Personal Information Protection Policy

The effective date of this Personal Information Protection Policy (the “Policy”) is 1^st January, 2024

The purpose of this Policy is to regulate the collection, storage, use, processing, transmission, provision, disclosure and deletion of personal information by Bachmann Electronics Co., Ltd. (the “Company” or “we”) through its Chinese website (309u.cn, the “Website”). Unless otherwise specified, this Policy does not apply to any other official website, webpage or other application of the Company other than this Chinese Website. Important provisions regarding your rights and interests in personal information have been bolded for your special attention.

This Policy will help you understand the following:

• Who is the handler of personal information
• How we collect and use your personal information
• How long we keep your personal information
• How we engage other entities to process, share, transfer or disclose your personal information
• How your personal information is transferred globally
• How we protect your personal information
• Your rights
• How we handle children’s personal information
• How this Policy will be updated

1. Who is the handler of personal information

The handler of personal information is: Bachmann Electronics Co., Ltd.

Address: Room 301, Building 1, No. 3, Hengzhong 1st Road, Hengkeng, Liaobu Town, Dongguan City, Guangdong Province

Contact email for protection of personal information: apac@bachmann.com

1. How we collect and use your personal information
   1. Personal information that we collect
      1. If you need to seek business cooperation or have other questions and requests, you may contact us directly via our contact form on the Website, anything you provide in a phone call or email will be deemed to be your express consent to the collection and processing of your relevant personal information by the Company. Please ensure that any attachment you voluntarily provide does not contain any sensitive personal information of yours, nor any personal information or sensitive personal information of others. Our collection of the above personal information is required to process or respond to your request. You may provide only part of your personal information, but if the information you fill in is incomplete, it may affect our ability to provide you with the service or response. If you refuse to provide the above information at all, we will not be able to receive and process your request, which, however, will not affect your access to the Website.
      2. We may implement so called social plug-ins (“Plugins”) from social networks and similar platforms (hereinafter referred to as “Social Networks”) on certain webpages of this Website. We use such Plugins in order to give you the possibility to share or recommend interesting offers in Social Networks and to promote our services. The use of Plugins is aimed to improve our reputation.

You may find Plugins of the following Social Networks on this Website:

Plugins of the social media platform Youku (Developer: Youku Information Technology (Beijing) Co., Ltd.) (“Youku”).

The Plugins can be clearly identified as they feature the logo of the associated social network.

When you visit a web page, the Plugin embedded in the web page usually connects your browser directly to the server of the respective provider and loads the Plugin and its content onto your browser so that it can be integrated into the web page you visit. Your browser will only make a direct connection to the servers of a Social Network, if you interact with the associated Plugin, such as by clicking on a “l(fā)ike” button and/or share the website content. If you interact with a Plugin without being logged into a social network, the respective social network provider will only receive information about the website from which you have called up the respective page. A direct connection between your browser and the social network is made only when you confirm the sharing of information. The information shared may be transmitted directly to the servers of the respective provider and stored there. The data collected by the provider may include user data including your IP address and geographic location, as well as technical data on the type of browser or operating system used.

The collection, storage and use of such data by social networks is not under our control. We do not have access to the collected data. For information on the scope and purpose of data collection, the provider's further processing and use of the data, and your rights and setting choices in relation to this, please read the provider's data protection statement to protect your personal information. Privacy policy of Youku: 優(yōu)酷隱私政策.

1. 1. How we use your personal information

Generally, we will only use the personal information we collect from you for the purposes described in this Policy or for the purposes we explain to you at the time we collect your personal information. The details are set out below:

• to safeguard data security, ensure that you can access our Website properly, enhance our Website and enable us to analyze errors;
• and to serve you better, enhance the management of our relationship with you, and optimize our Website and products;
• to respond to your request and to provide personalized services;
• to prevent fraud or other illegal activities, such as deliberate attacks on our technical systems;
• to lodge or defend our legitimate claims or to defend ourselves in relevant proceedings, or to provide support for any investigation or criminal investigation conducted in accordance with the law;
• to deal with such other matters as are permitted or required by the applicable laws.

1. How long we keep your personal information

Your personal information will be processed and stored for such period as necessary to carry out the purposes for which it has been collected, subject to the storage period required by the applicable laws or, where applicable, until such time as you withdraw your consent to the processing of personal information. At the end of such period, and when there is no longer any legal or commercial purpose for storing your personal information, the personal information will be automatically and permanently erased or anonymized.

Specifically, the storage periods of the personal information collected on the Website by the Company in relation to Sections 2 of this Policy are as follows:

• Personal information collected under Section 2.1.1 of this Policy is deleted when we have concluded our conversation with you or when the issue has been finally clarified. Other personal information collected in the process will be deleted at the latest after six months from the end of the conversation or when the issue has been finally clarified.
• Personal information independently processed by a third party will be retained for the period specified in the third party's personal information protection policy.

1. How we engage other entities to process, share, transfer or disclose your personal information

The Company will take adequate precautions, subject to the applicable laws, to ensure the security of your personal information. The Company will not provide, sell, rent, share or trade your personal information with any third party, unless it is required to do so to provide you the products and services, or we have obtained your consent, or it is in compliance with other laws to do so.

We may engage service providers to perform certain functions and provide certain products and services on our behalf (processing upon entrustment). We will enter into agreements with such service providers to protect your personal information, and these agreements specify all reasonable measures that should be in place at the contractual, legal, technical and organizational levels to ensure that the service providers provide adequate protection for the processing of your personal information and comply with applicable laws.

1. How your personal information is transferred globally

In principle, the personal information we collect and generate in the People’s Republic of China will be stored in the People’s Republic of China.

In order to provide you with a more comprehensive and optimized service, we may transfer your personal information (as described in Section 2.1.1 of this Policy) via Microsoft software to Bachmann Hong Kong Ltd., an affiliate of the Company. However, since the Microsoft software is purposed by our German headquarter Bachmann GmbH, your relevant personal information will be stored at the German server of Bachmann GmbH. Please note that, the purpose, methods, types of personal information, retention period, etc. of the overseas recipient Bachmann GmbH and the overseas third party Bachmann Hong Kong Ltd. are the same as stated in this Policy hereunder. The overseas recipient has signed a data protection agreement with the overseas third party to ensure that the third party’s personal information handling activities meet the standards of personal information protection stipulated by the relevant PRC laws and regulations, and that the overseas recipient shall be held legally liable for any infringement of the rights of the personal information subject in connection with its provision of the personal information to any third party outside the PRC. If you refuse to consent to such cross-border transfers of personal information, you will not be able to take advantage of the global resources offered by the Company.

You may exercise all your rights with respect to personal information under Section 7 of this Policy by contacting Bachmann GmbH at the addresses below. The contact information of the overseas recipient is also set forth below.

Name of overseas recipient：Bachmann GmbH

Address：Ernsthaldenstr.33, 70565 Stuttgart | Germany

Telephone number：+49 711 86602-0

Email address： info@bachmann.com

Name of overseas third party：Bachmann Hong Kong Ltd.

Address：8/F 88 Hing Fat Street Causeway Bay, Hong Kong

Telephone number：852 28022638

Email address： salesap@bachmann.com

In accordance with the requirements of the PRC data protection laws and regulations, the Company hereby solicits your separate consent for the cross-border transfer of personal information, and you will act as a third party beneficiary if, in accordance with the requirements of the PRC data protection laws and regulations, the Company enters into a standard contract with the overseas recipients in such format as formulated by the PRC cyberspace administration authority. If you do not explicitly refuse within 30 days following the date of the contract, you will become entitled to the rights of the third-party beneficiary under such standard contract.

1. How we protect your personal information

The Company uses technical and organizational security measures to protect the personal information we collect from you against accidental or intentional alteration, loss, destruction or access by unauthorized persons. Our security measures will be continually improving in line with technological developments.

The Internet environment is not 100% secure and we will endeavor to ensure or warrant the security of any information you send us. If any breach of our physical, technical or administrative safeguards results in unauthorized access to, public disclosure of, alteration of or destruction of information, resulting in damage to your legal rights and interests, we will be held legally liable accordingly.

In the event of a personal information security incident, we will immediately notify you in accordance with the requirements of laws and regulations, including the basic information of this security incident and its possible impact, including the response measures we have taken or will take, our advice to you on the measures you may take to prevent and mitigate the risks, as well as remediation actions. We will promptly notify you by email, phone, SMS text message and other means. If it is difficult to provide individual notification to certain specific subjects of personnel information, we will use reasonable and effective means to publish public announcements. At the same time, we will use a proactive approach to report on the handling of information security incidents as required by local regulatory authorities.

1. Your rights

In accordance with the applicable laws, regulations and standards of the PRC, as well as the prevailing practices in other countries and regions, we protect your right to exercise the following rights with respect to your personal information:

• Access your personal information. You have the right to access your own personal information, subject to the exceptions provided by laws and regulations.
• Correct and supplement your personal information. When you discover an error in the personal information about you which is processed by us, you have the right to request us to make corrections or supplementations.
• Delete your personal information. You may request us to delete your personal information when the reason why we need and process your information no longer exists, or when we are no longer legally permitted to process such information. If we decide to respond to your request for deletion, we will also at the same time notify the entities which have obtained your personal information from us and request them to timely delete your personal information, unless otherwise required by laws or regulations, or unless those entities have obtained your separate authorization. When you delete your information from our service, we may not immediately delete the corresponding information in our backup system, but will do so when updating the backup.
• Change the scope of your authorization and consent. Each business function requires some basic personal information to accomplish. You may give or withdraw at any time your authorization and consent for the collection and use of additional personal information. Upon your withdrawal of your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of your personal information previously carried out based on your authorization.
• Deregister your account. Currently, this Website does not have the function to register an account. If the account registration and management functions become available in the future, we will update the way to deregister the accounts and you may request to deregister your account at any time. After deregistration of your account, we will cease to provide you with products or services and delete your personal information upon your request, except as otherwise provided by laws or regulations.
• Obtain a copy of your personal information. Where technically feasible, we may also transfer a copy of your personal information directly to a third party designated by you upon your request if the data interface has been matched.
• Restraint the information systems from automated decision-making. At present, this Website does not use personal information for automated decision-making, and you may reject automated decision-making at any time and choose the option of not to target your personal characteristics if such decision-making function is adopted in the future. You have the right to request an explanation from the Company if a decision made through automated decision-making significantly affects your rights and interests, and you have the right to refuse the Company to make decisions only through automated decision-making.
• You have the right to ask us to explain to you how we process your personal information as well as this Personal Information Protection Policy if you do not really understand the contents of this Personal Information Protection Policy.
• You have the right to complain to the personal information protection and regulation authority about our collection or use of your personal information. You may contact the Cyberspace Administration of China or its local office at any time. 

If you wish to exercise any of the abovementioned rights with respect to your personal information or no longer wish to receive any communication from the Company, please send an email to: apac@bachmann.com.

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. Generally, we will reply within fifteen working days.

In principle, we do not charge for your reasonable requests, but we will, as appropriate, charge a cost fee for multiple repetitive requests beyond reasonable limits. We may refuse the requests that are unnecessarily repetitive, require excessive technical means (for example, requiring the development of a new system or a fundamental change in the current practice), pose a risk to the legal rights and interests of others, or are highly impractical (for example, involving the backup of information stored on disks).

We will not be able to respond to your request in the following circumstances:

• the circumstances which are related to the fulfilment of the obligations under laws and regulations by the controller of the personal information;
• the circumstances which are directly related to national security and national defense security;
• the circumstances which are directly related to public security, public health and major public interests;
• the circumstances which are directly related to criminal investigation, prosecution, trial and judgmentenforcement;
• the circumstances in which the controller of the personal information has sufficient evidence to prove that the personal information subjects have subjective malice or have abused their rights;
• the circumstances in which the significant legitimate rights and interests of a personal information subject or other individuals, such as life or property, are to be safeguarded, but the consent of such subject is difficult to be obtained;
• the circumstances in which responding to the request from a personal information subject would result in serious damage to the legitimate rights and interests of such subject or other individuals or organizations;
• the circumstances which involve trade secrets.

1. How we process children’s personal information

Our Website is primarily intended for adults. Where a child’s personal information is collected with parental consent, we will only use or publicly disclose such information as permitted by laws, with the express consent of the parent or guardian, or as necessary to protect the child.

Despite different definitions of a child under local laws and customs, we consider anyone under 14 years old as a child.

If we find that we have collected a child’s personal information without prior proven consent of the parents, we will try to delete the relevant personal information as soon as possible.

1. How this Policy will be updated

This Policy is subject to change as the functionality of the Website changes. We will not reduce your rights under this Policy without your express consent. We will post any changes we make to this Policy on this page. When we post a revised Policy on this Website, you will need to read the updated Policy and give your express consent again.

We will also keep an older version of this Policy on file for your review.