HiFleet Privacy Policy

Preamble：

Welcome to access to the products and services of HiFleet! HiFleet is aware of the importance of protection of the security and reliability of your user information. HiFleet is committed to maintaining your trust in us and abide by the following principles to protect your user information: the principle of consistent rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of minimum sufficiency, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. At the same time, we promise that we will take security protection measures according to the well-recognized security standards in the industry to protect your user information and privacy. Therefore, we hereby formulate the HiFleet privacy policy (hereinafter referred to as "this policy"). This policy applies to the information during your visiting and using HiFleet platform (including but not limited to HiFleet APP, website, Wechat official account, etc.).

Please read and understand this privacy policy carefully before using our products (or services).

This policy will help you understand the following items:
1. How does HiFleet collect and use your user information
2. How does HiFleet use cookies and similar technologies
3. How to share, transfer and publicly disclose your user information between HiFleet and the third party connected to HiFleet
4. How does HiFleet protect your personal information
5. How does HiFleet manage your personal information
6. Your Rights
7. Protection of Minors
8. Governing Law and Dispute Resolution
9. Amendments
10. Contact Us

1. How does HiFleet collect and use your user information

1.1 Before you click the 'agree' button in the privacy policy agreement, the APP and SDK will not obtain any personal information (including but not limited to IMEI, IMSI, MAC address, IP, Android_ID, installed APP information, hardware sequence table, phone number, location, running process information, etc.). The information we collect and use when you use HiFleet products or services We will only collect and use your user information subject to the business functions described in this policy. The purpose of collecting user information is for assisting you access to our products or services. You have the right to choose whether to provide this information or not, but in most cases, if not, we may not be able to provide you with corresponding services or better respond to your problems.

When you register your HiFleet account, we will collect your mobile phone number. This sensitive information is collected for identity verification with necessity. If you refuse to provide it, you will not be able to complete the registration. When you access to our services, we are allowed to collect your information including: device model, operating system, login IP address, access method, type and status of the network, network quality data, device accelerator (such as gravity sensing device), operation log, Service log information (such as the records of your search and viewing operations, service failure information, referral website and other information), which is the basic information that must be collected before providing services. According to your authorization, we may access to the location, mobile operating system, model and version, international mobile device identification code, unique device identification code, machine MAC address, mobile task list, device SSID and photo album access permission.

In particular, access to the above information is a necessary rather than sufficient condition for us. Our access to a specific sensitive authority does not necessarily mean that we will collect your relevant information; Even if we have obtained sensitive permission, we will only collect your relevant information when necessary and in accordance with this privacy policy.

The above information provided by you will continue to authorize us to use it during your use of our service. When you stop using the service, we will stop using and delete the above information.

We guarantee that we will de identify or anonymize the collected user information according to law. Information alone or in combination with other information that cannot identify the personal identity as natural persons does not belong to personal information in the legal sense. If we combine non personal information to identify your personal identity, or use non-personal with your personal information, we will regard and protect such information as your personal information in accordance with this Privacy Policy during the period of combination.

In order to better promote and improve our technology and services, or due to changes of business strategies, when the collection, use and processing of user information required by our products or services exceed the above scope, or when we want to use the collected user information for other purposes not specified in this privacy policy, or when we want to use the information collected for specific purposes, We will notify you within a reasonable period after obtaining user information or before processing user information and obtain your authorization and consent.

1.2 How is information used

I. When you log in to HiFleet, we will get your mobile phone number and email address, and send SMS to your mobile phone or email to your email address. When you forget your account password, we will get your account information and send verification SMS or email to help you to recover. When you purchase the historical track data of the ship, we will get your information, mobile phone number and other data. After the purchase, we will send a text message to your mobile phone.

II. Obtain user information and generate self-determined regional warning. Users can put their managed ships into groups according to their needs, customize the monitoring conditions, alarm and reminder judgment conditions for grouped ships, and the settings of customized conditions can be operated on the chart, which is displayed visually and convenient for users. Alarm and reminder is functional in terms of setting alarm and reminder trigger conditions. When the trigger conditions are met, alarm and reminder will be generated.

III. When you inquiry HiFleet customer service, HiFleet will contact with you via your wechat account. If you don't have WeChat account, you can get customer service consultation with HiFleet through online service, email, telephone calling or Tencent QQ group.

IV. When you use the hiFleet platform to upload or generate your planned routes, the route file selection will pop up. You can upload the planned routes manually or send the planned routes to a designated email of hiFleet. The platform will read the files on your computer and calculate the route by using the principles of navigation mathematics and combined with the planned routes, to compute and estimate the ship’s track. Or in the case of given ETA, the platform can calculate and estimate the ship speed in combination with the planned route, so as to provide reference for ship navigation decision-making.

V. When you use certain value-added functions and services of our platform, you must provide your personal contact information and company information to confirm the identity of the user and provide the corresponding services. For example, the ship valuation function needs to improve personal and company information so that we can contact you to open more professional services. The certification service provider function is used to display your company's products and services on our platform. Therefore, you must provide complete company information, including name, company type, service type, service port, services provided, address, contact person, mobile phone number, e-mail, etc., and a brief description to be publicly displayed after confirming the user's identity for users in need of contact information. In addition, if you need to apply for an invoice online, you must provide the contact information of the person in charge of the company, taxpayer identification code, company address, account opening bank and account number, which are mainly used to sign a contract and issue a VAT invoice. The above information is sensitive. If you refuse to provide, you will not be able to use the corresponding functions, but it will not affect your use of other functions of HiFleet.

VI. When you use the fleet's online HiFleet to receive message notifications related to functions, your personal information will be obtained through the Aurora Push SDK, which is detailed as follows: Third party entity: Shenzhen Hexun Huagu Information Technology Co., Ltd SDK purpose: To provide information push services for APP users Type of personal information collection: Device parameters and system information (device type, device model, system version, and related hardware information): used to identify the user's device type, device model, system version, etc., to ensure accurate message distribution; Device identifiers (IMEI, IDFA, Android ID, GID, MAC, OAID, VAID, AAID, IMSI, MEID, UAID, SN, ICCID, SIM information): used to identify unique users, ensure accurate delivery of push and accurate statistics of push information; Network information (IP address, WiFi information, base station information, DNS address, DHCP address, SSID, BSSID) and location information (latitude and longitude): used to optimize network connection requests between SDK and Aurora servers, ensure service stability and continuity, and achieve regional push function; Application list information (application crash information, notification switch status, APP application list and active status, APP application page information, APP function event related information): When a device has multiple APP push links active at the same time, we use merge link technology to randomly merge into a link to achieve the goal of saving electricity and traffic for users. Data processing methods: through de identification, encrypted transmission, and other security methods.

VII. In order to better operate and improve our products and services, or due to changes in business strategies, when the collection, use and processing of user information required by our products or services exceed the above scope, or when we want to use the collected user information for other purposes not specified in this Privacy Policy, or when we want to use the collected information for specific purposes for other purposes, we will notify you within a reasonable period after obtaining user information or before processing user information and obtaining your authorization and consent.

1.3 Exceptions with authorization and consent

According to the requirements of applicable laws, regulations, and standards, we may collect and use your personal information without seeking your consent if:
I. The information is directly related to national security or national defense;
II. The information is directly related to public safety, public health, or major public interests;
III. The information is directly related to a criminal investigation, prosecution, trial, or execution of judicial decisions;
IV. The collection and use of your information are necessary to protect your or other individuals’ legitimate rights and interests, life safety, and property safety and your authorization for collecting such information cannot be obtained for some reason;
V. The information has been made public by yourself;
VI. The information has been made publicly available in legitimate news coverage, governmental announcements, and other public channels;
VII. The information is required for entering into and/or fulfilling a contract to which you are either of the parties;
VIII. The information is required for ensuring the safe and stable operation of the provided products or services, such as identifying and/or fixing of such products or services;
IX. The information is necessary for the legitimate news coverage of the personal information controller which is a news agency;
X. The information is necessary for a statistical or academic research in the public interest that is conducted by the personal information controller which is a research institute, and de-identification has been performed on the information contained in the published research results or description.
XI.Other circumstances provided for by laws and regulations.

The following are the business functions that correspond to HiFleet map permissions, the purpose of calling permissions, and the requested information before calling permissions:

Permission description	Business function	Call purpose	Collect personal information	Whether to ask
Location	Location service and location marking	Get the user's current position, which is used to locate and label the position.	User location	Ask about the first installation
Camera / photo	Upload ship pictures	Realize photo upload, mobile photo album upload and other functional requirements	Ship picture	Call camera function query
System version	Operating system version, Baidu statistics	Check the application version number and application compatibility	Equipment identification number	Automatic acquisition without asking

2. How does HiFleet use cookies and similar technologies?

2.1 Cookies

To ensure the normal operation of the website, we will store a small data file named cookie on your computer or mobile device. Cookies usually contain identifiers, site names, numbers and characters. With the help of cookies, websites can store your access preference data.

We will not use cookies for any purpose other than those stated in this policy. You can manage or delete cookies according to your preferences. You can delete all cookies saved on your computer. Most web browsers have the function of blocking cookies.

2.2 Website beacons and pixel tags

In addition to cookies, we will also use other similar technologies such as website beacons and pixel tags on the website. For example, the email we send you may contain a click URL that links to the content of our website.

If you click on this link, we will track this click to help us understand your product or service preferences and improve customer service. A website beacon is usually a transparent image embedded in a website or email. With the help of pixel tags in e-mail, we can know whether the e-mail is opened or not. If you don't want your activities tracked in this way, you can unsubscribe from our mailing list at any time.

2.3 Do Not Track

Many web browsers are equipped with a Do Not Track feature, which can publish Do Not Track requests to websites. At present, the major Internet standards organizations have not established relevant policies to specify how websites should respond to such requests. However, if your browser does not track, all our websites will respect your choice.

3. How to share, transfer and disclose your user information between HiFleet and third parties connected to HiFleet

3.1 Access by third-party service providers

HiFleet may cooperate with third-parties to provide relevant services and share information.

HiFleet application embedded in third-party SDK Description:

SDK name	SDK category	Business function	Whether to obtain personal information	Call purpose
WeChat development kit	Third party login	Third party login sharing	No	User sharing sent to WeChat
Baidu mobile statistics	Data analysis, cloud platform, auxiliary operation	Traffic and access statistics	No	Monitor platform traffic
Jpush SDK	Message push service	Push message notifications	Yes	Ensure accurate delivery of push messages

3.2 Share of Data

HiFleet may share, transfer, or disclose your personal information as required by applicable laws, regulations, and standards without your consent, if:
I. We may share your user information with others after obtaining your explicit consent.
II. We may share your user information in accordance with laws and regulations or mandatory requirements of relevant government departments.
III. Share with our affiliates: Your user information may be shared with our affiliates. Only the necessary user data will be shared, which is subject to the purposes outlined in this Privacy Policy. It will ask again for your consent and authorization if the associated company wishes to change the purpose of processing user information.
IV. Share with Authorized Partners: Some of our services will be provided by authorized partners only for the purposes set out in this Policy. We may share some of your user information with our partners to provide better customer service and user experience. We will only share your user information for lawful, necessary, specific and clear purposes, and only share the user information necessary to provide services. In order to better operate and improve technology and services, you agree that we and authorized partners may use the collected information for other services and purposes on the premise of complying with relevant laws and regulations.
- Specific authorized partners are listed below. We recommend that you read this third party's privacy policy:
- Satellite AIS data and dynamic AIS data (ship-based) are licensed by Spire.
- AVCS online chart service is licensed by UKHO.
- CMAP chart service is licensed by i4 Insight.
- The Guide to Port Entry is authorized by Findaport.
- Tide prediction data is licensed by the National Marine Information Center of China.
- The ship valuation is licensed by Weselmann.

3.3 Transfer of Data

HiFleet will not transfer any of the following information to your online users, organizations and companies:
I. Transfer with explicit consent: after obtaining your explicit consent, we will transfer your user information to other parties;
II. In the event of a merger, acquisition or bankruptcy liquidation, if the transfer of user information is involved, we will require the new company and organization holding your user information to continue to be bound by this Privacy Policy, otherwise we will require the company and organization to request your authorization and consent again.

3.4 Disclosure of Data

We will only publicly disclose your user information in the following circumstances:
I. With your express consent;
II. Legal Disclosure: We may publicly disclose your user information in accordance with the mandatory requirements of laws, legal procedures, litigation or government authorities.

3.5 Exceptions to prior authorization and consent for information sharing, transfer and public disclosure

Please understand that according to laws, regulations and relevant national standards, we do not need your authorization to share, transfer and publicly disclose your user information under the following circumstances:
I. The information is directly related to national security or national defense;
II. The information is directly related to public safety, public health, or major public interests;
III. The information is directly related to a criminal investigation, prosecution, trial, or execution of judicial decisions;
IV. The collection and use of your information are necessary to protect your or other individuals’ legitimate rights and interests, life safety, and property safety and your authorization for collecting such information cannot be obtained for some reason;
V. The information has been made public by yourself;
VI. The information has been made publicly available in legitimate news coverage, governmental announcements, and other public channels;

4. How does HiFleet protect your personal information

4.1 We have used industry-standard security measures to protect user information provided by you from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and feasible measures to protect your user information. For example, it is protected by SSL encryption when exchanging data between your browser and the "service"; We also provide secure HTTPS browsing for the website; We will use encryption technology to ensure the confidentiality of data; We will use trusted protection mechanisms to prevent malicious attacks on data; We will deploy access control mechanisms to ensure that only authorized personnel can access user information; and We will conduct security and privacy training courses to increase employees' awareness of the importance of protecting user information.

4.2 During the period when you use HiFleet products or services, we will continue to save them for you, unless you independently request to delete and cancel your account. When our products and services are shut down or changed, we will notify you in the form of push, announcement, etc., and delete your personal information or anonymity within a reasonable period of time.

4.3 When using HiFleet products and services, your personal information will be stored in China. If you need to transfer across the border or store the information abroad, we will deal with it in accordance with relevant laws and regulations.

4.4 We will take all reasonable and feasible steps to ensure that irrelevant user information is not collected. We will only retain your user information for the period required to achieve the purpose stated in this policy, unless the retention period needs to be extended or permitted by law.

4.5 The Internet is not an absolutely secure environment, and email, instant messaging, and communication with other users are not encrypted. We strongly recommend that you do not send user information in this way.

4.6 The Internet is not 100% secure. HiFleet will do its best to ensure the security of any information you send us. Even if we have made great efforts and taken all reasonable and necessary measures, it may still be impossible to prevent your user information from being illegally accessed, illegally stolen, illegally tampered with or destroyed, resulting in damage to your legitimate rights and interests. Please understand the above risks of the information network and voluntarily assume them.

4.7 After an unfortunate user information security incident occurs, we will promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce risks, and the remedial measures for you in accordance with the requirements of laws and regulations. We will promptly inform you of the relevant information of the event by mail, letter, telephone, push notification, etc. When it is difficult to inform the subject of user information one by one, we will find a reasonable and effective way to publish the announcement. At the same time, we will also actively report the disposition of user information security incidents in accordance with the requirements of regulatory authorities.

5. How does HiFleet manage your personal information

5.1 Manage your personal information

Managing your personal information refers to the user's personal information collected and stored by HiFleet, including the user's mobile phone number, username, registration area, company name, contact information, contact address, etc. HiFleet respects your attention to personal information and provides you with methods to manage your personal information. You have the right to view, correct, manage and delete your information and protect your privacy and security.

5.2 Manage shared information

HiFleet would like to thank you for providing us with data updates, problem feedback and contributions to various ship pictures and content. You can use HiFleet to report ship location errors, add new tags, report ship information errors, share ship pictures, upload routes, share port information, company information, etc., to help more users enjoy more accurate information.

When you publicly share any information in HiFleet's products or services, anyone may view or access such information when using or not using HiFleet's products or services, such as photos you upload to HiFleet, ship location, Chinese ship name and other data. Please try to avoid sensitive personal information and make prudent decisions when sharing information. Once this shared data is reviewed by HiFleet, HiFleet shall have the final interpretation right to this data.

6. Your Rights

In accordance with the relevant laws, regulations and standards of China and the common practices of other countries and regions, we guarantee that you exercise the following rights to your user information:

6.1 Access to personal information

You have the right to access your personal information, except for exceptions provided by laws and regulations. If you want to exercise your right to access your data, you can access it yourself by clicking on the avatar in the upper right corner of the web page or app – enter the Personal Center to access your personal information.

If you cannot access this user information through the above link, you can contact our WeChat customer service at any time or send an email to support@hifleet.com. We will respond to your visit request within 3 days.

For other user information generated in the process of using our products or services, we will provide it to you as long as we do not need too much investment. If you wish to exercise data access, please email support@hifleet.com.

6.2 Change of personal information

When you find that there are errors in your user information processed by us, you have the right to ask us to make corrections. You can apply for correction through the methods listed in "6.1 Access to personal information". If you cannot correct this user information through the above methods, you can contact our online customer service or WeChat contacts at any time, or send an email to support@hifleet.com and we will respond to your request for correction within 3 days.

6.3 Delete personal information

In the case of your user's request to delete the information, you can make the following request to us:
I. If our handling of user information violates laws and regulations;
II. If we collect and use your user information without your consent;
III. If our handling of user information violates the agreement with you;
IV. If you no longer use our products or services, or cancel your account;
V. If we no longer provide you with products or services.

We will evaluate your request for deletion. If the relevant regulations are met, we will take appropriate steps to address them. When you make a deletion request for us, we may require you to authenticate to ensure the security of your account. After you delete the information from our service, we may not delete the corresponding information from the backup system immediately because of applicable laws and security technology. We will store your information securely until the backup can be cleared or anonymous.

6.4 Withdraw authorizations

Each business function requires some basic user information to complete (see "Part I" of this Policy). For the collection and use of user information, you may give or withdraw your authorization and consent at any time.

When you withdraw your consent, we will no longer process the corresponding user information. At the same time, please note that revoking your consent may have some consequences. For example, we may not be able to continue to provide you with relevant services or specific functions, but your decision to withdraw your consent will not affect the processing of user information previously performed based on your authorization.

6.5 Automatic decision of constraint information system

In some business functions, we may only make decisions based on automated non-manual decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will also provide appropriate remedies.

6.6 Respond to your above request

For security purposes, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

For your reasonable request, we will charge a certain fee according to the situation. We may refuse requests that are unreasonably repeated, require too many technical means (e.g. the need to develop new systems or fundamentally change existing practices), pose a risk to the legitimate rights and interests of others, or are highly impractical. Please also understand that we may not be able to respond to some of your requests due to security considerations, requirements of relevant laws and regulations or technical restrictions, such as the following situations:
I. The requests is related to the user information controller's performance of obligations stipulated by laws and regulations;
II. The requests is directly related to national security or national defense;
III. The requests is directly related to public safety, public health, or major public interests;
IV. The requests is directly related to a criminal investigation, prosecution, trial, or execution of judicial decisions;
V. The user information controller has sufficient evidence to show that the user information subject has subjective malice or abuse of rights;
VI. It is difficult to obtain my consent for the purpose of safeguarding the life, property, and other significant legitimate rights and interests of the user information subject or other individuals;
VII. The legitimate rights and interests of the user information subject or other persons and organizations will be seriously harmed by responding to the user information subject's request;
VIII. Requests involving trade secrets

6.7 Cancel your account

You have the right to control your access time. If you do not need to continue accessing, you can log out by clicking on the webpage or app's top right avatar - enter the personal center, click on the "Logout" button to end your current visit.

7. Protection of Minors

We place great value on the protection of minors' personal information. We will protect and handle minors' information in accordance with relevant national laws and regulations.

For the collection of minor user information with the consent of parents or guardians, we will only store, use or publicly disclose this information when permitted by law, expressly agreed by parents or guardians or necessary to protect minors, otherwise we will try to delete relevant data as soon as possible.

Given the limitations of existing technology and business models, it is difficult for us to actively identify the personal information of minors. If you find that we have collected the personal information of minors without our knowledge or the prior consent of a verifiable guardian, you can contact us in time, and we will try to delete it in time after discovery. If we find the above situation ourselves, we will remove it in time, except for what the law requires us to keep.

8. Governing Law and Dispute Resolution

8.1 Governing law

The implementation, interpretation and dispute settlement of this policy shall be governed by the laws of the People's Republic of China without regard to any conflict of laws.

8.2 Dispute resolution

In the event of any dispute between the parties concerning the content of this Agreement or its implementation, both parties shall endeavour to settle it through friendly negotiation. If negotiations fail, both parties agree to refer the matter to the China Maritime Arbitration Commission for arbitration and accept its arbitration rules. The arbitration award is final, and both parties will execute the arbitration award unconditionally.

9. Amendments

This Policy may be updated, revised, amended, or modified as appropriate from time to time. Without your express consent, we will not reduce your rights under this Privacy Policy. We will post any changes to this policy on this page.

For major changes, we will also provide more important notice. Major changes to this Policy include, but are not limited to:
I. Significant changes have taken place in our service model. Such as the purpose of processing user information, the type of user information processed, the use of user information, etc. ;
II. Significant changes have taken place in our ownership structure and organizational structure. Such as owner change due to business adjustment, bankruptcy and M&A;
III. The main objects of sharing, transferring or publicly disclosing user information have changed;
IV. Your right to participate in the processing of user information and the way you exercise it has changed significantly;
V. We are responsible for dealing with changes in the responsible department, contact information and complaint channels for user information security;
VI. When the user information security impact assessment report indicates that there is a high risk.

We will also archive the old version of this policy for your reference.

10. Contact Us

If you have any questions, comments or suggestions regarding HiFleet's privacy policy, please contact us at:

Name: Shanghai Maili Marine Technology Co., Ltd.

address: No. 403, Building 16, Lane 218, Haiji 6th Road, Nanhui New Town, Pudong New Area, Shanghai

E-mail: support@hifleet.com

Tel: +86 400-963-6899

In the event a difference arises regarding the meaning herein, the original Chinese version shall prevail.