Privacy Statement

Table of contents

Effective Date: February 5, 2025

Hello! Udesk is a service-oriented artificial intelligence and marketing service company, dedicated to applying artificial intelligence technology to various scenarios such as marketing acquisition, sales management, customer service and internal shared services. We have formulated this privacy statement (hereinafter referred to as the 'Statement') to explain to you how we collect, use, disclose and store personal data.

This statement only applies to situations where Udesk acts as a controller of personal data (for example: personal data of Udesk website visitors and corporate and corporate contact data). When our paying users use Udesk products and services, Udesk acts as a data processor, not a data controller. This statement does not apply to situations where Udesk processes personal data in its products and services as a data processor. If you have any questions about how Udesk's paying users use your personal data, please contact them directly. We are not responsible for the privacy and data security of paying users. This statement also does not apply to the personal data of Udesk's current and former employees, job seekers, agents, and contractors.

1： Introduction

This Statement applies to Wofeng Technology, Udesk.cn, Udeskglobal.com, other subsidiaries associated with Udesk and related affiliates mentioned in Section 14 (including 'Udesk', 'we', 'us' and 'our'). Terms we use but do not define in the Statement (such as site, service, subscriber, agent, agent contact information, etc.) are explained in detail in the main service agreement. If you are located in the European Economic Area ('EEA'), Switzerland or the United Kingdom ('UK'), please refer to Section 11 of this Statement for more information on which specific entity is the actual controller of your personal data.

What does this statement apply to? This statement only applies to situations where Udesk acts as a data controller, that is, Udesk controls the processing of your personal data). This includes you:

• Visit or interact with the Udesk website, Udesk mobile application, Udesk desktop application, Udesk App Marketplace, Udesk Developer Portal, Udesk branded social media pages and other websites operated by us (collectively, our 'Digital Properties');

• Register for or attend our webinars, events, programs, marketing and promotions;

• Interact with us offline or in person, such as when you visit our offices, ask us a question, or conduct a business transaction;

2：Personal Data We Collect and Disclose

• Personal Data We Collect and Disclose

• The following describes what personal data we collect about you and to whom we disclose it. This table includes the parties to whom we disclose personal data for business or commercial purposes as required by EU, US, and California personal data protection regulations

Categories of Personal Information Collected	Disclosure of Personal Information
Identifiers, such as your name, email address, postal address, telephone number, and device identifiers (such as advertising identifiers and IP address).	Affiliates and subsidiaries within the Udesk group, including the parent and ultimate holding company, affiliates, subsidiaries, business units and other companies acquired by us that will become part of the Udesk group in the future Service providers, such as security and platform vendors Third-party partners, such as credit card providers Sales partners, such as marketing business partners, channel partners, sales partners Sponsors Professional advisers, such as lawyers, accountants and auditors Entities involved in a corporate transaction, including a sale, acquisition or merger of all or a portion of our assets Entities or individuals to whom you have consented to disclosure Companies that use cookies and tracking technologies as described in Section 5 of this Statement, such as marketing and advertising partners
Commercial information, including purchasing preferences (e.g., purchasing history and trends) and transaction information (e.g., banking information)	Affiliates and subsidiaries within the Udesk group, including the parent and ultimate holding company, affiliates, subsidiaries, business units and other companies acquired by us that will become part of the Udesk group in the future Service providers, such as security and platform vendors Third-party partners, such as credit card providers Professional advisers, such as lawyers, accountants and auditors Entities involved in a corporate transaction, including a sale, acquisition or merger of all or a portion of our assets Entities or individuals to whom you have consented to disclosure
Web activity and electronic device information, such as your browsing history, search history, device information, and other information about your interactions with us and use of our products, services, emails, and other digital assets (whether passively browsing or actively engaging ).	Affiliates and subsidiaries within the Udesk group, including the parent and ultimate holding company, affiliates, subsidiaries, business units and other companies acquired by us that will become part of the Udesk group in the future Service providers, such as security and platform vendors Entities involved in a corporate transaction, including a sale, acquisition or merger of all or a portion of our assets Companies that use cookies and tracking technologies as described in Section 5 of this Statement, such as marketing and advertising partners
Geolocation information, such as your approximate location based on your IP address, mobile device location, or information you provide to us (such as city and state if you provide it through a web form). You can control the collection of this data through your device settings	Affiliates and subsidiaries within the Udesk group, including the parent and ultimate holding company, affiliates, subsidiaries, business units and other companies acquired by us that will become part of the Udesk group in the future Service providers, such as security and platform vendors Entities involved in a corporate transaction, including a sale, acquisition or merger of all or a portion of our assets Companies that use cookies and tracking technologies as described in Section 5 of this Statement, such as marketing and advertising partners
Audio, video and other recorded information (for example CCTV footage of our premises if you visit our offices; recordings of your interactions with our sales or marketing teams, for example for quality assurance or training purposes and to the extent permitted by law; or log records of chats or messages with customers	Affiliates and subsidiaries within the Udesk group, including the parent and ultimate holding company, affiliates, subsidiaries, business units and other companies acquired by us that will become part of the Udesk group in the future Service providers, such as security and platform vendors Entities involved in a corporate transaction, including a sale, acquisition or merger of all or a portion of our assets
The inference of EU, US, and California laws may lead to marketing that may cause you to react positively	Affiliates and subsidiaries within the Udesk group, including the parent and ultimate holding company, affiliates, subsidiaries, business units and other companies acquired by us that will become part of the Udesk group in the future Service providers, such as security and platform vendors Entities involved in a corporate transaction, including a sale, acquisition or merger of all or a portion of our assets
Sensitive personal information, such as proof of vaccination or race and ethnicity (optional) (collected where permitted by applicable law)	Affiliates and subsidiaries within the Udesk group, including the parent and ultimate holding company, affiliates, subsidiaries, business units and other companies acquired by us that will become part of the Udesk group in the future Service providers, such as security and platform vendors Entities involved in a corporate transaction, including a sale, acquisition or merger of all or a portion of our assets Entities or individuals to whom you have consented to disclosure

3：How we process personal data

• We may process your personal data for the following purposes:

Udesk will respect the rights of data subjects to the extent required by law, and you have the right to access, correct, update, and in certain circumstances request deletion of your personal data (subject to exceptions).

Udesk uses a limited number of third-party service providers to assist us in processing data for certain purposes. These third-party providers help support certain site features, perform database monitoring and other technical operations, assist with data transmission, and provide data storage services. These third parties may process or store personal data when providing services. Udesk has entered into contracts with these third parties to restrict their access, use, and disclosure of personal data to comply with our obligations under EU, US, UK, and Swiss law (including onward transfer clauses), and Udesk will remain liable if they fail to meet these obligations and we are responsible for the event giving rise to the damage.

4：Sources of Personal Data

• Information you provide directly to us , including when you register through our Digital Properties and communicate directly with us, visit our offices, or attend our events, marketing and tradeshows.

• Information collected from your employer, colleagues or friends , including information about representatives or other employees of our current, past and potential customers, suppliers, investors and business partners. We may also receive your information from friends as part of our referral services.

• Information collected automatically , including technical information about your interactions with our digital assets (such as IP address, browsing preferences and purchase history). Please see Section 5 below and our Cookie Statement for more information.

• Information from public sources , including information from public records and information you share in public forums, such as social media.

• Information from other third parties , including from third-party service and content providers, entities with whom we partner to sell or promote products and services, and social media networks (including widgets associated with such networks, such as the Facebook Like button).

We may combine information we receive from the various sources described in this statement, including third-party sources and public sources, and use or disclose it for the purposes described above.

5：Cookies and Other Tracking Technologies

• We use cookies and other tracking technologies and provide you with options to manage these settings as described in our Cookie Statement. Certain tracking technologies enable us to track your device activity over time, across devices, and across websites. While some browsers have set “Do Not Track” or “DNT” preferences, we currently do not accept such settings from web browsers.

6：Safety and Retention

• We implement appropriate security procedures and technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, disclosure, alteration or use.Your personal data will generally be retained for as long as necessary to fulfill the purpose for which we collected it. Once you and/or your company terminates your contractual relationship with us or otherwise ends your relationship with us, we may retain your personal data in our systems and records to ensure adequate performance of the surviving terms of the terminated contract or for other legitimate business purposes, such as to demonstrate our business practices and contractual obligations, to provide you with information about our products and services, or to comply with applicable legal, tax or accounting regulations. When we have no ongoing legitimate business need or legitimate legal basis to process your personal data, we will delete, anonymize and archive your personal data, and when processing conditions are not met (for example, because your personal data has been stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible. If you would like more information about the retention periods applicable to your specific situation, please contact us using the details provided in Section 9 below.

7：Children’s Privacy

• Our website and services are not directed to children under the age of 16, and we do not collect personal data directly from children. If you are the parent or guardian of a minor child and believe that child has disclosed online personal data to us, please contact us using the details provided in Section 9 below.

8：External links

• When you interact with us, you may encounter links to external websites or other online services, including links embedded in third-party advertisements. We do not control and are not responsible for the privacy and data collection policies of such third-party websites and services. For more information or if you have any questions about their practices, you should consult such third parties and their respective privacy statements.

9：Contact Information

• If you have any questions or complaints about this statement or Udesk's privacy policy, please contact us by email at: marketing@udeskglobal.com

10：Supplemental Terms for California Residents

• This section applies to the collection of certain personal data about California individuals in accordance with the California Consumer Privacy Act (“CCPA”) and does not apply to personal data of current and former employees, job applicants, agents, and contractors of Udesk.

• The following table provides the categories of personal data we sell, share, or disclose to third parties and the parties to whom we disclose it as defined in the California Privacy Rights Act.

Although we have not 'sold' or 'shared' personal data for profit in the past 12 months, we conduct routine operations on digital assets involving third parties, which may be considered 'sale' or 'sharing' as defined by California law. We do not intentionally sell or share the personal data of any minor under the age of 16. We do not collect or process 'sensitive personal information' as defined by California law to mark your characteristics. Udesk only uses sensitive personal information that is in accordance with restrictions on the collection of sensitive personal information.

Incentive Strategies: We may offer benefits or offers in exchange for your personal data, such as discounts or coupons to individuals who respond to surveys. In these surveys, we may collect personal data such as your name, contact information, preferences, experience, beliefs, opinions, and other responses to the survey.

Your data protection rights:

California residents have the following rights, limited to those set forth under California law.

• Right to Know . You have the right to request information about the categories of Personal Data we collected about you, the categories of sources from which we collected the Personal Data, the purposes for which the Personal Data was collected, the categories of third parties to whom we disclosed your Personal Data, and the purposes for which we disclosed your Personal Data (a 'Category Report'). You may also request information about the specific pieces of Personal Data we collected about you (a 'Specific Data Report').

• Right to erasure . You have the right to request that we delete the personal data we have collected from you.

• Right to rectification . You have the right to request that we correct inaccurate personal data we hold about you.

• Right to Opt Out of Sale or Sharing . We do not sell Personal Data to third parties in exchange for money. However, as we explain in Section 5, we share information with advertising partners and allow advertising partners to collect information from our digital properties. This exchange may be considered a “sale” or “sharing” under California law, and you have the right to opt out of such “sale” or “sharing” of Personal Data.

California residents may exercise their rights to know, delete, and correct by requesting through our web form or by emailing service@udeskglobal.com. We will not restrict your exercise of these rights in any manner that is prohibited by applicable law.

How to fully exercise your right to opt-out of sales or sharing : To fully exercise your right to opt-out of any “sales” or “sharing” of your information, you can take the following two steps:

Opt out of 'sell' or 'share' rights using a ticket submission.

Disable advertising cookies and other tracking technologies by clicking on the 'Do Not Sell My Shared Information' link in the footer of our website. This step must be performed on each device that logs in.

If you disable cookies, we will not be able to honor your request to 'not sell my shared information' which we collect online and disclose to third parties through cookies, personal information acquisition and other tracking technologies. If you clear your cookie cache, you will need to follow the above steps again. To the extent permitted by California law, we will honor 'not sell or share' opt-out preference signals sent in a format commonly used and recognized by businesses at the browser level (such as HTTP header fields or JavaScript objects).

Identity Verification: To comply with California data protection regulations, we need to obtain personal information to locate and verify your identity in our records, and the specific information collected depends on the nature of the request. In most cases, we will ask for information about you, which may include your name, email address, or other information. If you submit a right to know request, we may also ask you to provide a signed statement under penalty of perjury that you are who you say you are. In some cases, we may request additional information and/or use a third party to help verify your identity.

Authorized Agents: Authorized agents may exercise California data protection rights on behalf of California individuals, but we reserve the right to verify the identity of the individual directly as described above. Authorized agents must contact us via our ticket submission request and indicate that they are submitting the request as an agent. We may require the agent to provide a signed permission from you to demonstrate that they have the authority to act on your behalf. We may also require you to verify your own identity directly to us or to confirm directly to us that you have authorized the agent to submit the request

Processing Time: We will process 'opt-out of sale or sharing' requests within fifteen business days of receiving the request. We will respond to 'requests to delete' and 'requests to know' within forty-five days, and we will notify you if we need more time, and it may take up to ninety days to respond to your request.

11：Additional information for the European Economic Area, Switzerland and the United Kingdom

• The following clauses supplement this Statement and relate to our processing of personal data in the European Economic Area (i.e., EU Member States, Iceland, Liechtenstein and Norway), Switzerland and the United Kingdom. If there is any conflict or inconsistency between the rest of this Statement and the terms of Section 11, Section 11 shall apply and take precedence over the processing of personal data in the European Economic Area, Switzerland and the United Kingdom to the extent applicable.

• Data Controller : The Udesk entity with which you have a primary relationship (e.g., the entity with which you enter into a service contract; the entity that provides you with marketing materials and promotional information; or the primary entity in the region from which you access our website) is the data controller within the scope of this Statement. Usually, this controller is Udesk, unless we notify you otherwise.

• Legal Basis : Please refer to Section 3 for the legal basis we rely on to process, collect and use your personal data.

• Your data protection rights:

• Under applicable data protection laws, you may exercise the following rights in relation to your personal data:

• Right of access. You have the right to confirm with us whether or not we are processing your personal data and related information, and to obtain a copy of the personal data we are processing

• The right to data portability . You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit it to another data controller without hindrance. This right only exists if the processing is based on your consent or a contract and is carried out by automated means.

• Right to rectification . You have the right to have inaccurate personal data corrected and incomplete data completed

• Right to restrict processing . You can ask us to restrict the processing of your personal data in certain circumstances.

• Right to erasure . In certain circumstances, you can ask us to erase your personal data.

• Right to complain . You have the right to complain to a supervisory authority. Under the EU-US DPF, the UK’s extension to the EU-US DPF, and the Swiss-US DPF, we commit to cooperate with and comply with the advice of the panels established by the EU Data Protection Authorities (DPAs), the UK’s Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC), respectively, regarding unresolved complaints about our processing of personal data under the EU-US DPF, the UK’s extension to the EU-US DPF, and the Swiss-US DPF

• The right to refuse or withdraw consent . If we ask for your consent to process your personal data, you are free to refuse. If you have given your consent, you can withdraw it at any time without any adverse consequences. The lawfulness of any processing of your personal data that occurred before the withdrawal of consent will not be affected.

• Right not to be subject to automated decision-making . The types of automated decision-making referred to in Article 22(1) and (4) of the EU/UK General Data Protection Regulation (“GDPR”) will not be associated with your personal data. If this changes, we will inform you of the reasons and methods for such decision, its significance and possible consequences. You also have the right to request human intervention, express your point of view and contest the decision.You can exercise these rights by contacting us using the details provided in Section 9 above. Please note that we may decline to act on a request to exercise your data protection rights in certain circumstances, for example where providing access would infringe on the privacy rights of others or impact our legal obligations

• International Transfers of Personal Information Due to the global nature of our business, some of the recipients mentioned in Section 2 of this Statement may be located in countries outside the European Economic Area, Switzerland or the United Kingdom that do not provide an adequate level of data protection as defined by the data protection laws of the European Economic Area, Switzerland and the United Kingdom. Transfers within the Udesk Group or to third parties located in such third countries are carried out using valid data transfer mechanisms, such as the EU Standard Contractual Clauses and/or the UK Annex to such clauses, approved binding corporate rules, approved codes of conduct and certification mechanisms (based on permitted statutory exceptions) or any other valid data transfer mechanism issued or approved by the EEA, Swiss or UK authorities. If you would like more information on how we transfer personal data or, where available, a copy of the relevant data transfer mechanism, please contact us using the contact information in Section 9 above.

• Udesk.globle, Udesk.cn, Wofeng Technology complies with the EU-US Data Privacy Framework (EU-US DPF), the EU-US Data Privacy Framework EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) established by the U.S. Department of Commerce. If there is any conflict between the terms in this Privacy Policy and the EU-US Data Privacy Framework or the Swiss-US Data Privacy Framework, these guidelines and frameworks shall prevail.

• Data Protection: Our data protection officer can be contacted at: service@udeskglobal.com, Attention: Data Privacy Officer, Wofeng Technologies

12：Additional information for other regions

• Australia: The personal data collected, stored, used and/or processed by udesk Group described in this statement is collected, stored, used and/or processed in accordance with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles. If you are not satisfied with the way we handle your complaint or disagree with our proposed resolution, you can contact the Office of the Australian Information Commissioner (“ OAIC”) to lodge a complaint. Alternatively, you can ask us to forward the details of your complaint directly to the OAIC

• Brazil: The personal data collected, stored, used and/or processed by udesk Group as described in this Notice is collected, stored, used and/or processed in accordance with the General Data Protection Law (“LGPD”). Individuals who use or access our website or services expressly consent to the collection, use, storage and processing of their personal data for the purposes described in this Notice

• Canada: As defined in the Personal Information Protection and Electronic Documents Act (“PIPEDA”), udesk will collect, store, use and/or process personal data in accordance with its obligations under PIPEDA

• Japan: As described in this Notice, personal data collected, stored, used and/or processed by udesk Group is collected, stored, used and/or processed in accordance with the Japanese Act on the Protection of Personal Information (“APPI”).

• Nevada : We do not currently sell personal data under Nevada law. If you are a Nevada resident, you may still exercise your right to opt-out of sale under Nevada Revised Statutes Section 603A et seq. by sending us an email using the information above.

• New Zealand : As described in this Notice, personal data collected, stored, used and/or processed by Udesk Group is collected, stored, used and/or processed in accordance with the New Zealand Privacy Act 2020 and its 13 Information Privacy Principles (the “NZ IPPs”).

• Singapore: As described in this Notice, personal data collected, stored, used and/or processed by udesk Group is collected, stored, used and/or processed in accordance with udesk Group’s obligations under the Personal Data Protection Act 2012 (“PDPA”).

• United Kingdom: As described in this Privacy Statement, personal data collected, stored, used and/or processed by udesk Group is collected, stored, used and/or processed in accordance with udesk Group’s obligations under the UK Data Protection Act 2018 (as amended, replaced or superseded by the Data Protection, Privacy and Electronic Communications (Amendment etc) (Withdrawal from the European Union) Regulations 2019 (as amended, superseded or replaced)) (“UK GDPR”).

13：Chinese version control

• The non-Chinese translation of this statement is for reference only. If there is any conflict in the translation, the Chinese version shall prevail.

14：Udesk.cn Affiliates

• Beijing Wofeng Times Technology Co., Ltd. , Udesk.cn, Udesk.globle, Beijing Daorun Chuangde Technology Co., Ltd.