Privacy Policy

This Privacy Policy contains important information as it sets out how BOE Technology Group Co., Ltd. (hereinafter referred to as “BOE”, “we” or “us”) handles personal data of visitors of “boe.com” webpage and it’s sub-pages, and “event.boe.com” webpage and it’s sub-pages (hereinafter referred to as “the Website”), including employees of customers and suppliers and other third parties (“hereinafter referred to as “you”). We attach great importance to the protection of your privacy and personal data. This privacy policy explains to you how we collect, use, save, share, transfer or otherwise process your personal data when you, or in the case of business users any individuals acting on your behalf.

We may from time-to-time revise or add specific instructions, policies, and terms to this Privacy Policy. Whenever we make any changes to this Privacy Policy that are important for you to know about, we will notify you by email or text message or other means.

Please read this Privacy Policy carefully.

If you have any question about this Privacy Policy, please send an email to: boecbmo@boe.com.cn.

BOE collects and uses your personal data for the following reasons/purposes:

• Improve the user experience;

• Provide service or function at your request;

• Evaluate and analyse markets, customers, products and services (including conducting customer surveys) so that we can improve and develop our products and services;

• Improve your security or provide customer support;

• Use of various personal data for commercial purposes, including but not limited to providing value-added services, advertising, marketing or other activities to third parties;

• At the request of the judicial or the government authorizations;

• Other circumstances which benefit the users and BOE, and do not violate any applicable laws and regulations or other purposes with your consent.

Personal contact information. When you contact to provide us with comments, suggestions or enquiries, make an appointment as an investor to research at BOE, book a live broadcast, participate in our online and offline activities, subscribe to marketing materials, etc., you may provide your contact information, including your name, company name, position, title, email address, telephone number, etc.. You are not required to provide us with personal information, but in some cases, if you choose not to do so, we may not be able to provide you with the relevant products or services, or respond to your needs or solve the problems you encounter.

Cookies. The Website uses cookies or similar technologies, which will collect information about your use of the service, such as the application used, the site visited, and how to interact with the content provided through the service. Please check the cookies section of this Privacy Policy for further details.

It may be that providing certain personal data to us is a statutory or contractual requirements, a requirement necessary to enter into a contract, or that you are otherwise obliged to provide the data to us. If that is the case, we will inform you thereof separately, and will also explain the possible consequences if you fail to provide such personal data to us. In all other cases, provision of the requested personal data is optional, but it may affect your ability to use certain services or to participate in certain programs or systems, where the information is needed for those purposes.

Other than consented by you, we commit that we will not share or sell your personal data to any third party. In addition to the information disclosed in the “COOKIES AND SIMILAR TECHNOLOGIES” section, we may share information with the following third parties:

Depending on where you are and which product you asked for, we may share your personal data with our affiliates so that we can response to your request, provide our services or for general purposes. You can obtain the identity and contact details on our affiliates with who we share your personal data by contacting us using the details set out below in the “CONTACT US” section.

We will not disclose or transfer your personal data to any non-affiliated third parties, unless:

We will share personal data if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process/procedure, lawsuit or enforceable governmental request.

To provide you with a better experience through improving the Website or otherwise where you have consented, we may share the personal data with third-party service providers (in particular, site hosting, backend service provider, analytics service providers), contractors and agents, and use it consistent with this Privacy Policy.

If BOE is involved in a reorganization, merger, acquisition, sales of assets or liquidation, we will continue to ensure the confidentiality of your personal data and give affected users notice personal data is transferred or become subject to a different Privacy Policy in advance.

When using the Website, you can always manage, review and update information by connecting us via boecbmo@boe.com.cn. In the meanwhile, you are responsible for the truthfulness, accuracy, legality, validity and completeness of the information you provide, and update and maintain your personal data in a timely manner to ensure the truthfulness, accuracy and validity of the information.

You can export a copy of the information you provided to us if you want to back it up or use it with a service outside of the Website by sending your request to boecbmo@boe.com.cn. We will help you export the information based on applicable law and your specific request. You can also remove or delete information you provided. If there is any content you cannot remove or delete, please reach us via boecbmo@boe.com.cn. In some cases, we retain data for limited periods when it needs to be kept for legitimate business or legal purposes or to be protected from accidental or malicious deletion, there may be delays between when you delete something and when copies are deleted from our active and backup systems.

We use technology such as cookies, beacons and other technologies to collect information and store your online preferences.

A cookie is a very small text document, which often includes an anonymous unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website's server. Find out more about the use of cookies on www.allaboutcookies.org.

You can withdraw your consent to these cookies at any time by cleaning the cookies through your browser settings.

Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.

By accessing and using our services, you agree to store cookies on your device. In addition, you also agree that we and these third parties access such cookies information.

We use Cookies on our website as described below:

With the exception of cookies that are necessary for the proper functioning of the website and the provision of basic functions and services, all cookies will expire after the respective period that has been set.

We use a variety of organizational and technical security measures, including encryption and authentication tools, to protect your personal data. We use secure servers when you place orders.

We may maintain servers around the world and your information may be processed on servers located outside of the country where you live. Regardless of where your information is processed, we apply the same protections described in this policy. We will also keep this Privacy Policy in compliance with significant legal frameworks relating to the transfer of data. If we receive your complaints about data transfers, we will cooperate with appropriate regulatory authorities when we cannot directly resolve it. Some of our recipients of your personal data are located in countries that may not – by law – provide the same level of data protection as you are used to in certain countries. If that is the case, we will ensure that adequate safeguards are in place to duly protect your personal data and we guarantee that we are able to and have mechanisms in place to respect the level of data protection required by EU data protection laws and that we shall refrain from processing personal data in the event of a breach of the concluded safeguarding measures or if we (or our recipients) are no longer able to honor them.

For transfers of personal data from EEA to a third country, please refer to our EEA SPECIFIC TERMS below.

We do not knowingly collect or solicit personal data from children under 16. If you are a minor under the age of 16, you must obtain prior written consent from your parents before using our services. If we are aware that a child under 16 has provided us with personal data without prior consent, we will delete such information from our files.

This Privacy Policy applies to all the services provided by BOE in connection with the Website. This Privacy Policy does not apply to products and services that have separate privacy policies that do not incorporate this Privacy Policy. For example, this Privacy Policy does not apply to the processing of personal data for recruitment under the “Join Us” section. Please refer to [https://campus.boe.com/Portal/Apply/PrivacyPolicy] for the specific provisions.

To better enrich your experience, there may be products or services provided by third parties (including BOE affiliates). You can choose whether to access such content or links, or whether to use the third party’s products or services. However, we do not have control over the products or services provided by third parties. We cannot control any of your personal data held by third parties. The information protection issues in connection with your use of any third-party products or services are not governed by this Privacy Policy. This Privacy Policy does not apply to any information you choose to provide to third parties.

If provisions from this Privacy Policy are in conflict with the law, they will be replaced by provisions of the same purport that reflects the original intention of the provision, all this to the extent legally permissible. In that case, the remaining provisions remain applicable unchanged.

You are entitled to the following rights:

a) right of access to your personal data;

b) right to data portability (i.e., you have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller);

c) right to correction if your personal data is not complete or accurate;

d) right to deletion or restriction of your personal data, as permitted by law;

e) right to object (i.e., objecting to our processing of your personal data) (e.g., in case we process your data for direct marketing purposes), as permitted by law.

Where we have asked for your consent, you may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your personal data based on the consent you provided before you withdrew it.

The exercise of the abovementioned rights is free of charge and can be carried out by phone or by e-mail via the contact details displayed below. If requests are manifestly unfounded or excessive, in particular because of the repetitive character, we will either charge you a reasonable fee or refuse to comply with the request. We may request specific information from you to help us confirm your identity before we comply with a request from you concerning one of your rights.

We will provide you with information about the follow-up to the request without undue delay and in principle within one month of receipt of the request. Depending on the complexity of the request and on the number of requests, this period can be extended by another two months. We will notify you of such an extension within one month of receipt of the request. The applicable privacy legislation may allow or require us to refuse your request. If we cannot comply with your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

These rights are not absolute, they may be limited in some situations. For example, where we can demonstrate that we have a legal requirement to process your data or if making the information available to you would reveal personal data about another person or if we are legally prevented from disclosing such information. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

We hope that we can satisfy any queries you may have about the way we process your data. In the event you still have unresolved concerns, you also have the right to lodge a complaint with a supervisory authority, in particular to the data protection authority in the country of your habitual residence or place of work.

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, please refer to CALIFORNIA SPECIFIC TERMS: PRIVACY DISCLOSURES below.

If we are legally required to do so, we will seek your prior consent before providing you with promotional materials or information. You may withdraw your consent at any time (this will not affect the processing of your personal information undertaken until the withdrawal). If you want to stop receiving promotional materials, etc., you can do so at any time by communicating with us.

We will retain your personal data for as long as is necessary to carry out the purposes set out herein. We will also retain your personal data deemed necessary to comply with legal obligations, settle disputes, and enforce agreements.

The retention period may vary with scenario, service and category of personal data. The criteria BOE uses to determine the retention period are as follows:

a) the time required to retain personal data to fulfil business purposes, including providing services;

b) maintaining corresponding transaction and business records;

c) controlling and improving the performance and quality of products and services;

d) ensuring the security of systems, products, and services;

e) handling possible user queries or complaints and locating problems;

d) ensuring the security of systems, products, and services;

f) whether the user agrees to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention. Where applicable, we will delete your personal data upon your request. We are entitled at all times to delete your personal data without notice. In such case, we owe no compensation to you as result of deletion of the personal data.

If you wish to obtain further information about the retention periods as applied to your personal data, you may contact us at boecbmo@boe.com.cn.

The data controller for your personal data will be BOE Technology Group Co., Ltd.

If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us at boecbmo@boe.com.cn or by writing to [No.12 Xihuanzhong RD, BDA, Beijing, P.R.China].

In addition to our Privacy Policy presented above, the following terms will apply to the processing of personal data of data subjects in the European Economic Area (“EEA”) or the UK.

We process this personal data for the following purposes and based on the following legal grounds:

• On the basis of our legitimate interests for example when required by us to conduct our business, in particular:

- we will use your information to respond to any comments or complaints you may send us;

- we monitor use of the Website and other online services, and use your information to help us monitor, improve and protect the websites;

- we use information you provide to personalise our website or services for you;

- we use information you provide to investigate any complaints received from you or from others, about the Website;

- we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and

- we will notify you about changes to our services, where applicable.

• On the basis of your consent:

- providing you with information relating to BOE or promotional details about services that may be of interest to you, as well as marketing mailings (electronic or otherwise) or other communications;

- we place cookies and use similar technologies in accordance with the cookies section of the Privacy Policy and the information provided to you when those technologies are used; and

- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.

• As this might be necessary for compliance with a legal obligation that is applicable to us, such as:

- in response to requests by government or law enforcement authorities conducting an investigation, or to comply with the requirements imposed by applicable law or any court order.

In situations where we transfer your personal data to countries outside of the EEA or the UK to an organisation in a country which is not subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the applicable laws by using the European Commission approved Standard Contractual Clauses, a vendor's Processor Binding Corporate Rules or by relying on such other data transfer mechanisms as available under applicable data protection laws, and where necessary, by implementing further (organisational/contractual/technical) supplement measures in order to ensure the effectiveness of the transfer mechanisms.

Where we transfer your personal data from EEA to other entities in China, we use the European Commission approved Standard Contractual Clauses. A copy of the relevant mechanism can be obtained for your review on request by contacting boecbmo@boe.com.cn.

If you are a California resident, the following additional privacy disclosures under the California Consumer Privacy Act of 2018 (“CCPA”) and other California laws may be applicable to you and allow you to exercise your rights regarding your personal information.

If the CCPA is applicable, you have the right to know and understand how we collect, use, disclose, and share your personal information, to access your information, to request that we delete specific information, to exercise your rights to opt-out, and also not be discriminated against when exercising your privacy rights granted under the CCPA.

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly, or indirectly, with a particular consumer, household, or device (“personal information”). We may have collected the following categories of personal information from users within the last twelve (12) months:

A. Identifiers: real name, online identifier, IP address, email address, or other similar identifiers.

B. Personal information categories listed in the California Customer Records statute, such as name, address, cell phone number, and other personal information details that may overlap with other categories.

C. Professional or Employment-related information: including work email, company name and type, job role, and industry.

D. Commercial information, including your browsing history.

E. Internet or other electronic network activity information, such as the usage data we receive when you access or use our services. This includes information about your interactions within the Website, and about the devices and computers you use to access the Website, as well as browsing history, and inquiry interactions.

F. Inferences that can be drawn from any of the above categories, including a person’s preferences and characteristics.

We obtain the categories of personal information listed above from the following categories of sources:

• Information and data directly provided by you on the Website.

• Information and data indirectly from you through the Website.

Personal information does not include:

• Publicly available information from government records.

• Deidentified or aggregated consumer information

• Information excluded from the CCPA’s scope, like: health or medical information covered by HIPAA, clinical trial data, or other qualifying research data; and personal information covered by certain sector-specific privacy laws, including the FCRA, GLBA, or FIPA, and the Driver’s Privacy Protection Act of 1994.

To better understand how we collect your information, please review the general terms of the Privacy Policy.

We may use, disclose, or sell (if authorized) the personal information we collect for one or more of the following business purposes:

• To provide you with the Website or otherwise fulfil or meet the reason for which you provided the information.

• To provide you with support and to respond to your inquiries, including to investigate user reported issues and address your concerns by monitoring and improving our responses to errors.

• To provide, support, personalize, improve, analyze, and develop our products and services for user experience and operational stability.

• To personalize user experience and to deliver content and products and service offerings relevant to your interests, including targeted offers and ads through our Website, and via email or text message (with your consent, where required by law).

• To notify you about changes to our services, where applicable.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• To help maintain the safety, security, and integrity of the Website, our databases and other technology assets, and business.

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.

• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

To better understand how we use and disclose your information, please review the general terms of the Privacy Policy presented above.

We may share your personal information by disclosing it to third parties for business purposes. We only make these business purpose disclosures under written contracts that describe the specific business purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the obligations under the contract.

As stated in the general terms of the Privacy Policy, we do not sell your personal information unless we obtain your consent. We do not knowingly collect personal information from individuals under age 16; and therefore, our personal information sales do not include information about individuals we know are under age 16.

In the preceding twelve (12) months, BOE has shared the following categories of personal information to the following categories of third parties:

To better understand how we share your information, please review the general terms of the Privacy Policy presented above.

The CCPA provides California residents specific rights to know about our collection and use of their personal information over the past twelve (12) months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling (if applicable) that personal information.

• The categories of third parties with whom we share that personal information.

• If we sold or disclosed (if applicable) your personal information for a business purpose, two separate lists disclosing:

- sales, identifying the personal information categories that each category of recipient purchased; and

- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

• The specific pieces of personal information we collected about you (also called a data portability request).

The CCPA provides California residents specific rights to delete their personal information that we collected from them and retained, subject to certain exceptions (the “right to delete”). We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Provide service that you requested from the Website, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug the Website to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

To exercise your rights to know or delete described above, please submit a request by emailing us at boecbmo@boe.com.cn.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: your identification information, a signed permission authorizing the representative to submit the request on your behalf, and any other information permitted or recommended by the CCPA and any applicable regulations.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the ten (10) business days timeframe, please contact us via email boecbmo@boe.com.cn.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We may deliver our written response by email.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Under the CCPA, consumers have the right to direct us to not sell their personal information at any time (the "right to opt-out"). As stated in the general terms of our Privacy Policy, we do not sell your personal information of consumers unless we obtain consent for the sale. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise your right to opt-out provided under CCPA, you (or your authorized representative) may submit a request to us by emailing us at boecbmo@boe.com.cn.

We will only use personal information provided in an opt-out request to review and comply with the request.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of the Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to boecbmo@boe.com.cn.

We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal identifiable information about an individual consumer's online activities over time and across third-party websites or online services.

When you use the Website, certain third parties may use automatic information collection technologies to collect information about you or your device. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services websites. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

If you are a user under the age of 18, you can send a request to remove any content or information you posted on the Website via email to boecbmo@boe.com.cn. Please notice that the removal does not ensure complete or comprehensive removal of your posted content or information.

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Website, and update the notice’s effective date. Your continued use of the Website following the posting of changes constitutes your acceptance of such changes.