Hytera Application Privacy Policy

Hytera Communications Corporation Limited and its global affiliates (hereinafter collectively referred to as “Hytera”, “We”, “Us” or “Our” as required in context) deeply understand the importance of privacy to you and respect your privacy. The Hytera Application Privacy Policy (hereinafter referred to “this Policy”) Applies to Hytera products, Applications and services that display or provide links to this Policy.

Hytera and the Hytera Application & services respects and protects the privacy of all users who use the product and service. In order to provide you with more accurate and personalized services, Hytera and its product and services will collect, use and disclose your personal information in accordance with this Policy. Moreover, We will treat your personal information with a high degree of diligence and prudence. Except as otherwise provided in this Policy, We will not disclose or provide your personal information to third parties without your prior Approval. We will update this privacy policy from time to time.

This Policy sets forth how Hytera and its product, Applications and services collect, use, store, and share your personal information and the way We provide to you to the access to, updating, and to protect your personal information. We will, upon your written consent, collect your personal information according to this Policy and use your personal information for the purposes permitted by this Policy. Furthermore, We may inform you through supplementary statements or notices that provided in advance while conducting specific data collection regarding product, Applications or service.

This Policy describes:

1. How We Collect and Use Your Personal Information

2. How We Disclose Your Personal Information

3. Your Rights

4. How We Protect Your Information

5. Period of Data Preservation

6. Hosting and Back-end Infrastructure

7. International Transfers of Your Personal Information

8. Cookie Policy

9. How We Entrust the Processing, Sharing, Transfer and Public Disclosure of Your Personal Information

10. How We Handle the Personal Information of Minors

11. The Update of This Policy

12. Contact Us

While using the Hytera products, Applications or services, you may need to provide personal data. It is not mandatory for you to provide your personal data. However, if you do not provide certain personal data, in some cases, Hytera may not be able to provide you with certain products, Applications, services or responds to the issue that you have raised.

1. How We Collect and Use Your Personal Information

1.1 What personal information do We collect?

(a)The account registration information you provide as required by the Applications when registering for an account, such as registrant name, email, phone number, country, company name, job title;

(b)Your device information, such as International Mobile Equipment Identifier (IMEI), device type and mobile service provider (if Applicable), will be automatically collected when you download a Hytera App.

(c)During the process of downloading or launching of a Hytera App, We may ask you to allow Hytera to access your other personal information. In this case, unless you authorize us to access and obtain the requested information, We will not be able to provide you with the specific Applications and services listed below: - The device information, network information and geographic location is required in order to properly use the message push feature of Hytera App. - Access to storage is required in order to properly use the information download function provided by this application.

(d)System logs and maintenance: For operation and maintenance purposes, this Application and any third-party services may collect log files that record interaction with this Application (System logs) and use other Personal Information (such as the IP Address).

Upon your agreement, we may collect your personal information aforementioned for the purposes specified herein within the scope specified herein. By activating either authorization, you consent to our collection and use of your personal information under the respective program. Upon termination or revocation of any of your authorizations, we will cease to collect your personal information under the respective program. Your termination or revocation of an authorization does not affect the disclosure or use of your personal information based on your authorization prior to your termination or revocation.

You understand and agree that the following information does not apply to this Privacy Policy:

(a) the keyword information you entered when using the search service provided by this Application;

(b) Relevant information collected by this Application in relation to information posted by you in the Application, including but not limited to participation activities, transaction information and evaluation details;

1.2 How Do We Use Your Personal Information?

We may use your personal information collected in accordance with this policy for following purposes:

To help register you or your Hytera equipment;

To provide the services or features you need;

To understand the manner you use the products and services of Hytera, so that We can improve the quality of Our services and develop new products and services;

To release you important information such as product dynamics, order dynamics, lead dynamics, etc;

To evaluate and analysis markets, customers, products, and services (including inquiring your advice on Our products and services and carrying out the customer satisfaction surveys);

As well as the following: Hosting and back-end infrastructure, Content performance and functionality testing (A/B testing), Analytics, Managing contacts and sending messages, Platform services and hosting, Processing payments, User database management and Contacting the Users.

Any other use with your consent.

2. How We disclose your Personal Information

In the following circumstances, this Application will disclose or share your personal information in whole or in part in accordance with your personal wishes or as required by law:

(a) Disclose the information to third parties with your prior consent;

(b) When We must share your personal information with a third party in order to provide the products and services you have requested; If certain services are provided by a cooperative partner authorized by Hytera, Hytera will share or disclose your personal information with such partner as stated herein.

(c) Disclosure to third parties or administrative or judicial authorities in accordance with the relevant provisions of the law, or at the request of the administrative or judicial authorities. Where required by Applicable law or in response to legal process, Hytera may also disclose your personal information to relevant law enforcement or other governmental authorities, including but not limited to any competent law enforcement, regulatory, governmental, court or any third party where such disclosure is necessary to comply with Hytera's legal obligations under applicable law or to satisfy a judicial decision or at the request of, a governmental or regulatory authority, to make the necessary disclosures. In the event of a reorganization, merger or bankruptcy and liquidation proceedings of Hytera or an affiliate of Hytera, your personal information may also be disclosed to the counterparty. In addition, Hytera may also disclose your data where there is a legitimate need to do so, such as where such disclosure is necessary for the performance of a contract, to enforce, establish, or defend Our legal rights, to protect your vital interests or the vital interests of others, to prevent bodily harm or property damage, or to investigate possible or actual unlawful acts, and where such disclosure is appropriate.

(d) If you appear to violate the relevant Chinese laws and regulations or the relevant rules of this Application and services, your personal information may be disclose to a third party as required by relevant laws or regulations;

(e)In transactions initiated through the products or services, if any party to the transaction performs or partially performs the transaction obligation and makes a request for information disclosure, this Application has the right to decide to provide the user with the contact information of the counterparty and other necessary information required for signing a contract or performing a contract, in order to facilitate the completion of the transaction or the resolution of disputes.

(f) Other disclosures that the Application and Services deem appropriate in accordance with laws, regulations or website policies.

(g) In addition, as a multinational company, We may share your personal information among affiliates of Hytera and ensure that such sharing is done with your prior consent and in accordance with the personal information protection laws Applicable to Hytera and the affiliate of Hytera that receiving the data.

3. Your Rights

To refuse to receive information. We may use your personal information to send marketing information to you by Our services, email, or other means. If you do not want to receive such marketing information, you may refuse to receive such marketing information or unsubscribe for relevant services by clicking relevant option or linkage in Our advertisement or email. We may send you an announcement regarding services when necessary (for example, when a specific service needs to be suspended for system maintenance). You may not be able to refuse to receive such announcements that are relating to services and are not promotion information. Please note that Our affiliates and other data-receiving parties have their own data privacy policies. You will therefore, need to contact each of the above parties regarding the refusal to receive promotion information from them in accordance with their Privacy Policy. Please noted that, this Application contains a trading information provision and aggregation function, the pushing of relevant trading opportunities is a basic service of this Application and therefore should not be deemed as a marketing message.

To have access to, modify, update, and delete information. If you want to know what personal information of you has been collected and kept by Hytera or if you wish to update or request Us to delete your personal information that you have submitted through the website since such information is no longer accurate, outdated, or incomplete, you can send your request for modification or deletion by email to service@hytera.com. Upon receipt of your request, We will use your personal information that We have previously obtained to verify your identity, and after that, We will provide, update, correct, or delete your personal information in accordance with your request. For requests that are too frequent or clearly unreasonable, We reserve the right to take other action as We deem Appropriate.

To make a complaint about personal information. If you believe that your personal information has been misused or disclosed by Hytera without due authorization, or if you have any comments or complaints about Hytera’s practices regarding the collection and handling of your personal information, please send an email to service@hytera.com and We will deal with your relevant complaints and suggestions as soon as possible.

To withdraw your consent at any time. If allowed by applicable laws, you have the right to withdraw your consent at any time when Hytera processes your personal data on the basis of your consent. However, withdrawal of consent does not affect the legality and validity of Our processing of your personal data based on your consent prior to such withdrawal, nor will it affect Our processing of your personal information based on other Appropriate bases of legitimacy.

4. How We Protect Your Information

Hytera attaches importance to the security of personal information. We adopt Appropriate physical, managerial and technical safeguards to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. For example, We use cryptographic technologies to ensure the confidentiality of data; We use protection mechanisms to prevent malicious attacks on data; We deploy access control mechanisms to ensure that only authorized personnel have access to personal information; and We conduct training sessions to enhance employee awareness of the importance of protecting personal information. We will do Our best to protect your personal information, but please note that no security measure can be invulnerable. In the unfortunate event of a personal information security incident, We will, in accordance with laws and regulations, promptly inform you of: the basic situation and possible impact of the security incident, the measures We have taken or will take to deal with the incident, the suggestions you can make on your own to prevent and minimize the risk, and the remedial measures to be provide to you. We will promptly inform you of the situation related to the incident, and when it is difficult to inform the subject of personal information one by one, We will take a reasonable and effective way to make a public announcement.

5. Period of Data Preservation

The information and materials collected from you through the product and Applications of Hytera will be stored on the Application and/or the servers of its affiliates, such information may be transmitted to, accessed, stored, and displayed in your country, region or the location where the Application collects information and materials.

We will preserve your personal information during the period that is necessary for achieving the purposes specified herein, unless the period of data preservation is prolonged with your consent or as required by law. The periods of data preservation for different products and services under difference circumstances may be different.

The criteria We use to determine the data retention period include: the period of time for which personal information is required to be retained to achieve the business purpose, including the provision of products and services, the maintenance of corresponding transaction and business records, the control and enhancement of the performance and quality of products and services, the assurance of the security of the system, products and services, the response to possible inquiries or complaints from users, and the localization of problems, etc.; whether or not the user agrees to a longer retention period; and whether or not there are any special requirements for data retention in law, contract, and other special requirements for data retention, etc. As long as your account is necessary to provide services to you, We will retain your registration information. You can also choose to cancel your account, after you cancel your account, We will stop providing products and services based on the account, and delete your corresponding personal information without special legal requirements. We will preserve your registration information so long as your account is necessary for providing you with services. You may also choose to cancel your account, We will stop providing you with products and services under such account and, if no laws otherwise require, delete your relevant personal information after such account is cancelled by you.

6. Hosting and Back-end Infrastructure

The data collected by the Hytera App is generally stored in a database on the Amazon Cloud.

Amazon Web Services, Inc(AWS) Cloud Platform is a hosting and back-end service provided by Amazon.com, Inc. Personal data that may be processed by the Platform includes usage data; various types of data specified in this privacy policy.

Data Storage Location: Hong Kong, China

AWS Privacy Policy:https://aws.amazon.com/cn/compliance/

AWS implements and maintains technical and organizational security measures Applicable to AWS cloud infrastructure services according to the globally recognized security framework and certification, including ISO 27001, ISO 27017, ISO 27018, PCI DSS Level 1 and SOC 1, 2 and 3. These technical and organizational security measures are validated by independent third-party evaluation agencies, and are designed to prevent unauthorized access to or disclosure of customer content. AWS has been certified by Singapore Multi-Layer Cloud Security Standard for the Asia Pacific region (MTCS SS 584),

Level 3 (CSP). Multi-layer security (MTCS) is an operable Singapore security management standard (SPRING SS 584), which is based on ISO 27001/02 Information Security Management System (ISMS) standard.

7.International Transfers of Personal Data

As stated herein, Hytera may share your personal information We collected with Our global subsidiaries and authorized partners. Your personal information may be transferred to and processed in other countries. These countries may Apply different data protection laws than China (and, in some cases, your data may not be protected by law) . When transferring your personal information to other countries, We comply with the personal information protection laws applicable to both the transferor and recipient of the data and take appropriate measures to ensure that your personal information is protected. For example, in the case of transfers of personal information involving affiliates of Hytera located in the European Union, We implement the standard contractual clauses provided by the European Commission, which require Our global offices to protect and process personal information We collect from the European Union in accordance with European Union data protection laws.

8. Cookie Policy

We may use cookie, Web beacon, or similar technologies to collect the abovementioned information. Cookie is a small text file stored in the hard drive of your computer or terminal when you browse a website. We may use cookie for:

(1) providing you with customized contents or services at the Website;

(2) monitoring the use of the website;

(3) identifying you when you return to Our website;

(4) carrying out research so as to improve the contents and services of Our website.

In addition, We may also permit any third party (such as network analysis tool partner, advertising company, or advertising network) to set or visit their cookie or web beacon (also known as 1x1 pixel. gifs or action label)at the website.

You may reject cookie without restriction, but you probably cannot use certain functions of Our website or fully utilize the contents and services provided by Us if you do so. You may check the Help menu on your browser to understand how to change your cookie preference.

For more information, please refer to the Hytera Cookie Policy

(https://www.hytera.com/en/cookie.html).

9. How We Entrust Processing, Sharing, Transfer and Public Disclosure of Your Personal Information

Entrust Processing. Certain specific modules or functions of Our Services are provided by external vendors. For example, We may engage service providers to assist us with customer support. Companies, organizations and individuals with whom We have entrusted the processing of personal information will be subject to strict confidentiality agreements, Furthermore, these parties will be required to handle personal information in accordance with Our requirements, local personal information protection policies and any other relevant confidentiality and security measures.

Third party information sharing. We will not share your personal information with any companies, organizations and individuals outside of Our company unless We have your express consent. Currently, in order to ensure the realization of some independent functions and to enable you to use and enjoy more services and functions, We will embed third-party SDKs in Our Apps, and We will carefully evaluate the purpose of use of such SDKs and ask for your express consent to share your personal information:

SDK Name: Push Message SDK

Third party name: Daily Interactive Co., Ltd

Purpose of use: To provide message push technology services for App users

Personal information to be collected:

(1) Device information (including device identifiers (mainly the anonymous device identifier OAID), device brand, device model, and system version) Push SDK privacy policy link: https://docs.getui.com/privacy

10. How We Handle the Personal Information of Minors

Our products, Applications, Websites and services are primarily intended for adults. We will not intentionally collect any personal information from minors under the age of 14. Minors under the age of 14 should not submit any personal information with Our product or Applications without parental or guardian consent. In the event that We collect personal information from a minor with parental consent, We will only use or disclose this data as permitted by law, with the express consent of the parent or guardian, or as necessary to protect the minor. If We become aware that We have collected personal information from a minor without first obtaining verifiable parental consent, We will attempt to delete the data as quickly as possible.

11. The Update Of This Policy.

We reserve the right, at Our sole discretion and from time to time, to modify, amend, add to or delete from this Policy, indicating the date of the most recent update in the Policy, and such amendments will form part of this Policy. The updated Policy will be posted on Our official website, which you can visit to keep up to date with the latest Policy content. If such revisions result in a material reduction of your rights under this Policy, We will notify you by prominently displaying a notice on Our homepage or by sending you an e-mail or otherwise notifying you prior to the effective date of the revisions. We recommend that you re-read this Policy from time to time to be aware of changes.

12.Contact Us

If you have any doubt, advice, or suggestion, please send an email to service@hytera.com to contact Us. If you have any claims or problems about privacy and need to contact Hytera, please click here.

The party discloses its personal information, such as contact information or postal address. Please protect your personal information and provide it to others only when necessary. If you find that your personal information is leaked, especially if the Application username and password are leaked, please contact this Application customer service immediately so that the Application can take corresponding measures.

You have fully read and understood all contents of the Policy and hereby authorize Hytera to collect and process your personal information according to the Policy.

Last Updated June, 2024