Privacy Policy

Privacy Policy Statement on the Use of this Website

Updated April 22, 2021

Midooc Group Limited (“Midooc” or “we”) adopts the following Privacy Policy in regards to the use of [www.midooc.com] and related investment web pages and services (the “Website”), but specifically excluding affiliated websites covered by independent privacy policies. This Privacy Policy applies to information collected through the Website and otherwise (for example, if you contact us directly). However, it does not cover any information—personal or not—that may be collected through other websites (including those of our affiliates) or in other venues. Your use of the Website and our services is subject to this Privacy Policy, which may be updated periodically to reflect changes in how we collect, use, and/or share information. Our Privacy Policy will reflect the date it was last updated. It is your responsibility to review this Privacy Policy for any changes, so please check this Privacy Policy each time you use our Website to ensure you are aware of any changes in our practices. Your continued use of the Website will signify your acceptance of any changes to our Privacy Policy.

Collection, Use, and Disclosure of Personally Identifiable and Non-Personally Identifiable Information

Collection

You may browse the Website without providing any personal information to us. However, if you request receipt of certain notifications and updates, we may collect personally identifiable information, or “PII,” which you voluntarily give us, including your name, telephone number, email address, postal address, and any other information which would allow someone to personally identify you. Certain non-personally identifiable information, or non-PII, which does not identify you, may also be collected when you use this Website, including the type of the Internet browser and operating system you use, other navigational clickstream data, etc.

Purpose and Use

Midooc uses the PII collected through this Website to provide you with public information regarding us and our services; to share news, updates and reports in response to your inquiries; for gaining an understanding of your needs; for performing statistical analysis or analyses of global website usage; for security and legal compliance; for direct marketing activities; for notifying you of any changes to this Website or our services; and for other services. We also reserve the right to make full use of information that is not PII.

Cookies

Web pages on this Website may contain cookies or related technology to facilitate your experience with this Website. Cookies are text files placed in your computer’s Internet browser to store your preferences. Cookies do not provide your email address or other PII. We may also collect information on which web pages you visited, the links or advertisements you click on and other actions you take while on our Website. Midooc only obtains this information when you choose to provide it to the Website. However, once you choose to provide Midooc with your PII by entering it into this Website, such data may be linked to data stored in the cookies. You may disable cookies in your browser. However, certain functionalities of this Website may not work if cookies are disabled.

Disclosure

We will not sell, share, or rent your information to others except to our staff and to trusted third parties and affiliates when we need to share the information to provide a product or service you have requested. We may also share your information to enable a trusted third party or affiliate to provide services to us, and then only to provide those services. We limit as commercially reasonable their access and use of your PII to that which is necessary to provide these services to us. Without limiting the above, we will share your PII with third parties only in the ways that are described in this Privacy Policy.

We may also be required by law to disclose your PII in response to a subpoena, court order, or a request for cooperation from law enforcement or other governmental agency globally. Your PII may also be shared when we believe disclosure is necessary for connection with efforts to investigate, prevent, or take other action regarding actual or suspected illegal activity or other wrongdoing, to protect and defend the rights, property or safety of Midooc, our users, or others. We will use commercially reasonable efforts to make you aware of the disclosure of your PII contrary to the terms set forth in this Privacy Policy (e.g., in the event of any material security breach).

Third Party Links and Policies

The Website may contain links to other websites owned and operated by third parties and/or affiliates. These third parties and affiliates may collect information from you. These affiliates and third parties and their computer servers may be located in the People’s Republic of China, the United States, or in other countries. We do not control and are not responsible for, the privacy and security practices of any third parties or affiliates. We strongly recommend that you review the privacy and security policies of all third parties and affiliates to determine how they handle information they may collect about you. To the extent their privacy policies conflict with this Privacy Policy, their privacy policies shall control.

Do Not Track Policy

The laws of some jurisdictions require that operators of website and online services disclose how they respond to a Do Not Track signal and whether other third parties may collect PII about an individual’s online activities over time and across third-party websites or online services.

Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common, global understanding of how to interpret Do Not Track signals, Midooc does not currently respond to Do Not Track signals.

Contact Us

Within the Midooc Group, Midooc Group Limited is responsible for the use of your personal information. If you have questions or comments about this Privacy Policy (including about the manner in which we or our service providers treat your personal information), you may contact us in the following ways:

a.If you are an Ivy user, please email us at we@midooc.com;

b.if you are a Midooc user and a resident of the European Economic Area, please email us at midooc@outlook.com;

c.otherwise, if you are a Midooc user, please email us at we@midooc.com.

You may also reach our Chief Privacy Officer by mailing us at our address at 406-2 Huasui Road, Tianhe District, Guangzhou 510623, Guangdong Province, China, Attn: Chief Privacy Officer or by emailing we@midooc.com, Attn: Chief Privacy Officer.

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