personal information with our third party service providers and business partners. This includes our data centers, data storage facilities and other business partners , such as Alibaba cloud and Amazon cloud. These third parties may process your personal information on Emotn ’s behalf or for one or more of the purposes of this Privacy Policy. We guarantee that the sharing of personal information necessary for providing services to you is solely for legitimate, legal, necessary, specific, and explicit purposes. Emotn will conduct due diligence and have contracts in place to ensure that third-party service providers comply with the applicable privacy laws in your jurisdiction. There may be occasions that third-party service providers have their sub-processors.

To provide performance measurement, analysis, and other business services, we may also share information (non-personal information) with third parties in aggregated form. We use the information we have to help our business partners evaluate the effectiveness and coverage of their services, and understand the types of people who use their services and how people interact with their websites, apps, and services. We may also share general usage trends of our services with them, such as the number of customers in a particular group of people who purchase certain products or engage in certain transactions.

3.1. 4 OTHER

In accordance with legal requirements, legal procedures, litigation and/or requests from public agencies and government agencies, we may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.

In order to enforce our terms or protect our business, rights, assets or services, or to protect users, or if the disclosure is reasonably necessary for the following purposes (detecting, preventing and resolving fraud, unauthorized use of the service, violations of our terms or policies, or other harmful or illegal activities), we may also disclose information about you. (There may be occasions when we may collect, use or disclose your personal information without your consent if it is and only to the extent it is permitted under applicable data protection laws). This may include providing your personal information to public or government agencies; communicating with third-party partners about the reliability of your account to prevent fraud, violations, and other harmful behaviors.

In addition, we may share your personal information with:

· our accountants, auditors, lawyers, or similar advisers when we ask them to provide us with professional advice; and

· investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to an entity of Emot n affiliates ; and

· any other third parties, if authorized by you to do so in relation to a specific disclosure.

3.2 TRANSFER

We will not transfer your information to any subject except in the following cases:

· Where we have obtained your explicit consent;

· If Emotn is involved in the merger, acquisition, or sale of all or part of its assets, we will notify you of any changes in the ownership, use, and any choice of your personal information you possibly possess by email and/or by posting a prominent notice on our websites.

3.3 PUBLIC DISCLOSURE

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

· Where we have obtained your explicit consent;

· Public disclosure based on law or reasonable grounds: including laws and regulations, legal procedures, litigation, or at the request of the competent government departments.

3 .4 Exceptions for obtaining prior authorization and consent when sharing, transferring, and publicly disclosing personal information

In any of the following cases , n o prior consent is required to share or disclose your information :

· It is related to our fulfillment of obligations as stipulated by laws and regulations;

· It is directly related to national security and national defense security;

· It is directly related to public safety, public health, and major public interests;

· It is directly related to criminal investigation, prosecution, trial, and execution of judgments;

· For the purpose of safeguarding the life, property and other important legal rights and interests of personal information subject s or other individuals, it is difficult to obtain authorization and consent of the subject;

· The personal information involved is disclosed to the public by the personal information subject;

· The personal information is collected from legally publicly disclosed information, such as legal news reports, government information disclosure, academic research results, and other channels;

· Other circumstances stipulated by laws and regulations.

4 HOW WE STORE AND PROTECT YOUR PERSONAL INFORMATION

4 .1 How do we store your personal information

We will store your information with security techn ological protection measures, including local storage, data cach ing , database and server log. All your personal information will be stored on secure servers and protected in controlled facilities. Your information will be classified according to its importance and sensitivity, and your personal information will surely possess the required level of security. We have special access controls for cloud-based data storage. A periodic review will be performed on o ur information collection, storage and processing practices, including physical security measures, to prevent any unauthorized access and use.

4.2 Emotn 'S SECURITY SAFEGUARDS

We are committed to keeping your personal information secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place all legally required physical, electronic and managerial procedures to safeguard and secure the information we collect from you. We will ensure that we safeguard your personal information in accordance with applicable law.

We conduct due diligence on business partners and third party service providers to make sure that they are able to protect your personal information. We also check that appropriate security standards are maintained by these third parties by putting in place appropriate contractual restrictions, and where necessary, carrying out audits and assessments. In addition, our employees and those of our business partners and third party service providers who access your personal information are subject to enforceable contractual obligations of confidentiality.

We conduct security and privacy protection training courses and tests to enhance our employees' awareness of the importance of protecting personal information. We will take all practicable and legally required steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information when transferred from you or to you via the Internet.

We handle personal data breaches as required by applicable data protection law which includes, where required, notifying the breach to the relevant data protection supervisory authority and data subjects.

4.3 WHAT YOU CAN DO

You can not disclosing your sign-in password or account information to anybody (unless such person is duly authorized by you) to avoid password leaks to other websites which may harm your account security . Whenever possible, please do not disclose the verification code you received to anyone (including those who claim to be Emotn ’ s customer service). If you need to use your account to log in to use our services, particularly on somebody else's computer or on public Internet terminals, you should always sign out at the end of your session.

We cannot be held responsible for lapses in security caused by third party accessing your personal information as a result of your failure to keep your personal information private. Notwithstanding the foregoing, you must notify us immediately if there is any unauthorized use of your account by any other Internet user or any other breach of security. Your assistance will help us protect the privacy of your personal information.

4.4 RETENTION POLICY

We retain personal information for the period necessary for the purpose of the information collection described in this Privacy Policy, or as required by applicable laws. We will cease to retain and delete or anonymize personal information once the purpose of collection is fulfilled, or after we confirm your request for erasure, or after we terminate the operation of the corresponding service. An exception to this is personal information that we are processing for public interest, scientific, historical research, or statistical purposes. We will continue to retain this type of information for longer than its standard retention period, where permitted based on applicable laws or your request, even if further data processing is not related to the original purpose of collection.

5 YOUR RIGHTS CONTROLLING YOUR PERSONAL INFORMATION

5.1 CONTROLLING SETTINGS

We recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways Emotn makes available to you to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings, such as sign in or out of the Account.

If you have previously agreed to us using your personal information for the aforementioned purposes, you may change your mind at any time by emailing us with the following email address: support@emotn.com .

5.2 YOUR RIGHTS TO YOUR PERSONAL INFORMATION

Depending on applicable laws and regulations, you have the right to access, rectification, and erasure of any other personal information that we hold about you (hereinafter referred to as the request).

You may also access and update the details relating to the personal information in your Account by logging into your account on your device. For additional information, please write to us or contact us at https://www.emotn.com .

This Privacy Policy requires that your request satisfy applicable laws and regulations and the following conditions:

(1) Through Emotn 's particular request submission channels listed below, and your request should be in writing (unless the local law explicitly recognizes the oral request), for the protection of your information security;

(2) Provide sufficient information to enable Emotn to verify your identity and ensure that you are the subject of the requested information or a personal legally authorized to act on the subject’s behalf.

Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.

In detail:

· You have the right to be provided with clear, transparent and easily understandable information about how we use your personal information and your rights. This is why we are providing you with the information in this Privacy Policy.

· Based on the requirements of applicable laws, a copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests for relevant information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.

· If any information we are holding on you is incorrect or incomplete, you are entitled to have your personal information corrected or completed.

· • Based on the requirements of applicable laws, you have the right to request the deletion or removal of your personal information where there is no compelling reason for us to keep using it. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures. If the right is upheld, we may not be able to immediately remove the information from the backup system due to applicable law and/or technology limitations. If this is the case, we will securely store your personal information and isolate it from any further processing until the backup can be cleared or be made anonymous.

· You have the right to object to certain types of processing, and under certain circumstances where the legal basis for processing is our legitimate interests..

Particularly under the laws of some jurisdictions:

· You have the right to obtain from us the restriction of processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.

· You have the right not to be subject to a decision based solely on automated processing, which produces legal effects concerning you or similarly significantly affects you.

· You have the right to apply for your personal information in a structured, commonly used format and transmit the information to another data controller.

We have the right to refuse to process requests that are frivolous requests that damage others' right of privacy, extremely unrealistic requests, requests that require disproportionate technical work, and requests not required under local law, information that have been made public, information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, it may also be rejected.

6 HOW YOUR PERSONAL INFORMATION IS TRANSFERRED GLOBALLY

Emotn processes and backs up personal information through a global operating and control infrastructure. Currently, Emotn has data centers in the United States and China . For the purposes described in the Privacy Policy, your information may be transferred to these data centers in accordance with applicable law.

We may also transfer your personal information to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions. The jurisdiction in which these global facilities are located may or may not protect personal information to the same standards as in your jurisdiction. There are different risks under different data protection laws. However, this does not change our commitment to comply with this Privacy Policy and to protect your personal information.

If we need to transfer personal information outside of your jurisdiction, whether to our affiliates or third-party service providers, we will comply with related applicable laws. We ensure that all such transfers meet the requirements of applicable local data protection laws by implementing uniform safeguards. You can find out about the safeguards that we have in place by contacting us at https://www.emotn.com .

7 PROTECTION OF MINORS

We consider it the responsibility of the parent or guardian to supervise the child's use of our services. However, we do not offer services directly to a child or use personal data of children for the purposes of marketing.

If you are a parent or guardian and you believe that the minor has provided Emotn with personal information, please contact us at https://www.emotn.com to ensure that the personal information is removed immediately and that the minor is unsubscribed from any of the applicable Emotn services.

8 DO I HAVE TO AGREE TO ANY THIRD PARTY TERMS AND CONDITIONS?

Our Privacy Policy does not apply to products or services offered by a third party. Depending on the service you use, it may incorporate a third parties’ products or services. Some of these will be provided in the form of links to third parties’ websites. Your information may also be collected when you use these services. For this reason, we strongly suggest that you take the time to read the third party’s privacy policy just like you read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

9 HOW WE UPDATE THIS PRIVACY POLICY

We review the Privacy Policy periodically based on changes in business and technology, and we may update this Privacy Policy. If we make a material change to this Privacy Policy, we will notify you via your registered contact information such as email (sent to the email address specified in your account) or publish on Emotn websites or notify you via mobile devices so that you can learn about the information we collect and how we use it. We encourage you to check this page regularly for the latest information on our privacy practices. Your continued use of the services will be deemed acknowledgement of the updated Privacy Policy. We will ask for your explicit consent when we collect additional personal information from you or when we use or disclose your personal information for new purposes.

10 CONTACT US

If you have any comments or questions about this Privacy Policy or any questions relating to Emotn ’s collection, use, or disclosure of your personal information, please contact us at the following address : ( 1)Official customer service email: support@emotn.com ；（ 2 ） Official website: https://www.emotn.com . When we receive privacy or personal information questions about access/download requests, we have a professional team to solve your problems. If your question itself involves a significant issue, we may ask you for more information. If you are not satisfied with the response you received, you can hand over the complaint to the relevant regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your actual situation.