HK BioCode Company Limited (hereinafter referred to as “BioCode”) attaches great importance to and strictly protects users’ personal information. When you use various services provided by the BC Platform, the Company will collect, use and share your personal information in accordance with this Privacy Policy.

This Policy fully specifies all standards for the collection, storage, utilization, sharing and protection of your personal information, aiming to clearly explain our personal information processing rules to you. We recommend that you read this Policy in full to fully understand the ways to protect your privacy rights and interests. If you have any questions regarding this Policy, you may contact us through the official contact channels published on the BC Platform.

If you disagree with any provisions of this Privacy Policy, please immediately stop using all services of the BC Platform. Your use of any service on the BC Platform shall constitute your full understanding and acceptance of the stipulations herein, and your authorization for the Company to legally process and protect your personal information in accordance with this Policy.

Scope of Application

BioCode is committed to providing users with high-quality, considerate and personalized services to simplify your daily life through platform services. This Privacy Policy applies to all services launched by the BC Platform. Whether you browse through the BC Platform website or log in to the official client to use relevant services, you shall be bound by this Policy.

Special Note: This Policy does not apply to services independently provided by third parties. For example, when merchants on the Platform provide you with goods or services through BioCode channels, the personal information you actively submit to merchants is not protected by this Privacy Policy, and the information processing rules thereof shall be solely the responsibility of the relevant third party.

1. Definition of Professional Terms

BioCode: The operator of the BC Platform, namely HK BioCode Company Limited.

BC Platform: Covers BioCode’s official websites (domain names: ibreastguardian.com, hkbiocode.com), all official applications, websites and mobile/PC clients of BioCode.

BC Platform Services: All services provided by BioCode to users based on the Internet and big data technologies in all existing and future derivative service forms.

BC Platform Rules: All regulations, interpretations and announcements published and subsequently updated in all Platform rule columns, as well as management rules, implementation detailed rules, product process guidelines and official announcements released in forums, help centers and community sections of each Platform.

BioCode Network Rules: The management provisions specified in the exclusive rule column of BioCode Network, with the detailed content subject to the Platform’s published page.

Affiliated Companies: Collectively or individually refers to all operating entities under the BioCode Group other than BioCode itself.

Same User: Any natural person who registers multiple accounts with the same identity verification information, or is confirmed as the actual controller of multiple BioCode accounts through BioCode’s background verification, shall be deemed the same user.

2. Scope and Methods of Information Collection

We collect personal information primarily to optimize and customize platform services for users. The specific collection channels are divided into the following three categories:

2.1 Information You Actively Provide to Us

When you register for a BioCode account or fill in and submit data to use platform services, the information you actively provide includes: name, gender, date of birth, ID number, Chinese and English passport names, passport number, contact phone number, email address, mailing address, and supplementary information (including province, city, postal code, etc.).

2.2 Information Automatically Collected During Your Use of Services

To stably deliver and continuously optimize service experience, the system will automatically record behavioral data generated during your use of the Platform, including:

1. Browsing information: IP address, browser type, language settings, access time, device software and hardware parameters, browsing page records;
2. Mobile device information: If you download and use clients of BioCode and its affiliated companies or access mobile website services, the system will collect device model, device identifier, operating system, screen resolution, telecom operator and geographical location data;
3. Interactive supplementary information: Data provided during communication with our customer service team, questionnaire responses, and relevant information generated from your interaction with platform partners and affiliated enterprises;
4. Risk identification data: To prevent phishing websites, Trojan viruses and online fraud, the system will record your internet usage habits and commonly used software information, and retain high-risk URLs for account security risk assessment.

2.3 Information Legally Shared by Third Parties

For legitimate purposes including service optimization, joint service provision and online fraud prevention, BioCode’s affiliated enterprises and authorized partners may share your personal information with us in accordance with legal provisions, prior agreements with you or with your explicit consent.

Information Not Governed by This Privacy Policy

The following information is not included in the scope of personal information protection under this Policy:

1. Keywords entered when using the Platform’s search function;
2. Transaction data retained by the system (including bidding records, transaction information and evaluation details) when you do not enable the “Anonymous Purchase” and/or “Anonymous Evaluation” functions;
3. Credit rating records, illegal or rule-violating behavior records, and disposal measures taken by BioCode against you;
4. Enterprise business registration information and individual operator information publicly disclosed as required by laws and regulations.
5. Purposes of Personal Information Usage

All information collection is centered on delivering and upgrading platform services. We will only use your personal information for the following legitimate scenarios:

1. To deliver, maintain and optimize various platform services you use;
2. To recommend content that may interest you, including releasing product and service information and displaying personalized third-party promotional content. With your consent, we may share information with our partners for them to send you information about their products and services. You may unsubscribe from such commercial information at any time through the in-platform unsubscribe function;
3. Risk and violation management: To prevent, detect and investigate fraud, security threats, illegal acts, and violations of platform agreements and policies by using personal information, so as to protect the legitimate rights and interests of you, other users, BioCode and its group companies;
4. Cross-service integration and optimization: To integrate information generated from different service modules to create a more personalized user experience (including information sharing and disclosure required for expanding social interaction scenarios);
5. Other usage scenarios with your separate authorization and consent.
6. Personal Information Sharing Rules

The Company assumes strict confidentiality obligations for your personal information and will never sell or rent any user information for third-party marketing benefits. Your personal information may only be shared with third parties under the following statutory or agreed circumstances:

1. With your prior explicit consent or written authorization;
2. In compliance with mandatory laws and regulations or official law enforcement requirements from administrative and judicial authorities;
3. Internal sharing within BioCode Group’s affiliated enterprises;
4. Provision to authorized and trusted partners for processing, provided that such partners fully comply with this Privacy Policy and supporting confidentiality and security specifications, and process information solely in accordance with BioCode’s instructions;
5. If you are a valid intellectual property complainant, disclose necessary information at the request of the respondent to assist both parties in resolving rights disputes;
6. Disclosure necessary for completing transactions or mediating disputes: For example, if either party to a platform transaction fully or partially performs transaction obligations and applies for information disclosure, BioCode may appropriately provide key information such as the counterparty’s contact details to facilitate transaction performance or dispute settlement;
7. Disclosure to law enforcement authorities or relevant third parties when you violate local laws and regulations or breach BC Platform service agreements and management rules;
8. To safeguard the legitimate rights and interests of BioCode, its affiliated enterprises or platform users.
9. Rules for the Use of Cookies and Web Beacons

To improve your browsing convenience, when you visit BioCode websites or use platform services, the system will identify user identities through small data files to avoid repeated submission of registration information and assist in judging account security status. Such files include standard Cookies, Flash Cookies and browser/application local storage spaces, collectively referred to as “Cookies”.

Some core platform functions rely on Cookies to operate normally. You may adjust Cookie acceptance permissions or refuse BioCode Cookies through browser settings or plug-in tools. However, disabling Cookies may prevent some web pages from loading normally and restrict partial service functions.

Web pages contain small electronic images (1-pixel GIF images, also known as Web Beacons) for counting page visitors and reading local Cookie data. We collect your browsing behavior information through Web Beacons, including accessed URLs, source page addresses, page stay duration, browsing environment and display settings.

6. Information Storage Rules

All user information and data collected by BioCode are uniformly stored on exclusive servers of the Company and its affiliated enterprises. Relevant data may be transmitted to your country/region or the location of BioCode’s data center for local storage, access and display.

7. Personal Information Security Protection Mechanism

To fully protect your information security, we have established a complete and reasonable three-layer security protection system covering physical, electronic and management measures to prevent information leakage, damage and loss, including SSL encrypted transmission, encrypted storage technology and data center access control.

We implement strict permission management for internal employees and outsourced personnel who may access user information, including role-based data access permission division, confidentiality agreement signing and full operation log monitoring. BioCode will continuously upgrade security protection based on mature technologies to fully protect your information.

Your account is equipped with independent security protection functions, and you shall properly keep your account name and password. The Company prevents data loss, tampering and abuse through server off-site backup and irreversible password encryption. It is hereby clarified that no absolutely risk-free security system exists for network information transmission.

When conducting online transactions on the Platform, you may need to disclose personal information such as contact addresses to transaction counterparties. We recommend that you only disclose information when necessary. If you discover any leakage of your personal information (especially account and password leakage), please contact BioCode customer service immediately, and we will initiate emergency security disposal promptly.

8. Minor Information Protection

The Company attaches great importance to the privacy protection of minors. If you are a minor under the legal age of majority, please ask your guardian to fully read this Privacy Policy and obtain the guardian’s explicit consent before using our services or submitting personal information to us.