Privacy Policy

Dear Moore Threads Users:

Moore Threads Technology Co., Ltd. and/or its affiliated entities (referred to as "Moore Threads" or "we") hereby inform individuals utilizing our products and /or services (referred to as "users" or "you") of the scope of your personal information we may collect, the purposes for its collection, the methods of using such information and the measures we have taken to protect the security of your personal information, when we provide Moore Threads’ products and/or services for you. Based on your consent or authorization, your necessary personal information may be provided to third-party partners who provide their products and/or services for you through our products and/or services, and in such instances, please be aware that their respective privacy policies equally apply and must be strictly observed.

In addition, this policy applies exclusively to products or services provided by Moore Threads, but not to any products or services provided by any third party. This policy is also independent of any personal information protection policies or similar legal documents that may be presented or provided to you by our clients or any third party.

Before using Moore Threads’ products or services, please read and understand this policy carefully, and confirm that you have fully understand and agree. By using Moore Threads’ products or services, you acknowledge and accept the entire content of this policy (including its updated versions) and agree to Moore Thread collecting, using, and sharing your information as described herein. If you disagree with any part of this policy, you should immediately cease using Moore Threads’ products or services. For any question, comment, or suggestion regarding this policy, please contact us through the provided contact information. We reserve the right to amend this policy from time to time. Once the version has been updated, we will display the updated content via push notifications, pop-ups, or alternative communication channels.

Unless otherwise defined, the terms used in this policy have the same meanings as those in relevant Chinese laws, regulations, and national standards, including “Cyber Security Law of the People's Republic of China”, “Civil Code of the People's Republic of China” and GB/T35273-2020 “Information Security Technology Personal Information Security Specification”.

This Privacy Policy includes:

1. 1. How we collect and use your personal information
2. 2. How we store and protect your personal information
3. 3. How we use cookies and similar technologies
4. 4. How we share, transfer, and publicly disclose your personal information
5. 5. How we process minors' personal information
6. 6. How you can manage your personal information
7. 7. Changes and revisions to this policy
8. 8. How to contact us
9. 9. Dispute resolution
10. 10. Definitions
11. 11. Effectiveness of this policy

1. How We Collect and Use Your Personal Information

We adhere to the principles of legality, legitimacy, and necessity to collect and use your personal information provided by you voluntarily，arising from the use of products and/or services，and obtained by any third party for the purposes stated in this policy. If your personal information is to be used for purposes not specified in this policy, or information collected for specific purposes is to be used for other ones, we will inform you in a reasonable manner and obtain your consent again beforehand.

1.1 Situations where your consent for collecting and using your personal information is required

Our products/services contain certain functionalities, such as submitting resumes, joining developer communities, or engaging in business collaborations. To realize the above functions, we may collect and utilize your specific personal information. Without such information, we cannot provide the corresponding services for you. These functionalities include:

(1) Developer Account Registration, Login, and Authentication

When you register and log in to a developer account of Moore Threads for learning more development information and downloading resources, you must provide your email address or phone number and passwordat minimum. Upon successful registration and agreeing to this policy, you can use your Moore Threads account to log in, browse the developer community section and download resources. If you opt not to provide the necessary information for these basic business functions, we will be unable to provide you with download services, and we will not collect your personal information mentioned above.

(2) Information Browsing

You can browse our basic content without registration. To display products or services effectively, we will collect information such as your screen width for layout adaptation, and IP address, operating system, and browser type for security verification. To enhance your experience and tailor our content to your needs, we will also collect your browsing history.

(3) Resume Submission

If you opt to apply for our position by submitting your resume via our website, you will be transferred to a third-party technical service platform collaborating with Moore Threads. By agreeing to the privacy policy of the third-party platform and registering an account, you will authorize the third-party service platform and Moore Threads to jointly collect and store your personal information on your submitted resume, including name, date of birth, gender, place of origin, education, work experience, and contact details. Moore Threads will use the aforementioned information to communicate with you regarding employment opportunities. Failure of providing the necessary information will prevent us from contacting you for communications of potential job opportunities.

(4) Event Participation

When you apply for participation in the "Innovators Alliance" or "PES Alliance" to engage in business cooperation with us or sign up for other activities, we need to collect detailed information such as your company name, industry, city, contact email, and specific business needsto understand your requirements, so as to quickly contact you, handle and respond to your or your company's questions and suggestions. With your consent, such information may also be used to provide you with details of products and services that you or your company may be interested in.Inability or refusal to provide required information for enrollment and participation may hinder your ability to enroll or partake in the activity.

(5) Download Requests

When requesting to download drivers or software, we need to collect information such as your company name, contact email and the description of the product you're developingto understand your specific needs to promptly contact you and provide feedback with the download link. Without the necessary information for downloading drivers or software, we will be unable to provide the download services for you.

(6) User Services

For handling complaints or inquiries to Moore Thread, we may need to collect personal information such as your name, phone number, email, and other contact details, as well as save your communication/call records and content. Without such information, we may not be able to provide you with timely feedback on your complaints, appeals, or inquiries.

1.2 Exceptions to Obtaining Authorization and Consent

According to applicable laws, regulations and national standards, Moore Threads can legally collect and use certain necessary personal information without obtaining your consent in the following situations:

• 1) Directly related to national security or defense.
• 2) Directly related to public safety, public health, or significant public interests.
• 3) Directly related to criminal investigations, prosecutions, trials, and judgment enforcement.
• 4) Necessary to protect your or other individuals' life, property and other major legitimate rights and interests, where obtaining your consent or authorization is difficult.
• 5) Personal information concerned is publicly disclosed by you.
• 6) Collecting personal information from legally disclosed sources, such as lawful news reports and public government disclosures.
• 7) Necessary for contract execution and fulfillment as requested by you.
• 8) Essential for maintaining the secure and stable operation of the provided services, such as identifying and addressing product or service malfunctions.
• 9) Necessary for conducting public interest-oriented statistical or academic research; provided that the personal information contained in the results shall be de-identified and processed when provided externally.
• 10) Other circumstances as stipulated by laws and regulations.

If we intend to use information for any purpose not specified in this policy, we will obtain your consent beforehand. Similarly, if we plan to use information collected for a specific purpose for other purpose, we will obtain your consent in advance.

We will use, store, disclose and protect your information according to this policy and related user agreements. You may opt out of providing certain information, but this may prevent you from using specific services or functionalities or achieving the intended outcomes of the services.

If we cease operations of Moore Threads’ products / services, we will immediately stop collecting your personal information, notify you individually or through public announcements and delete or anonymize your personal information without contravening the storage period requirements specified by relevant laws and regulations.

1.3 If you have any doubt or need further information regarding the legal basis for our collection and use of your personal information, please contact us through the contact information provided in the "How to Contact Us" section.

2. How We Store and Protect Your Personal Information

2.1 Storage of Your Personal Information

(1) Storage Period

We set the storage period for personal information lawfully and reasonably, according to the national laws, regulations, and norms related to personal information storage, retaining your personal information only as long as necessary for the purpose of providing services. For personal information that exceeds its retention period, we will promptly delete or anonymize it.

In cases of business failure or other reasons leading to cessation of operations, we will immediately stop collecting and delete your personal information. This situation will be announced on our website or communicated to users individually through in-site messages, emails, or other reasonable means.

(2) Storage Location

Your personal information is stored within the territory of the People's Republic of China. If the cross-border transfer of personal information becomes necessary for fulfilling the purposes of our products or services, or as required by laws and regulations, we will lawfully obtain your consent and carry out such data transfers in compliance with legal requirements, ensuring the security of your personal information during the process.

2.2 Protection of Information

Your personal information's security is of utmost importance to us. We strictly adhere to relevant legal regulations and adopt recognized reasonable and feasible measures to protect your personal information from unauthorized access, disclosure, use and alteration, and damage or loss.

(1) Data Security Measures

We will take security measures that comply with industry standards, including using standard toolchains and mature design, development, testing, release, monitoring, and maintenance processes to protect your personal information comprehensively, prevent unauthorized access, use, and modification, and thus avoid data damage or loss. For instance, Moore Threads uses HTTPS to ensure the secure transmission of hypertext information, encryption technology to encrypt and protect personal data, Web Application Firewall to guard against cyber-attacks, SSO for secure user login, RBAC to authorize users’ access to network resource, VPC for logical isolation in cloud services, and containerization schemes for logical isolation within clusters. We also safeguard access to sensitive data through means such as authorizing access to sensitive fields, hiding sensitive fields, and hiding sensitive content, conduct code quality self-inspections for security, scan container images for vulnerabilities, monitor API access in real-time to prevent abnormal activities, and customize, grade, and manage access permissions to accommodate various user needs on the platform.

Despite these robust measures and compliance with legal standards, due to technical limitations and potential malicious acts in the internet sector, it is impossible to always guarantee 100% information security even if we try our best to strengthen the security measures. We will spare no effort to ensure the security of the personal information you provide to us.

(2) Handling of Security Incidents

We strive to ensure the security of any information you send us, however, please understand that due to the technical limitations and various malicious means may exist in the Internet industry, it is impossible to guarantee 100% information security. You should be aware that the systems and communication networks used to access our services may have problems due to factors beyond our control. We have developed appropriate early warning systems and emergency plans to prevent security incidents. In the event of a personal information security incident, we will inform you promptly in accordance with the requirements of laws and regulations about the basic situations and possible impact of the security incident, the measures we have taken or will take, and suggestions for self-protection and risk reduction that you can adopt, and the remedies available to you. We will immediately initiate our emergency response plan with the aim of minimizing losses. The incident will be communicated through phone calls, push notifications or other means. When individual notification is not feasible, we will issue a public announcement in a reasonable and effective manner. Moreover, we will proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities and cooperate closely with government agencies.

3. How We Use Cookies and Similar Technologies

When you utilize our services, we may store small data files known as cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. We utilize this information to determine whether registered users have logged in, or whether they have encountered theft, fraud, nior illegal activities. Such technologies also streamline your experience by saving you from repeatedly filling in your personal information, enhance the service/product quality and optimize user experience. Cookies will not be used for any purpose other than purposes stated in this policy.

If you prefer not to have your personal information stored in cookies, you can configure your browser and choose to disable cookies. Be aware that disabling cookies may affect your access to Moore Threads or you may not be able to fully obtain the products/services provided by Moore Threads.

You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer, as most web browsers have the function of blocking cookies.

4. How We Share, Transfer and Publicly Disclose Your Personal Information

4.1 Sharing of Information

Moore Threads will share your personal information with third parties except in the following circumstances:

• 1) When obtained your explicit consent or authorization in advance.
• 2) When provided in accordance with the mandatory requirements of laws, regulations, administrative, and judicial authorities.
• 3) To the extent permitted by laws and regulations, when necessary to protect Moore Thread, Moore Thread's affiliates or partners, you, other Moore Thread users, or the public's interests, property, or safety from damage.
• 4) Only by sharing your personal information could we achieve the core function of our products and / or services or provide the service you have requested.
• 5) When handled disputes or conflicts between you and others upon your request.
• 6) Provided in compliance with relevant agreements or other legal documents executed with you.
• 7) Used for the purposes of academic research.
• 8) Used based on social public interest, and public health emergencies that comply with laws and regulations.
• 9) Some specific services will be provided by Moore Threads and authorized partners, and your information may be shared with relevant third parties to ensure the smooth completion of the services provided to you. Moore Threads will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share the personal information necessary to provide products and/or services. In this case, Moore Threads will inform you in advance, obtain your explicit consent and provide you with relevant products and/or services after you fully agree to the third party's privacy policy and data security protection specifications. At the same time, we will sign a strict confidentiality agreement/data processing agreement with our authorized partners or add necessary confidentiality clauses/data processing clauses to the cooperation agreement between the two parties, requiring them to follow our instructions, this policy and any other relevant confidentiality and security measures to process your personal information. Authorized partners have no right to use shared personal information for any other purpose.

Our partners include the following types:

Providers of technical services. We may provide your personal information to third parties that support our functions, including suppliers that provide us with infrastructure technology services, data analysis services, and data processing services.

4.2 Transfer of Information

We will not transfer your personal information to any other company, organization or individual unless we obtain your explicit consent.

If personal information needs to be transferred due to merger, division, dissolution, declaration of bankruptcy, etc., we will inform you of the name and contact information of the recipient and require the company or organization that receives your personal information to continue to be bound by this privacy policy. If there are any change to the collection and processing of personal information agreed in this policy, we will require the company or organization to obtain your authorization and consent again.

4.3 Movement of Information

If personal information needs to be moved due to merger, division, dissolution, declaration of bankruptcy, etc., we will inform you of the name and contact information of the recipient and require the company or organization that receives your personal information to continue to be bound by this privacy policy, otherwise, we will require the company or organization to seek your authorization again.

4.4 Public Disclosure

We will only publicly disclose your personal information under the following circumstances and on the premise of taking security measures that comply with industry standards.

• 1) Disclose corresponding personal information according to the scope of your specific authorization.
• 2) In cases of material violation of laws, regulations or relevant agreements and rules, we may disclose the relevant violations and the measures we took against.

We may disclose your personal information to the competent authorities based on laws, legal procedures, litigation, or mandatory requirements from government authorities. However, we guarantee that when the above situation occurs, we will require the disclosure requesting party to issue corresponding valid legal documents and take security protection measures that comply with laws and industry standards for the disclosed information.

5. How We Process Minors' Personal Information

5.1 Moore Threads attaches great importance to the protection of minors' personal information. We consider individuals under 14 years of age as minors and do not intentionally collect or request personal information from them. Our products and services are targeted at adults, and minors are not allowed to create accounts without consent from their parents or legal guardians. With parental or guardian consent, we will collect and use minors' personal information within the scope permitted by current laws and protect the minors’ personal information in accordance with the law.

5.2 If you are a minor under 14, please do not submit personal information to Moore Threads, and you should obtain the consent of your parents or legal guardian before using our products or services. We recommend your parents or guardians to review our privacy policy carefully and suggest that you used our products and /or services with the guidance of your parents or guardians. For situations where we collect personal information from minors with the explicit consent from parents or guardians, we will only use or publicly disclose this information as permitted by law, with explicit consent from parents or guardians, or as necessary to protect the minor.

5.3 If you are a guardian of a minor, you may contact us immediately if there are concerns about the minor who use of our services or the user information they provide to us. We are committed to the confidentiality and security of minors' personal information in accordance with relevant national laws and regulations and this policy. If we inadvertently collect personal information from minors without obtaining verifiable parental or legal guardian consent, we will try to delete the relevant date as soon as possible.

6. How You Can Manage Your Personal Information

We highly value your attention to your personal information and are committed to protect your rights to access, correct, delete, and withdraw consent to your personal information, ensuring your privacy and security.

6.1 Accessing and Correcting Your Personal Information

You have the right to access and correct your personal information, as allowed by law. If you wish to exercise these rights, please contact us through contact information provided in the "How to Contact Us" section. We will respond to your request within 10 days.

6.2 Deleting Your Personal Information

To delete your personal information, contact us as through the "How to Contact Us" section. We will respond within 15 days based on the requirements of relevant laws, regulations, and internal policies. Note that deleting or modifying information may affect your use of our products or services and may cause the failure of some functions.

6.3 Changing the Scope of Your Authorization and Consent

You have the right to change the scope of your authorization and consent or withdraw your authorization by deleting information, turning off device functions, and setting privacy settings on the website or software, or by canceling your account. Understand that withdrawing authorization or consent may prevent Moore Threads from providing the service related to that consent or authorization and will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the previous processing of personal information based on your authorization.

6.4 Account Cancellation

You may request to cancel your account under the terms of the related product or service. Upon cancellation, Moore Threads will cease providing services and will delete or anonymize your personal information unless otherwise required by law.

6.5 Responding to Your Requests

Moore Threads will employ appropriate technical measures to ensure you can query, supplement, correct or delete your personal information, or apply through feedback or complaint channels provided by related Moore Threads’ products or services. Upon receiving your request, Moore Threads will process it according to established procedures. For security purposes, you may be required to submit a written request or otherwise verify your identity. Moore Threads may ask for identity verification before proceeding with your request.

For legitimate and reasonable requests, Moore Threads will respond within a reasonable timeframe without charging fees in principle. For repetitive or unreasonably excessive requests, Moore Threads may charge a fee based on the circumstances. Requests that are baseless, technically demanding (such as requiring new system development or significant changes to current practices), pose a risk to others' legal rights, or are impractical (like those involving information on backup tapes) will be legally denied by Moore Threads.

Under certain circumstances mandated by law and regulations, Moore Threads may not be able to fulfill your request. These circumstances include:

• (1) Directly related to national security or defense.
• (2) Directly related to public safety, public health, or significant public interests.
• (3) Directly related to criminal investigation, prosecution, trial, and judgment execution.
• (4) There is sufficient evidence of your subjective malice or abuse of power.
• (5) Responding to your request would severely harm the legal rights and interests of you or others.
• (6) Involving trade secrets.
• (7) Necessary to protect your or other individuals' life, property and other major legitimate rights and interests, where obtaining your consent or authorization is difficult.
• (8) The personal information concerned is publicly disclosed by you.
• (9) Necessary for entering and performing a contract required by the personal information subjects.
• (10) Collected from legally disclosed sources, such as lawful news reports and public government disclosures.
• (11) Essential for maintaining the secure and stable operation of the provided services, such as identifying and addressing product or service malfunctions.
• (12) Necessary for conducting public interest-oriented statistical or academic research; provided that the personal information contained in the results shall be de-identified and processed when provided externally.

6.6 If you are unable to access, correct or delete your personal information, or you need to access, correct or delete other personal information generated when you use Moore Threads’ products or services, or if you believe Moore Threads has violated any laws, regulations or agreements related to the collection or use of your personal information, please contact us through the official feedback channels.

7. Changes and Revisions to This Policy

We reserve the right to update or modify this policy as needed. Changes will not restrict your rights under this policy without your explicit consent.

For significant policy changes, we will provide clear notice. You can always view the latest policy on our official website.

Significant changes include, but are not limited to:

• (1) Major changes in our service model, such as the purposes, types, and usage of personal information.
• (2) Significant changes in control, such as ownership changes due to mergers or reorganizations, etc.
• (3) Changes in the primary recipients of personal information sharing, transfer, or public disclosure.
• (4) Major changes in your rights and how they are exercised concerning personal information processing.
• (5) Changes in our contact methods and complaint channels.
• (6) High-risk indications in personal information security assessment reports.

If you disagree with the modified policy, you have the right and should immediately stop using Moore Threads' products / services. Your continued use of our website after such changes will constitute your agreement to the revised policy.

8. How to Contact Us

If you have any questions, comments, suggestions, or complaints about our policy or how we manage your personal information, please contact us at privacy@mthreads.com.

Generally, we respond to inquiries within 15 business days.

9. Dispute Resolution

For any disputes arising from this policy and our processing of your personal information, you may file a lawsuit with the People's Court of Chaoyang District, Beijing.

10. Definitions

Personal information includes electronic or other records that can identify an individual or reflect their activities, excluding anonymized information. This encompasses names, birth dates, ID numbers, personal biometric information, addresses, contact info, communication records and content, and account credentials etc.

Sensitive personal information refers to personal information that, once leaked, illegally provided or misused, may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment, including biometrics, religious beliefs, specific identities, medical health, financial accounts, whereabouts, and the personal information of minors under the age of 14.

Cookies refer to text files that the website server stores on your device (your computer, mobile phone or other smart terminal) when you browse the website. When you visit the corresponding website again, the website can identify your browser through the cookie. Cookies may store user preferences and other information. You can configure your browser to block all cookies or to display a prompt when a website sends a cookie. You can block cookies, but this may affect website functionality.

11. Effectiveness of This Policy

This policy version was published on September 18, 2023, and will take effect on the same date.