This Privacy Policy is formulated by Glenfly Tech Co., Ltd. (hereinafter referred to as “we” or “us”) to govern the processing of your personal information. We understand the importance of your personal information and will make every effort to protect your personal information and privacy. This Privacy Policy is intended to help you understand our privacy practices, including what personal information we collect, how we use such information, and how we protect your personal information.

Please read this Privacy Policy carefully before using our products and services and make sure that you fully understand its contents, particularly the bolded sections. You may make appropriate choices in accordance with this Privacy Policy. Please do not use our website, WeChat service account, or other products or services until you have confirmed that you fully understand and agree to this Privacy Policy. If you do not agree with this Privacy Policy, we will be unable to provide our products or services to you normally. Please immediately stop accessing or using Glenfly’s relevant products or services.

Please note that this Privacy Policy does not apply to other third-party products or services that you access through our products and services (“other third parties” include your transaction counterparties, third-party websites, third-party service providers, etc.). Third-party services are subject to their own privacy policies. Before using any third-party service, you should fully understand the functions of the relevant product or service and its privacy policy.

If you have any questions about this Privacy Policy while reading it, you may contact us through the contact information provided at the end of this Privacy Policy. We will respond to your questions as soon as possible.

How We Collect and Use Your Personal Information

If you submit your resume to us through the “Careers - Join Us” section of the Glenfly official website (www.glenfly.com), the “Glenfly Recruitment” WeChat service account, third-party recruitment platforms, or other channels, you may use the recruitment system to upload your resume and express your intention to apply for a position. The specific types of personal information we need to collect may vary depending on the requirements of the position. We may collect relevant personal information, including your name, gender, age, contact address, educational background, mobile phone number, email address, work experience, and other information that you voluntarily provide. The specific information collected will be based on the information you provide and will be used for 【recruitment evaluation and recruitment process management】. If you refuse to provide such information, you will not be able to use the resume submission function of the recruitment system, but this will not affect your use of other functions of the recruitment system. During this process, we may communicate with you by telephone for interview invitations or other necessary communications related to recruitment activities. If you proceed to the interview stage, we will also collect relevant personal information through the “Job Applicant Registration Form” you complete, including but not limited to your name, gender, mobile phone number, email address, educational background, previous work experience, and other information you provide.

If you are a contact person of one of our partner organizations, we may collect relevant personal information, including but not limited to your name, telephone number, email address, address, job title, and company name. The specific information collected will be based on the information you provide and will be used for 【completing transactions and cooperation related to products and services】.

If you wish to obtain information about our products, you may use the contact information provided on the Glenfly official website to contact us by email. In this process, you will need to provide your name, telephone number, email address, and employer information so that we can review and verify your request before providing you with relevant product information.

How We Entrust the Processing, Share, Transfer, and Publicly Disclose Your Personal Information

We will not share or transfer your personal information to any company, organization, or individual, or publicly disclose your personal information, unless we have obtained your explicit consent.

To provide recruitment-related functions through the “Careers - Join Us” section of the Glenfly official website and/or the “Glenfly Recruitment” WeChat service account, we have engaged a third-party service provider, Beisen Cloud Computing Co., Ltd. (hereinafter referred to as “Beisen”), to develop and maintain the recruitment system. Beisen does not collect the resume information you submit. We recommend that you also read the “Beisen Recruitment Portal Privacy Policy” to understand how Beisen processes and protects your personal information. In addition, based on business needs, we may collect your resume and obtain your personal information through other recruitment platforms that we use.

To 【ensure that products purchased through us by your organization can be delivered smoothly, securely, and accurately for the purpose of completing product delivery】, when products are shipped through a third-party logistics company, we will disclose your personal information as the recipient, including your name, telephone number, and company address, to the logistics company we cooperate with. We will inform you of the name and contact information of the relevant logistics company at that time, and you may also contact it through its publicly available contact information. You acknowledge and agree that the relevant logistics company will inevitably have access to and use your personal information.

Exceptions to Consent

In accordance with applicable laws and administrative regulations, we may process (including collect, store, use, process, transmit, provide, publicly disclose, delete, etc.) your personal information without obtaining your consent in the following circumstances:

  • Where such processing is necessary for us to perform our statutory duties or obligations;
  • Where such processing is necessary for entering into or performing a contract to which you are a party, or for human resources management implemented in accordance with legally established labor rules and regulations and legally concluded collective contracts;
  • Where such processing is necessary to respond to public health emergencies, or to protect the life, health, and property of natural persons in emergency situations;
  • Where your personal information is processed within a reasonable scope for the purpose of conducting news reporting, public opinion supervision, or other activities in the public interest;
  • Where your personal information that you have voluntarily disclosed or that has otherwise been lawfully made public is processed within a reasonable scope in accordance with the Personal Information Protection Law;
  • Other circumstances stipulated by laws and administrative regulations.

How We Store Your Personal Information

Storage Location

In accordance with applicable laws and regulations, we will store your personal information collected and generated during our operations within the territory of the People’s Republic of China within the territory of the People’s Republic of China. If cross-border transfer is required, we will ensure that such transfer complies with the applicable laws and regulations governing the cross-border transfer of personal information.

Storage Period

We will retain your personal information only for the period necessary to provide the relevant products or services, unless a longer retention period is required or permitted by law. After the necessary retention period has expired, we will delete or anonymize your personal information, unless otherwise provided by applicable laws and regulations.

When determining the retention period of personal information and carrying out the relevant operations, we primarily consider the following criteria:

  • Completing relevant transactions with you or your organization and maintaining corresponding transaction and business records to respond to potential inquiries or provide other services to you or your organization;
  • Ensuring the security and quality of the products or services we provide to you or your organization;
  • When you request the deletion of your personal information, we will promptly delete or anonymize your personal information in accordance with applicable laws and regulations;
  • Other specific arrangements regarding retention periods, or specific requirements imposed by laws, regulations, or relevant competent authorities, such as retention periods required under the Cybersecurity Law of the People’s Republic of China and other applicable laws and regulations.

How We Protect Your Personal Information

We will use security measures to protect the personal information you provide and prevent unauthorized access, disclosure, use, modification, damage, or loss of data. We will take all reasonably practicable measures to protect your personal information. For example, we use encryption to protect the security of your information when transmitting sensitive information; we use trusted security mechanisms to prevent malicious attacks on data; and we implement access control mechanisms to ensure that only authorized personnel can access personal information.

The Internet is not an absolutely secure environment, and no product, service, or data transmission can guarantee 100% security. Nevertheless, we will make every effort to protect your personal information. In the event of a personal information security incident, we will promptly activate our emergency response procedures as required and make every effort to prevent the impact and consequences of such incident from expanding. If, unfortunately, a personal information security incident occurs, we will, in accordance with applicable laws and regulations, promptly notify you of the basic circumstances and possible impact of the security incident, the measures we have taken or will take, recommendations for you to independently prevent and reduce risks, and remedies available to you. We will promptly notify you of relevant information through email, letters, telephone calls, push notifications, or other means. Where it is difficult to notify each individual personal information subject, we will issue an announcement through reasonable and effective means. We will also proactively report the handling of personal information security incidents to the relevant regulatory authorities as required.

Your Personal Information Rights

We attach great importance to your ability to manage your personal information and will make every effort to protect your rights to know and decide how your personal information is processed, as well as your rights to access, copy, correct, supplement, transfer, delete, restrict the processing of, and withdraw consent or authorization regarding your personal information. If you wish to exercise any of these rights, please contact us through the methods provided in this Privacy Policy.

How We Handle the Personal Information of Minors

Our products and services are not directed toward minors. If we discover that we have collected a minor’s personal information without obtaining verifiable consent from the minor’s guardian in advance, we will make efforts to delete such information as soon as possible. If you are the guardian of a minor and have any questions regarding the personal information of the minor under your guardianship, please contact us through the contact information provided in this Privacy Policy.

Revision and Updates to This Privacy Policy

This Privacy Policy provides a truthful and comprehensive description of our personal information processing practices, and we will promptly update this Privacy Policy when any changes occur. When this Privacy Policy is updated, we will issue an updated version and notify you of the changes through pop-up notices or other appropriate means so that you can stay informed of the latest version.

For material changes, we will also provide more prominent notices, such as notifications by text message, private message, or special notices displayed when you browse our website, specifying the changes to the personal information protection policy, and will obtain your consent again.

Material changes to this Privacy Policy include but are not limited to:

1. Material changes to our service model, such as changes to the purposes or methods of processing personal information or the types of personal information processed;

2. Material changes to our ownership structure, organizational structure, or other significant aspects, such as changes in ownership resulting from business restructuring, bankruptcy, mergers, or acquisitions;

3. Changes to the primary recipients of shared, transferred, or publicly disclosed personal information;

4. Material changes to your rights relating to the processing of personal information or the manner in which such rights may be exercised;

5. Changes to the department responsible for personal information security, contact information, or complaint channels.

If you do not agree to the revised Privacy Policy, you have the right and should immediately stop using the Glenfly official website and the services we provide. If you continue to use the Glenfly official website or accept the services we provide, you will be deemed to have fully read, understood, and accepted the amendments to the relevant provisions of this Privacy Policy.

How to Contact Us

If you have any requests, questions, comments, or suggestions regarding this Privacy Policy or matters relating to your personal information, you may contact us at 【Support@glenfly.com】. Under normal circumstances, we will respond within 【15】 days. If you are dissatisfied with our response and believe that our processing of your personal information has seriously infringed upon your legitimate rights and interests, you may also file a complaint or report with the Cyberspace Administration of China, the Ministry of Industry and Information Technology, or other relevant authorities, or seek a resolution by filing a lawsuit with the competent People’s Court in 【Pudong New Area, Shanghai】, where Glenfly Tech Co., Ltd. is located.

 

Last Updated: July 24, 2026

Effective Date: August 1, 2026