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  1. Platform-related

Privacy Policy

Welcome to the high-value GenAI Open Platform provided by FC and its affiliates (hereinafter referred to as "FC" or "we"). We attach great importance to the protection of your information (you are hereinafter referred to as "you"). When you register, log in, and use https://console.nexhina.ai/ (hereinafter referred to as "the Platform"), we will collect and store the necessary user information required for your registration and normal use of the Platform's functions (defined in 1.1). We will not collect or store the interaction data between you and open-source models, third-party websites, software, applications, or services during your use of the Platform (defined in 1.4.1). If our services contain links to third-party websites, applications, or services, this policy does not apply to any products, services, websites, or content provided by such third parties. If you (or your company) use our products or services to provide services to your (or your company's) customers, you (or your company) need to formulate a privacy policy that is appropriate for the transaction scenario and relevant laws. If you (or your company) agree to use our products or services to access links to third-party websites, applications, or services, you (or your company) need to comply with the relevant policies of such third-party websites, applications, or services on your own. We hope to introduce to you through this Privacy Policy how we handle your user information and interaction data. Please pay attention to the clauses highlighted in bold. Please make sure that you fully understand and agree to these terms before you start using our services. If you do not agree to this Privacy Policy, please stop using our services immediately. When you choose to use our services, you are deemed to accept and agree to our handling of your relevant information in accordance with this Privacy Policy.

Overview#

This Privacy Policy will help you understand:
1.
How we collect and use your user information
2.
Our use of Cookies and similar technologies
3.
How we store your user information
4.
How we share, transfer, and publicly disclose your information
5.
How we protect your information security
6.
How we manage your user information
7.
Terms for Minors
8.
Revisions and notifications of the Privacy Policy
9.
Scope of application

1. How We Collect and Use Your User Information#

1.1 We Will Proactively Collect Your User Information#

1.1 We proactively collect your user information. To ensure your normal use of our platform, and within the scope permitted by law, we will collect user information that you proactively provide in the following scenarios and business activities when using our services, as well as user information automatically generated during your use of our services, including but not limited to personal information you provide (user information). Please note that if the information itself, or when combined with other information, cannot identify your personal identity and is unrelated to you, such information does not constitute personal information in the legal sense; if your information itself, or when combined with other information, can identify your personal identity, or when we cannot link the data to any specific user, such information will be used in combination with other user information and will be handled and protected as your user information in accordance with this Privacy Policy during the combined use. It should be noted that personal information does not include information that has been anonymized.
1.1.1 When you register, verify, and log in to your platform account
you can use your mobile phone number to create an account. We will verify your identity by sending an SMS verification code; this information is collected to help you complete registration and login. If you log in to the platform using an account from another platform, you authorize us to obtain relevant information from your other platform account, such as account/account information from third-party platforms such as WeChat (including but not limited to your name, avatar, and any other information you authorize).
1.1.2 When you subscribe to or activate services
Before subscribing to or activating any of the services we provide, in accordance with the laws and regulations of mainland China (excluding Hong Kong, Macau, and Taiwan), we need to conduct real-name authentication for you.
(1) For individual users: You may need to provide your real identity information, including your full name, ID number, photos of the front and back of your ID, a China UnionPay Class I bank account or credit card number issued by a member institution, and the mobile phone number registered with the bank, etc., to complete real-name authentication.
(2) For enterprise users: You may need to provide relevant information about your organization, including the organization's name, unified social credit code, account registration authorization letter (with official seal), the registration/qualification certificate of the legal representative or organization (certificate types include business license, organization legal person certificate, institutional legal person certificate, social organization legal person registration certificate, administrative law enforcement subject qualification certificate, etc.), bank name, bank account (UnionPay bank account or credit card number), the name, ID number, photos of the front and back of the ID, and ID photo of the legal representative or authorized person, to complete real-name authentication. In addition, you may need to provide personal information of the enterprise contact, including name, phone number, and email address. We may use this information to verify your identity, and may use it for promotion or introduction of services, sending business notifications, issuing invoices, or business communication with you. If the information you provide contains third-party personal information or user information, you agree and warrant that you have obtained authorization from the relevant rights holder before providing such information to us.
(3) During the above real-name verification process, if you complete real-name verification through facial recognition, you need to provide your facial feature biometric information and authorize us to verify this information through a national authoritative and trusted identity verification agency.
1.1.3 When you use this service
(1) We are committed to providing you with a safe and reliable product and service environment. Providing high-quality, reliable services and information is our core goal. At the same time, we ensure the stable operation of products and services and protect the legitimate rights and interests of you, other users, or the public. Therefore, we will collect necessary information to maintain the safe and stable operation of products and services.
(2) When you browse or use this platform, in order to ensure the normal operation and security of the website and services, prevent network attacks or intrusion risks, and more accurately identify behaviors that violate laws, regulations, or the relevant agreements and service rules of this platform, we may collect your device information, such as resolution, time zone, and language settings, network access method and type, and browsing history. This information is crucial for us to provide and ensure the normal operation of services and network security.
(3) In order to improve your experience and ensure your usage security, we may record network log information, usage frequency, crash data, usage, and related performance data of this platform and its related services.
(4) When you participate in surveys or lottery activities of this platform, the platform may retain information such as your account ID, name, address, phone number, job title, and product and service usage information. This information will be used to contact you, verify your identity, and provide rewards (if any) according to the rules of the specific activity. If the rules of a specific survey or lottery activity conflict with this agreement, the activity rules shall prevail.
(5) We may collect user consultation records, fault report records, and troubleshooting process records (such as communication or call records) generated during your use of this platform and related services. We will record and analyze this information to respond to your help requests more promptly and improve our services.
(6) Contract information: If you need to apply for offline delivery or conduct product testing, please contact contact@nexhina.cn.
(7) In order to provide you with domain name services, we will collect the domain name holder's name, contact name, mailing address, region, postal code, email address, landline/mobile phone number, ID number, and ID photo in accordance with the relevant regulations of the Ministry of Industry and Information Technology. You understand and authorize us and third-party domain name service providers to use this information to provide you with domain name services.
(8) In order to provide you with certificate center services, we will collect the contact's name, email address, mobile phone number, company name, city, and company address in accordance with the requirements of digital certificate authorities. You understand and authorize us and third-party certificate service providers to use this information to provide you with certificate center services.
(9) You acknowledge and agree that, during your use of the products and/or services, we may send notifications to you through one or more of your contact methods (such as phone number and email address) for purposes such as user message notifications, identity verification, security verification, and user experience surveys; in addition, we may send commercial information about services, features, or activities that may interest you via SMS or phone to the phone numbers collected in the above process. However, please rest assured that if you do not wish to receive such information, you can unsubscribe by replying to the SMS or email, or by contacting us directly.

1.2 We May Obtain User Information from Third Parties#

In order to provide you with better, more efficient, and more personalized services, or to provide services jointly with you, or to prevent network fraud, our affiliates and partners may share your information with us in accordance with laws and regulations, the agreement signed with you, or your consent. We will make every commercial effort to protect your user information in accordance with relevant laws and regulations and/or identity verification function requirements.

1.3 Handling of Changes in the Purpose of User Information Collection and Use#

Please understand that, with the development of our business, the functions or services we provide may be adjusted. In principle, when newly added functions or services are related to the functions or services we currently provide, the collection and use of user information will be directly or reasonably related to the original processing purposes. Only when there is no direct or reasonable connection with the original processing purposes, will we, in accordance with laws and regulations and national standards, inform you again about the collection and use of user information through page prompts, interactive processes, and consent confirmations.

1.4 Business and Customer Data#

Please note that your business and customer data is different from user information. The Platform will handle your business and customer data as follows:
1.4.1 Data generated or processed ("processed") through the services provided by this Platform (excluding third-party services), including but not limited to data involving open-source models, third-party websites, software, applications, or services through input, feedback, modification, processing, storage, upload, download, distribution, and other means, is your business and customer data ("Interaction Data"). You have full ownership of the Interaction Data. As a neutral technical service provider, the technical services provided by this Platform will process your Interaction Data strictly in accordance with your instructions. Unless otherwise provided by laws and regulations, or otherwise agreed upon according to specific product rules, or at your request to provide technical support to solve technical problems, we will not access your Interaction Data, nor will we make any unauthorized use or disclosure of it.
1.4.2 You shall be responsible for the source and content of the Interaction Data. We recommend that you carefully evaluate the legality of the data source and content. You must ensure that you have the right to authorize this Platform to process such Interaction Data through technical services. Data processing must comply with relevant laws and regulations. There must not be any illegal, non-compliant, or rights-infringing behavior, nor any violation of contracts with third parties. In addition, the Interaction Data shall not be used for illegal or improper purposes. If any problem arises due to the content of your Interaction Data, or your behavior in processing data or authorizing this Platform to process data in violation of laws, regulations, departmental rules, or national policies, you will bear all resulting consequences and responsibilities alone.
1.4.3 On the premise of complying with the preceding paragraph, when the Interaction Data you provide contains any personal information or information that requires authorization before use ("Authorized Information"), you shall, in accordance with the law, perform the obligation of prior notification to the relevant information subjects on your own and obtain their separate consent, and shall ensure that:
(1) Upon our request, you shall provide written explanation and confirmation of the source and legality of the Authorized Information.
(2) Upon our request, you shall provide the scope of authorization of the Authorized Information, including the purpose of use and proof that the personal information subjects have agreed to your use of this Platform to process their personal information. If you process Authorized Information beyond the scope or duration of authorization, you shall be responsible for obtaining expanded or extended authorization on your own.
You understand and agree that, unless the above conditions and other obligations stipulated by law are met, you shall not provide Interaction Data containing Authorized Information to us.
If you violate the above obligations and fail to provide us with reasonable and satisfactory evidence as required, or if we receive reports or complaints from personal information subjects, we have the right to unilaterally decide to stop providing technical services (including limiting relevant service functions, freezing, canceling, or withdrawing accounts, etc., as appropriate), or to refuse to process relevant personal information and related data in accordance with your instructions. All resulting responsibilities shall be borne by you.
1.4.4 You understand and agree that you are responsible for storing your Interaction Data according to your own needs. We only provide data storage services when required by relevant laws and regulations or stipulated by specific service rules (for example, you have signed a specific agreement with our data center regarding the storage of your business and customer data). You understand and further agree that, unless otherwise provided by laws and regulations or otherwise agreed in service rules, we have no obligation to store your Interaction Data, and we do not assume any responsibility for your data storage work or results.

2. Use of Cookies and Similar Technologies#

Cookies and similar technologies are commonly used technologies on the Internet. When you use this Platform, we may use relevant technologies to send one or more Cookies or anonymous identifiers to your device to collect and store your account information, search history, and login status information. Cookies and similar technologies can help you avoid the steps of repeatedly filling in account information and entering search content, and also help us improve service efficiency and login and response speed.
You can refuse or manage Cookies through your browser settings. However, please note that if you disable Cookies, you may not be able to enjoy the best service experience, and the availability of some functions may be affected. We promise not to use user information collected through Cookies or similar technologies for any purpose other than those described in this Privacy Policy.

3. How We Store Your User Information#

3.1 Information Storage Location#

To ensure the professionalism of the service, we may entrust affiliates or other legal entities to provide you with one or more specific services on this Platform. In accordance with laws and regulations, we will store user information collected and generated in the operation of this website and related services within the territory of the People's Republic of China.

3.2 Information Storage Period#

3.2.1 We will retain your user information only for the period necessary to provide this Platform and related services. However, you understand and acknowledge that the necessary storage period may vary depending on different services and their functional requirements. The criteria we use to determine the storage period include:
(1) The retention time of user information required to achieve business purposes, including providing services, legally maintaining relevant transactions and business records, ensuring system and service security, responding to potential user inquiries or complaints, and resolving problems;
(2) The longer retention period agreed to by the user;
(3) Special requirements for retention of user information stipulated by laws, contracts, etc.
3.2.2 We will retain relevant information until you withdraw your authorization, delete, or cancel your account. After the necessary period expires, we will delete or anonymize your information. If there is a mandatory requirement of laws and regulations to retain it, even if you cancel your account or request deletion of user information, we may not be able to delete or anonymize your user information.

4. How We Share, Transfer, and Disclose Your Information#

4.1 Partners Participating in Data Use#

4.1.1 Principles
(1) Legality principle: Data use activities involving partners must have a legitimate purpose and comply with the legal basis of legality. If the partner's use of information no longer complies with the legality principle, your user information should not be used, or it should only be used after obtaining an appropriate basis of cooperation.
(2) Legality and minimum necessity principle: Data use must have a legitimate purpose and should be limited to the scope necessary to achieve that purpose.
(3) Security and prudence principle: We will carefully evaluate the partner's purpose of using data, conduct a comprehensive assessment of the partner's security capabilities, and require them to comply with cooperation legal agreements. We will implement strict security monitoring of the Software Development Kits (SDKs) and Application Programming Interfaces (APIs) used by partners to protect data security.
4.1.2 Entrusted Processing
In scenarios involving entrusted processing of user information, we will sign relevant processing agreements with entrusted partners in accordance with laws and regulations, and supervise their activities related to the use of user information.
4.1.3 Joint Processing
In scenarios involving joint processing of user information, we will sign relevant agreements with partners in accordance with laws and regulations, clarifying the rights and obligations of each party to ensure compliance with legal requirements and protection of data security when using relevant user information.
4.1.4 Partner Scope
If specific functions and scenarios involve services provided by our affiliates or third parties, the scope of partners includes our affiliates and third parties.

4.2 Scenarios of Joint or Entrusted Processing of User Information#

4.2.1 Certain specific modules or functions in this Platform and related services are provided by partners. You understand and agree that, when cooperating with any partner, we will only provide your user information to them within the minimum scope necessary to provide the service, in accordance with the principles of legality, fairness, necessity, and security, and will make every effort to ensure that partners comply with this Privacy Policy and other appropriate confidentiality and security measures we require, and commit not to use your information for any other purpose.
4.2.2 In order to provide better services, we may entrust partners to provide services for you, including but not limited to customer service, payment functions, real-name authentication, and technical services. Therefore, in order to provide services, we may share certain information with partners. For example:
(1) For user real-name authentication, when you use identity verification functions or related services, you may need to complete real-name authentication to verify your identity in accordance with relevant legal and security requirements. During the real-name authentication process, the certification service agencies we cooperate with may need to use your real name, ID number, phone number, and other information.
(2) The payment function is provided by third-party payment institutions that cooperate with us. To provide this function, third-party payment institutions may need to use your name, bank card type, card number, expiration date, ID number, mobile phone number, and other information.
(3) In order to promptly handle your complaints, suggestions, and other requests, our customer service personnel (if any) may need to use your account information and related event details in order to promptly understand, process, and respond to relevant issues.
4.2.3 Data Use for Service Security and Analysis
(1) Usage security: We attach great importance to account and service security. In order to protect the accounts and assets of you and other users, and to ensure that your and our legal rights and interests are not harmed, our partners and we may use necessary device, account, and log information.
(2) Service usage analysis: In order to analyze the use of our services and improve user experience, our partners and we may collect statistical data about your service usage, such as crash or shutdown data, which cannot be easily identified or associated with your identity.

4.3 Transfer of User Information#

Except in the following circumstances, we will not transfer your user information to any other third party:
4.3.1 According to your written request and in compliance with the requirements of the national cybersecurity department, we may provide transfer channels.
4.3.2 With your explicit consent, we may transfer your user information to other third parties.
4.3.3 If there is a change, merger, acquisition, or bankruptcy liquidation of the Platform's operations involving the transfer of user information, we will inform you of the relevant situation in accordance with legal requirements and require the new entity holding your information to continue to comply with this Privacy Policy, or to meet security standards no lower than those stipulated in this Privacy Policy. Otherwise, we will require the company or organization to obtain your authorization and consent again. In the event of bankruptcy without a data successor, we will delete your information.

4.4 Disclosure of User Information#

4.4.1 In principle, unless we obtain your explicit consent or it is required by national laws and regulations, we will not publicly disclose your user information.
(1) With your explicit consent or based on your voluntary choice, we may publicly disclose your user information.
(2) In order to protect the personal or property safety of you or the public, we may disclose your user information in accordance with applicable laws or the relevant agreements and rules of the Platform.
4.4.2 Exceptions to Authorization and Consent
Please understand that, in the following circumstances, we may collect and use your user information without your prior authorization and consent, in accordance with laws, regulations, and relevant national standards:
(1) Necessary for the performance of legal obligations.
(2) Directly related to national security or national defense.
(3) Directly related to public safety, public health, or major public interests.
(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments.
(5) Necessary to protect your or others' significant legitimate rights and interests (such as life or property) and where it is difficult to obtain your consent.
(6) You have personally and publicly disclosed personal information.
(7) Necessary for concluding or performing a contract at the request of the personal information subject.
(8) When the information comes from a legally disclosed source, such as legitimate news reports or government disclosure information.
(9) Necessary to maintain the safe and stable operation of software and related services, such as detecting and handling software and service failures.
(10) Necessary for legitimate news reporting.
(11) When necessary for academic research institutions to conduct statistics or academic research in the public interest, and the research results are published in a way that anonymizes all personal information.
(12) Other circumstances stipulated by laws and regulations.
Please note that if the information, alone or in combination with other information, cannot identify your personal identity, it does not constitute personal information in the legal sense. When your information, alone or in combination with other information, can identify your personal identity, during the combined use, such information will be treated as your user information and protected in accordance with this Privacy Policy.

5. How We Protect Your Information Security#

We attach great importance to user information security and are committed to implementing reasonable security measures (including technical and management measures) to protect your information from unauthorized access, disclosure, misuse, modification, damage, loss, or leakage. We will adopt industry-standard encryption technologies, anonymization, and other feasible means to protect your information, and use security mechanisms to minimize the possibility of malicious attacks.
We have dedicated personnel and systems in place to ensure the security of your information. We follow strict data usage and access control. Despite the effective measures we have taken and our compliance with legal standards, please understand that, due to technical limitations and the possibility of malicious behavior, the Internet industry cannot guarantee absolute security, and we will make every effort to ensure the security of the information you provide to us. You acknowledge and understand that the systems and communication networks you use to access our services may be affected by factors beyond our control. Therefore, we strongly recommend that you take active measures to protect the security of user information, such as using complex passwords, changing passwords regularly, and not disclosing your account password to others.
We have formulated an emergency response plan. Once a user information security incident occurs, we will immediately activate these plans to prevent the spread of potential harm. If a user information security incident (such as a leak or loss) occurs, we will promptly notify you in accordance with legal requirements, including the basic situation of the incident and possible impact, the measures we have taken or will take, self-protection and mitigation recommendations, and remedial measures. We will notify you via push notifications, emails, letters, or SMS. If it is difficult to notify each user, we will issue announcements in a reasonable and effective manner. In addition, we will report the handling of user information security incidents to the relevant regulatory authorities as required.
We remind you that the user information protection measures outlined in this Privacy Policy apply only to this Platform and related services. Once you leave this Platform, browse or use other websites, products, services, or content resources, regardless of whether you access other websites or software through links or guidance provided by this Platform, we cannot protect any information you submit on software or websites outside the Platform.

6. How We Manage Your User Information#

We attach great importance to the management of user information and, in accordance with the law, protect your rights to access, copy, correct, supplement, delete, withdraw consent, cancel accounts, and file complaints and reports regarding your information, so that you can protect your privacy and information security.

6.1 Your Rights in User Information Processing Activities#

6.1.1 Under normal circumstances, you can access, copy, correct, supplement, view, modify, or delete the user information you provide.
6.1.2 In the following circumstances, you can request the deletion of your user information:
(1) The processing purpose has been achieved, cannot be achieved, or no longer needs to be achieved.
(2) Our user information processing activities violate laws and regulations.
(3) We collect or use your user information without your consent.
(4) Our user information processing activities violate the agreement between us and you.
(5) We have stopped providing products or services, or the storage period of user information has expired.
(6) You have withdrawn your consent authorization.
(7) We no longer provide services to you.
(8) Other circumstances stipulated by laws and regulations.

6.2 Withdrawing or Changing the Scope of Your Authorization and Consent#

6.2.1 You understand and agree that each service requires certain necessary user information to complete. In addition to collecting necessary user information for business functions, you can choose to withdraw your authorization or change the scope of authorization. You can also withdraw all authorizations by canceling your account, allowing us to continue to collect your user information.
6.2.2 You understand and agree that, after withdrawing consent or authorization, you will no longer be able to continue to use the services related to the withdrawn consent or authorization, and the Platform will no longer process your corresponding user information. However, your decision to withdraw consent or authorization will not affect our previous processing of user information based on your authorization.

6.3 How to Obtain a Copy of Your User Information#

According to your written request, we will provide you with copies of the following types of user information: your basic information and user identity information. However, please note that the copies provided to you are limited to the information we collect directly.

6.4 Responding to Your Requests#

You have the right to cancel your account, submit reports, or file complaints. To ensure security, you may need to provide a written request and proof of identity. For reasonable requests, we usually do not charge a fee. However, for repeated requests or those beyond a reasonable scope, we may charge a certain fee according to the specific situation. For baseless requests, those that require excessive technical means (such as developing new systems or fundamentally changing existing practices), that infringe on the legitimate rights and interests of others, or that are impractical (for example, information stored on backup tapes), we may refuse to handle them.
You understand and acknowledge that, in the following circumstances, we may not be able to respond to your request:
(1) When the request is related to the performance of our legal obligations;
(2) When the request directly relates to national security or national defense;
(3) When the request directly involves public safety, public health, or major public interests;
(4) When the request directly involves criminal investigation, prosecution, trial, and execution of judgments;
(5) When we have sufficient evidence to show that the personal information subject has acted in bad faith or abused their rights.
(6) When it is difficult to obtain consent in order to protect the life, property, or other significant legitimate rights and interests of the personal information subject or other individuals.
(7) When responding to the request would seriously harm the legitimate rights and interests of the personal information subject or other individuals and organizations.
(8) When it involves trade secrets.

6.5 Notice of Business Termination#

If we cease operations, we will stop collecting your user information, notify you of the cessation of operations through a separate notice or through feasible commercial means (such as a public statement), and delete or anonymize the user information we hold about you.

7. Terms for Minors#

Our services are mainly oriented to enterprises and related institutions. Minors (under 14 years old) are not allowed to create accounts or use this Platform and its services. If we discover that user information has been provided without the prior verifiable consent of a guardian, upon receiving the guardian's written notice, we will delete the relevant information as soon as possible.

8. Revisions and Notifications of the Privacy Policy#

In order to provide better services, this Platform and related services will be updated and adjusted regularly. We may revise this Privacy Policy in a timely manner. Such revisions form a part of the Privacy Policy and have the same legal effect. However, we will not, without your explicit consent, reduce the rights you enjoy under the current Privacy Policy.
After the Privacy Policy is updated, we will post the updated version on this Platform and notify you through website announcements or other appropriate means before it takes effect, so that you can keep abreast of the latest version of the Privacy Policy in a timely manner. If you continue to use this Platform and related services, you are deemed to fully agree to the revised Privacy Policy.
For significant changes, we will provide more prominent notices (including but not limited to emails, SMS, system messages, or special reminders on browsing pages) to explain the specific changes to the Privacy Policy.
Significant changes to this Privacy Policy include, but are not limited to:
(1) Significant changes in the service model, such as changes in the purpose of user information processing, the types of user information processed, and the way user information is used.
(2) Significant changes in the ownership structure, organizational structure, etc., such as business restructuring, bankruptcy, and mergers and acquisitions.
(3) Changes in the main recipients of user information transfer, transmission, or public disclosure.
(4) Significant changes in your participation rights in user information processing and the way you exercise these rights.
(5) Changes in our contact information and complaint channels.

9. Scope of Application#

This Privacy Policy applies to the products, services, and solutions provided by this Platform, as well as any other products, services, or solutions that the company may periodically launch and that are included in the scope of services.
This Privacy Policy does not apply to third-party products or services provided by this Platform, which are subject to separate privacy policies and are not included in this Privacy Policy. Your use of these third-party services (including any user information you provide to these third parties) will be subject to the third party's terms of service and privacy policy (not this Privacy Policy). You should make relevant requests, complaints, and reports through the mechanisms specified by these third parties in their policies. Please properly protect your user information and provide it to third parties only when necessary.
It is especially important to note that, as a user of this Platform, if you use the technical services of this Platform to further provide services to your users, the data generated by your business cooperation with customers belongs to you. You should separately agree on the relevant privacy policy with your users. This Privacy Policy cannot replace the privacy policy between you and your users.

10. Supplemental Provisions for International Users#

This section supplements the provisions above for users located outside of mainland China. In the event of any conflict between this section and the preceding provisions, this section shall prevail for international users. If you are a mainland China user, the preceding provisions apply.

10.1 Applicable Law and Jurisdiction#

For users located outside of mainland China, this Privacy Policy and any dispute or claim arising out of or in connection with it shall be governed by, and construed in accordance with, the laws of the user's habitual residence, without regard to its conflict of law principles. Nothing in this section shall deprive you of the protection afforded to you by mandatory provisions of the consumer protection laws of your country of residence.

10.2 Identity Verification (KYC) Alternatives#

International users are not required to provide a Chinese national ID card, UnionPay bank account, or undergo facial recognition. Instead, we accept the following alternatives for identity verification:
A valid passport, driver's license, or other government-issued photo ID from your country of residence
A valid international credit card (Visa, MasterCard, American Express, etc.) or a PayPal / Stripe account in your name
For enterprise users: a Certificate of Incorporation, business license, or equivalent registration document issued by the competent authority of your jurisdiction, together with proof of authorization for the account operator
We will never require biometric data (such as facial features) from international users.

10.3 Data Storage and International Transfers#

For international users, we undertake the following:
Storage location: Personal information of international users may be stored in data centers located in Singapore, Frankfurt, or other regions where we operate, in addition to mainland China. We will select the storage region closest to the user by default.
Cross-border transfers: Where personal information needs to be transferred across borders (for example, to our affiliates or service providers), we do so only on the basis of one of the following legal mechanisms: (i) your explicit consent; (ii) the EU Standard Contractual Clauses (SCCs); (iii) the UK International Data Transfer Agreement (IDTA); (iv) other legally recognized transfer mechanisms.
Government access requests: We will challenge any government request for your data that we consider overly broad, and will notify you of such requests to the extent permitted by law, unless we are legally prohibited from doing so.

10.4 Payment Methods#

International users may pay for our services using:
International credit / debit cards (Visa, MasterCard, American Express, JCB, etc.)
PayPal
Stripe-supported local payment methods (such as SEPA, iDEAL, Bancontact, etc.)
Wire transfer for enterprise users
Pricing is displayed in your selected billing currency (USD, EUR, GBP, JPY, etc.) and excludes any local taxes (such as VAT or GST), which will be added at checkout where applicable.

10.5 Your Rights under GDPR, UK GDPR, CCPA/CPRA, and Similar Laws#

If you are located in the European Economic Area (EEA), the United Kingdom, Switzerland, California, Virginia, Colorado, Connecticut, Utah, Texas, or any other jurisdiction with similar data protection laws, you have the following additional rights with respect to your personal information:
Right of access (Art. 15 GDPR / CCPA §1798.110): to obtain confirmation of whether we process your personal information and a copy of it.
Right to rectification (Art. 16 GDPR): to have inaccurate personal information corrected.
Right to erasure / right to be forgotten (Art. 17 GDPR / CCPA §1798.105): to have your personal information deleted, subject to certain exceptions.
Right to restriction of processing (Art. 18 GDPR).
Right to data portability (Art. 20 GDPR / CCPA §1798.110): to receive your personal information in a structured, commonly used, machine-readable format and to transmit it to another controller.
Right to object (Art. 21 GDPR): to object to processing based on legitimate interest or for direct marketing purposes.
Right to opt out of sale or sharing (CCPA / CPRA §1798.120, §1798.135): we do not sell or share your personal information for cross-context behavioral advertising.
Right to opt out of automated decision-making (Art. 22 GDPR): you have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning you.
Right to lodge a complaint with your local data protection authority (e.g., the CNIL in France, the BfDI in Germany, the ICO in the UK, the California Privacy Protection Agency).
To exercise any of these rights, please contact us at privacy@nexhina.ai. We will respond within 30 days (or such shorter period as required by your local law). We will not charge you for exercising these rights, except where requests are manifestly unfounded or excessive.

10.6 Children's Privacy#

We recognize the following age thresholds for international users:
EEA / UK: 16 years old (or such lower age as your Member State permits, but not below 13)
United States: 13 years old (in compliance with COPPA)
Other regions: 14 years old, or the minimum age of digital consent in your jurisdiction, whichever is higher

10.7 AI-Generated Content and International Regulations#

In addition to the AI content identification obligations described in this Privacy Policy, we comply with the following international AI regulations as applicable:
EU AI Act: Synthetic content generated by our services is labeled in accordance with the EU AI Act's transparency obligations (Art. 50). High-risk use cases are subject to additional review.
US Executive Order 14110 on Safe, Secure, and Trustworthy AI: We implement red-team testing and content provenance (C2PA) standards for generated outputs.
Other regional regulations: We monitor and adapt to emerging AI laws in the UK, Canada, Japan, Australia, Singapore, and other jurisdictions where we operate.
If you are subject to specific AI disclosure obligations in your jurisdiction (for example, marking synthetic media in political advertising), you remain responsible for compliance with those obligations when you publish or distribute outputs generated through our services.

10.8 International Data Protection Officer and Contact#

For international users, our contact points are:
General privacy inquiries: privacy@nexhina.ai
EU / UK GDPR representative: eu-rep@nexhina.ai
Data Protection Officer (DPO): dpo@nexhina.ai
Postal address (international correspondence only): Nexhina International Ltd., 88 Market Street, Singapore 048948
We aim to respond to all privacy-related requests within 30 days. For urgent matters involving imminent harm, please indicate "URGENT" in the subject line.

10.9 Language#

This Privacy Policy is provided in English. Translations into other languages (such as Spanish, French, German, Japanese, Korean) are provided for convenience only. In the event of any inconsistency between the English version and a translation, the English version shall prevail, except where mandatory local law requires otherwise.
Modified at 2026-07-01 03:47:13
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