Privacy Policy for TEAM Model Account

Our Privacy Policy for TEAM Model Account (hereinafter referred to as this "Privacy Policy") was updated on August 12, 2022.

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

Introduction

The TEAM Model Account is a kind of account registration, logging and management services provided by HABOOK and its affiliated companies (hereinafter refer to as "HABOOK", "we", "our" or "us").

We take your privacy very seriously. This Privacy Policy sets out the privacy representations and commitments on the TEAM Model Account, and constitutes an important part and parcel of the HABOOK Privacy Policy.

This Privacy Policy is designed with your needs in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, while ensuring that ultimately, you have control of your personal information provided to us, which is crucial. This Privacy Policy sets out how we collect, use, disclose, process and store any information that you give us when you use our TEAM Model Account. Please note that you can refer to the privacy policy for the service for rules of collection and use of personal information for your use of the corresponding service. For the purpose of this Privacy Policy, "personal information" refers to data that can help identify a specific person through the information itself or after linked with other information. We will use such information in strict accordance with this Privacy Policy.

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarized in this Privacy Policy, please contact habook@habook.com to address your specific concerns. We will be happy to hear from you. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our third party dispute resolution provider (free of charge) at: https: //feedback-form.truste.com/watchdog/request

I. What information is collected by us and how do we use it?

(I) We collect your personal information upon your authorization for the purpose of providing you with products and/or services, and ensure that we will abide by relevant applicable laws, regulations and other normative documents. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our services or respond to your queries. The functions include:

1.Basic functions

(1) Registration or login

At the time of registration, you needs to provide us with your mobile phone number or email address as your TEAM Model Account name. Meanwhile, you can set a password for your TEAM Model Account. Your account number and password will be encrypted and saved on our server. It is suggested that you should properly keep your password to prevent your TEAM Model Account from embezzlement by others.

(2) Improvement of account information

While using different services provided by HABOOK, you may obtain better services and experience by improving basic information including avatar, nickname, gender, country or region and setting encryption. If you do not provide such information, you may also get access to basic functions of the TEAM Model Account.

2.Functions necessary for guaranteeing registration and login security

With the view of enhancing system safety at the time of your use of our products and/or services, better preventing phishing website fraud and protecting account safety, we will verify your identity by short message verification. In that light, we will need to collect your short message verification code.

Besides, we will collect your registration/login time, relevant equipment information (for example, equipment OAID, equipment model and the version of operating system, Android ID), network information (e.g. the generally used IP address of login) so as to judge whether current registration and login environment is safe or not.

(二)You are fully informed that we may collect and use personal information without your consent if:

1.The personal information is vital to national security and national defense security;

2.The personal information is vital to the public safety, public health and major public interests;

3.The personal information is related to the criminal investigation, prosecution, trial or execution of judgement;

4.We do that for the purpose of safeguarding major legitimate rights and interests of the personal information subject or others, like life and property, but find it hard to obtain such subject's consent;

5.The personal information collected is made public by the personal information subject to the society at its own discretion;

6.Your personal information is collected from the legally publicized information, such as legal news reports and information publicized by the government;

7.The personal information is necessary for us to sign the contract as required by you;

8.The personal information is necessary to maintain the safe and steady operation of products and/or services provided, such as for discovering and handling faults of products and/or services;

9.The personal information is necessary for legal news reports; and

10.Academic research institutions de-identify the personal information contained in the results of their academic findings or descriptions out of the needs for statistics or academic researches for and in the public's interest.

(III) Collection of the personal information from third-party sources

When permitted by law, we will collect information about you from third-party sources. For example, you authorize the binding of a third-party account with the TEAM Model Account, and log in the former to use HABOOK's services or authorize the import of your avatar, nickname and other information on the third-party platform; for the purpose of risk control, we will learn about whether your current registration/login environment is safe via a third party (such as the risk grade library of mobile phone numbers).

(IV) Non-identifiable information

We may also collect other types of information which are not directly or indirectly linked to an individual (i.e. the information other than the personal information), for example, statistical data generated during your use of any specific service, and the login/exit records, interaction records and error records during your use of services of the TEAM Model Account. The purpose for such collecting is to improve the services we provide to you. The type and amount of information collected depend on how you use our products and/or services. We aggregate such information. Such aggregated data is not personal information as it cannot be used to identify you. However, if we combine non-personal information with personal information, such information will be treated as personal information.

II. Sharing of your personal information with any third party

When you log in the TEAM Model Account at a third-party website/application, we will, upon authorization and approval by you, transmit your nickname, avatar and other information (depending on the nature of the third party's services and products) to the said third party. If you disagrees about the third party's acquisition of your personal information, please do not agree about authorization.

Please note that we will guarantee the security of your information by such means as of encryption. However, your personal information at a third party shall be subject to the privacy policy of the said third party. It is suggested that you should carefully read the third party's privacy policy, just as you read this Privacy Policy. You can log in https://account.habookaclass.biz/ at any time, and click "Binding Authorization" to cancel your authorization of the said third party.

III. Retention policy

We retain personal information for the period necessary for the purpose of the information collection described in this Privacy Policy or as required by applicable laws. We will cease to retain and delete or anonymize personal information once the purpose of collection is fulfilled, or after we confirm your request for erasure, or after we terminate the operation of the corresponding product or service. An exception to this is personal information that we are processing for public interest, scientific, historical research or statistical purposes. We will continue to retain this type of information for longer than its standard retention period, where permitted based on applicable laws, even if further data processing is not related to the original purpose of collection.

IV. Your rights

(I) Controlling settings

We recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways the TEAM Model Account makes available for you to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings:

▪ Log in https://account.habookaclass.biz/, or tap mobile phone settings - TEAM Model Account at your mobile phone to check and change account security information, personal information, authorization binding and equipment management; and

▪ Log in or out of the TEAM Model Account.

If you have previously agreed to us using your personal information for the abovementioned purposes, you may change your mind at any time by writing or emailing us at habook@habook.com.

(II) Your rights to your personal information利

Depending on applicable laws and regulations, you have the right to access, rectification and erasure of any other personal information that we hold about you (hereinafter referred to as the request).

You may also access and update the details relating to the personal information in your TEAM Model Account at https://account.habookaclass.biz/or by logging into your account on your device. For additional information, please write to us or contact us at the email address below. Email: habook@habook.com

Most laws requires that the request made by the personal information subject follow specific requirements, and this Privacy Policy requires that your request satisfy the following conditions:

• Through our exclusive access of request and for the protection of your information security, your request should be in writing (unless the local law explicitly recognizes the oral request);

• Provide sufficient information to enable us to verify your identity and ensure that the applicant is the subject or legally authorized person of the requested information.

Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws. In detail:

• Based on the requirements of applicable laws, a copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests for relevant information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.

• If any information we are holding on you is incorrect or incomplete, you are entitled to have your personal information corrected or completed based on the purpose of use.

• Based on the requirements of applicable laws, you have the right to request the deletion or removal of your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures. If the right is upheld, we may not be able to immediately remove the information from the backup system due to applicable legal and security technologies. In that case, we will securely store your personal information and isolate it from any further processing until the backup can be cleared or be made anonymous.

We have the right to refuse to process requests that are not meaningful/entangled, requests that damage others' right of privacy, extremely unrealistic requests, requests that require disproportionate technical work, and requests not required under local law, information that have been made public, information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, it may also be rejected.

(III) Withdrawal of consent

• You may withdraw your consent by submitting a request, including collecting, using, and/or disclosing your personal information in our possession or control. The withdrawal of your consent is equal to the cancellation of your TEAM Model Account. For that, you can send an email to habook@habook.com. We will process your request within a reasonable time from when the request was made, and thereafter not collect, use and/or disclose your personal information as per your request.

• Attention: Your withdrawal of consent may result in some legal consequences. You may not be able to continue receiving the full benefit of HABOOK’s products and services depending on the extent of our processing of information upon your authorization. The withdrawal of your consent or authorization will not affect the validity of our processing carried out upon your authorization up until the point of withdrawal.

(IV) Cancelling a service or account

If you wish to cancel the TEAM Model Account, you can choose to cancel the account through the account management. Please note that the cancellation will prevent you from using the full range of HABOOK products and services. In order to protect your accidental deletion, and confirm that it is your actual operation, we will send an SMS verification code or email verification letter. If you do not have any verifiable information, we will immediately clear the account information.

V. Protection of minors

We consider it the responsibility of the parent or guardian to supervise the child's use of our products or services. However, we do not offer services directly to a child or use personal data of children for the purposes of marketing.

If you are a parent or guardian and you believe that the minor has provided HABOOK with personal information, please contact us at habook@habook.com to ensure that the personal information is removed immediately and that the minor is unsubscribed from any of the applicable HABOOK’s TEAM Model services.

VI. Terms and conditions of third-party websites and services

Our Privacy Policy does not apply to products or services offered by a third party. Depending on the HABOOK product or service you use, it may incorporate a third parties’ products, services involving voice support, camera processing, video playback, system cleaning and security related services, gaming, statistics, social media interaction, payment processing, map navigation, sharing, push, information filtering, input methods, etc. Some of these will be provided in the form of links to third parties’ websites, and some will be accessed in the form of SDKs, APIs, etc. Your information may also be collected when you use these products or services. For this reason, we strongly suggest that you take the time to read the third party’s privacy policy just like you read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

VII. How we update this Privacy Policy

We review the Privacy Policy periodically based on changes in business and technology, and we may update this Privacy Policy. If we make a material change to this Privacy Policy, we will notify you via your registered contact information such as email (sent to the email address specified in your account) or publish on HABOOK websites or notify you via mobile devices so that you can learn about the information we collect and how we use it. Such changes to Privacy Policy will apply from the effective date specified in the notice or website. We encourage you to check this page regularly for the latest information on our privacy practices. Your continued use of the products and services on the website, mobile and/or any other device will be deemed acknowledgement of the updated Privacy Policy. We will ask for your explicit consent when we collect additional personal information from you or when we use or disclose your personal information for new purposes.

VIII. Contact us

If you have any comments or questions about this Privacy Policy or any questions relating to HABOOK’s collection, use or disclosure of your personal information, please contact us at the address below referencing “Privacy Policy”. When we receive privacy or personal information questions about access/download requests, we have a professional team to solve your problems. If your question itself involves a significant issue, we may ask you for more information. If you are not satisfied with the response you received, you can hand over the complaint to the relevant regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your actual situation.

Contact Addresses:
HABOOK Information Technology Inc.
8F. No.149, Sec. 3, Xinyi Rd., Da'an Dist., Taipei City 10658 , Taiwan
E-mail: habook@habook.com