Sangfor Privacy Policy

Privacy Policy

Last Updated: February 20, 2025

Sangfor Technologies (Hong Kong) Limited and its affiliates (collectively, "Sangfor" or "We") attach great importance to the protection of our Customer's Privacy. This privacy policy (“Privacy Policy”) applies to the personal information that we process in relation to your business activities or any interaction with Sangfor websites, platforms, events, and business promotion, excluding situations where Sangfor processing personal information on behalf of our Customer during the process of product or service delivery. 

Sangfor takes your privacy concern seriously and is committed to strictly complying with applicable laws and regulations to take appropriate security measures to ensure your privacy in a secure and controllable status. To achieve this objective, Sangfor has prepared and published this Privacy Policy (hereinafter referred to as the "Policy") to explain how Sangfor collects, uses, shares, discloses and stores your personal information, how we protect your personal information and the rights to which you are entitled. 

This Policy will help you understand the following:

1. What personal information we collect
2. How we use your personal information
3. How we share, transfer, and disclose your personal information
4. How we store your personal information
5. How we protect your personal information
6. How you access and manage your personal information
7. Protection of minors
8. Updates to this Policy
9. Contact us

1. What personal information we collect

Personal Information referred in this Privacy Policy refers to any information processed during your interaction with our websites, platforms, events, and business promotion that i) relates to an identified or identifiable natural person; or ii) is defined as “personally identifiable information”, “personal information”, “personal data” or similar terms as defined under Data Protection Laws. The term does not include aggregate or de-identified data that is maintained in a form that is not reasonably capable of being associated with or linked to an individual and does not apply to other information that is excluded from applicable privacy and data protection law.

We collect your personal data in two ways: (i) Personal Data You Provide, and (ii) Automatically Collected Personal Data.

1.1 Personal Data You Provide

• Information When You Contact Us or Interact with Us: We collect personal data that you provide when you contact or interact with us, such as your name, address, email address, telephone number, account information of instant message. We may collect other information to process your request properly, such as questions, comments, feedback, or requests.
• Promotions and Products Interest: We collect personal data if you choose to join our email newsletter, participate in promotion event, marketing campaign or forums, or obtain free trials or evaluations of our products. You may provide us with personal information such as your name, email address, and/or telephone number, company name, your title and position, etc.
• Transaction Information: When you conduct any business activities with Sangfor on our Platform or with our employee, we collect information about the business activities, such as contact information, transaction item, payment information and other related transaction information.

1.2 Automatically Collected Personal Data

1.2.1 Cookies 

Cookies are small data files that are installed on your computer or mobile endpoint device when you visit a website. The content of a cookie can only be retrieved or read by the server that created it. We may record and use information about you through cookies, but the information recorded through cookies is only stored on your local device and only processed when you are using the relevant features/services of Sangfor Websites or Platforms. The specific purposes for which we use cookies include:

• To remember your identity for the purposes of logging in and completing authentication, e.g. cookies help us to recognize you as a registered user of Sangfor;
• To store your operational settings or preferences so that you can have a more efficient experience.
• To count and analyze your use of the Platform in order to provide you with a more thoughtful and personalized service, which may include, but is not limited to, customized pages, content recommendations, etc.

1.2.2 Other similar technologies

In addition to cookies, we may use other similar technologies to collect information automatically. For example, we may use browser web storage (including through HTML5), also known as local storage objects, for purposes similar to cookies.

1.2.3 Most web browsers have settings to block cookies and clear the browser’s web local storage, which you can manage or clear according to your preferences. Please note that if you set to block the operation of cookies or other similar technologies, you may not be able to enjoy an optimal experience of the related services and the usability of certain features may be affected.

2. How we collect and use your personal information

We may process your personal data for the following purposes:

• To provide you with the service of Sangfor websites and platforms to help you conduct business with Sangfor.
• To respond to your inquiries.
• To process and complete transactions, and send you related information, such as purchase confirmations and invoices.
• To send promotional communications, such as providing you with information about our products and services, newsletters, offers, promotions, and events.
• To monitor and analyze usage and activities in connection with our websites and platforms for marketing or advertising purposes.
• To investigate and prevent fraudulent transactions, unauthorized access to our websites and platforms, and other illegal activities.
• To complete your requests related to an event held or sponsored by us, such as completing the registration to the event, enable your participation, access to the event activities, book travel accommodations, purchase an event ticket, and other marketing purposes.
• To comply with our legal obligations and to maintain the security of our website, content, and products.
• For other purposes for which we obtain your consent, or for any other purpose disclosed at the time of collection.

And please note that, in accordance with applicable laws, we may collect and use relevant personal information without your authorization or consent under the following circumstances:

• It is related to the performance of our obligations specified by laws and regulations.
• It is directly related to national security and national defense security.
• It is directly related to public safety, public health, or significant public interests.
• It is directly related to criminal investigation, prosecution, trial, or judgment execution.
• It is for the purpose of safeguarding the life, property, or other significant legitimate rights and interests of you or other individuals while it is difficult to obtain your consent.
• The personal information involved is disclosed to the public by you.
• It is necessary to execute and perform the contracts or agreements between you and us.
• The personal information is collected from the information disclosed to public legally, such as through legal news reports, government information disclosures, or other channels.
• It is necessary to maintain the operational security and stability of our products or services, such as discovering and handling the failure of our products or services.

3. How we share, transfer, and disclose your personal information

3.1 Sharing

We provide your personal data to service providers, technical supporter, and other third parties to support our websites, platforms, events and other business activities, which are bound by obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them. More specifically, during your access to Sangfor's websites, the following third parties may engaged in data processing activities for the corresponding purposes:

Under the following circumstances, We may also access, preserve, and share your personal data with third parties when required by law or if we have good faith that:

• It is for purposes related to national security and national defense security.
• It is for purposes related to public safety, public health, or major public interests.
• It is for purposes related to criminal investigation, prosecution, trial, or judgment execution.
• It is for the purpose of safeguarding the life, property, or other significant legitimate rights and interests of you or other individuals while it is difficult to obtain your consent.
• The personal information disclosed is from the information collected from legally publicly disclosed information, such as through legal news reports, government information disclosures, or other channels.
• It is necessary to maintain the operational security and stability of our products or services, such as discovering and handling the vulnerability or failure of our products or services.

4. How we store your personal information

Data collected and processed by Sangfor will be retained in Sangfor's data server for a period which is necessary to make transaction with you or to provide business related support for you, unless a longer retention period is required and/or permitted by applicable laws, or necessary to fulfill the purposes of use agreed upon by Sangfor and you.

The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in to locations where we or our third-party service providers have operations.In the event of a cross-border transfer, we ensure that the personal data is transferred to countries recognized as offering an adequate level of protection, or the transfer is made pursuant to appropriate safeguards, such as standard contractual clauses adopted by competent data protection authority.

5.How we protect your personal information

5.1 Sangfor attaches great importance to your information security. We use various technical security measures to protect the information against unauthorized access, use, disclosure, abuse, alteration, destruction, or loss, for example, we provide secure browsing on the Platform using the HTTPS protocol; we use encryption technology to increase the security of user information; and we use trusted protection mechanisms to prevent malicious attacks on user information. In addition, we establish user information security management systems and work processes to strictly control access to user information; restrict the permissions of the staff having access to personal information and provide them with training relating to security and confidentiality; and regularly conduct personal information security risk assessments and promptly handle related risks, to continuously improve our ability to protect the security of personal information.

5.2 In addition to our obligation to protect your personal information, you are also responsible for the appropriate use and safekeeping of information relating to your account for using Sangfor Websites and Platforms (hereafter referred to as "Sangfor Account"), so please set a password with a high level of complexity in order to maximize account security. If you identify that anyone is using your Sangfor Account without your authorization, you shall immediately report this to the contact person who has assigned the Sangfor Account access to you or contact us to assist you in stopping the unauthorized use.

5.3 In the event of a personal information security incident (information leakage or loss), we will, in accordance with applicable laws and regulations, promptly inform you of the basic information and possible impact of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and the remedies for you in a reasonable manner. We will promptly inform you of the incident-related situation by email, letter, phone call, online push and notification, etc. If it is difficult to inform the data subject separately, we will take a reasonable and effective way to make a public announcement. In addition, we will report our handling of the personal information security incident in accordance with the requirements of regulatory authorities.

5.4 THOUGH WE WILL USE OUR RESONABLE EFFORTS TO TAKE REASONABLE MEASURES TO PROTECT THE SECURITY OF YOUR PERSONAL INFORMATION, THERE ARE NEITHER COMPLETELY PERFECT SECURITY MEASURES NOR UNBREAKABLE SERVICES, PRODUCTS, WEBSITE, DATA TRANSFER, INFORMATION SYSTEM OR NETWORK CONNECTION IN THE EVENT OF ANY UNAUTHORIZED ACCESS TO, PUBLIC DISCLOSURE OF, UNINTENTIONAL ALTERATION OF, OR DESTRUCTION OF INFORMATION DUE TO A BREACH OF OUR PHYSICAL, TECHNICAL, OR MANAGERIAL SAFEGUARDS, WHICH RESULTS IN DAMAGE TO YOUR LEGAL RIGHTS AND INTERESTS, WE WILL ASSUME THE RESPONSIBILITIES AND LIABILITIES ARISING THEREFROM. IN THE EVENT OF ANY USER INFORMATION LEAKAGE, LOSS, OR OTHER SECURITY INCIDENT ARISING OUT OF YOUR DISCLOSURE OF THE PRODUCT OR SERVICE ACCOUNT AND PASSWORD TO A THIRD PARTY, YOUR BREACH OF THE RELEVANT PRODUCT OR SERVICE USE AGREEMENT, OR OTHER REASONS ATTRIBUTABLE TO YOU, OR HACKING, INTRUSION OF COMPUTER VIRUSES, OR OTHER REASONS ATTRIBUTABLE TO THIRD PARTIES, OR FORCE MAJEURE, YOU ACKNOWLEDGE THAT SANGFOR SHALL NOT BEAR ANY DIRECT OR INDIRECT LOSS OR LIABILITY ARISING THEREFROM.

6. Your personal information protection rights

Under applicable data protection laws, you may have the following data protection rights:

6.1 You have the right to access and manage your personal information processed by Sangfor.

6.2 You have the right to demand the rectification of any incorrect or inaccurate personal data we hold with respect to you.

6.3 You have the right to object to processing of your personal data, or ask us to restrict processing of your personal data..

6.4 You may also request us to delete your relevant personal information under the following circumstances:

6.4.1 Our processing or authorized processing of relevant personal information violates applicable laws and regulations.

6.4.2 We collect and use your personal information without your express consent.

6.4.3 Our processing or authorized processing of relevant personal information seriously breaches the relevant agreement.

6.5 You have the right to withdraw your consent previously made and relating to the processing of your personal data with future effect. However, such withdrawal of consent does not affect the legitimacy of any processing operations previously executed. To exercise any of the above rights, please contact us by following the instructions available in the Section 9 "Contact Us" in this Privacy Policy.

6.6 Response to your request

6.6.1 When you claim the said rights, we may require you to submit a written request and may verify your identity. In principle, we do not charge a fee for your reasonable requests, but we will charge a certain cost for repeated requests that exceed reasonable limits, as appropriate. We may reject requests that are repeated for no reason, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legitimate rights and interests of others, or are highly impractical (for example, involving the backup of information stored on tapes).

6.6.2 To ensure security, you may need to submit a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

6.6.3 Under the following circumstances, we will not be able to respond to your request:

6.6.3.1 It is related to the performance of your obligations specified by laws and regulations.

6.6.3.2 It is directly related to national security and national defense security.

6.6.3.3 It is directly related to public safety, public health, or major public interests.

6.6.3.4 It is directly related to criminal investigation, prosecution, trial, or judgment execution.

6.6.3.5 We have sufficient evidence that you have subjective malice or abuse of rights.

6.6.3.6 It is for the purpose of safeguarding the life, property, or other significant legitimate rights and interests of you or other individuals.

6.6.3.7 Response to your request will cause serious damage to the other legitimate rights and interests of related individuals or organizations.

6.6.3.8 It involves trade secrets.

7. Protection of minors

7.1 Our Products and Services are provided mainly to adults. We attach great importance to the protection of personal information of minors. If you are a minor, you must ask your parent or other guardians to carefully read this Policy and you may use our products or services or provide information to us after obtaining the consent of your parent or other guardians.

7.2 In the case of the collection of personal information of minors who use the Platform with the consent of their parents or other guardians, we will only process the relevant information as permitted by law, with the express consent of the parents or other guardians, or as necessary for the protection of the minors.

7.3 In the event that Sangfor identifies any collections of personal information of minors without obtaining verifiable consent of their parents or other guardians, we will seek to obtain valid consent from their parents or other guardians or delete the relevant personal information as soon as possible.

8. Updates to this Policy

We may revise and update this Policy from time to time according to changes in the management and operation of the Platform or the processing of personal information. If the update of this Policy may result in any material reductions of your rights under this Policy, or involves any changes of important regulation such as expanding the scope of our processing activities, we will notify you to check the updated Policy by posting a notice in a prominent position on the page of this Platform, popping up, or sending an email or other reasonable means. Your continued use of the Platform under the above circumstances constitutes your understanding and acceptance of the updated Policy.

9. Contact us

If you have any questions about this Policy or other matters related to the your interactions with Sangfor, or have any comments or suggestions, you may contact Sangfor by sending an email to privacy@sangfor.com We will review the information you submit as soon as possible upon receipt and will provide you with timely feedback after your demand is clarified.