Users: It refers to individuals or organizations that purchase SANGFOR products or services, from fields like government institutions, educational institutions, financial institutions, enterprises, etc.

User Information: It refers to account that You register to use SANGFOR products or services and account information (such as your name, company, email address, phone number, etc.) that you provide to use SANGFOR products or services or is collected by SANGFOR.

Business Data: Different from user information, it refers to the data that are uploaded, downloaded or distributed through SANGFOR products or services by SANGFOR customers or the data processed via SANGFOR products or services.

Legal Notice

• 1. To be able to use SANGFOR products and enable SANGFOR to provide better network security and cloud computing solutions, You authorize SANGFOR to legitimately collect, use, transfer, share and process Your information, including device information, personal information and business data.
• 2. To ensure basic operations and maintenance services through SANGFOR products or services, certain features of SANGFOR product may collect device information and some personal information. For example, SANGFOR enterprise-level security products and services need to collect such information as operating data of devices, IP address, unknown URL, vulnerable webpage browsing history, unknown email sender and recipient, to identify and protect your network and devices from viruses and attacks.
• 3. As the owner of information set forth above, you should obtain consent from your users to ensure legality of information source. Notice that You shall have your own privacy policy accepted by your users if You provide services to them via SANGFOR products or services and your business data are owned by You. SANGFOR collects, uses, transfers, shares and processes the information set forth in this Legal Notice and Privacy Policy by complying with the aforementioned terms.

Privacy Policy

SANGFOR respects and protects Your data and treat the data with prudence. When You use SANGFOR products or services, we shall collect, process, share, transfer and disclosure your information. Please read and understand the following privacy policy:

• 1. ELIGIBILITY
• 2. COLLECTION AND USE OF USER INFORMATION
• 3. USER INFORMATION STORAGE
• 4. USER INFORMATION MANAGEMENT
• 5. USER INFORMATION PROTECTION
• 6. SHARING, TRANSFER AND DISCLOSURE OF USER INFORMATION
• 7. PRIVACY POLICY UPDATE
• 8. AFTER-SALE SERVICES AND OTHER TERMS

1. ELIGIBILITY

1.1 This Privacy Policy is applicable to SANGFOR products or services. Products and services provided by SANGFOR may contain links or information from third parties. The third party may have its own privacy policy. Please read it carefully before providing personal information. This Privacy Policy is not applicable to the acts conducted by third party to collect USER information.

1.2 If You purchase SANGFOR products such as SANGFOR aCMP, SANGFOR HCI, SANGFOR Branch Business Center (BBC), this privacy policy is also applicable to involved SANGFOR software. Since login pages of those products are the unified entry to the involved SANGFOR software, You agree to that the policy is applicable to those software involved in SANGFOR HCI and BBC systems.

Notice that You shall have your own privacy policy accepted by your users if You provide services to them via SANGFOR products or services and your business data are owned by You.

2. COLLECTION AND USE OF USER INFORMATION

SANGFOR provides diverse and comprehensive services to users. As business scenarios vary, we may need to collect and use a variety of types of data to ensure our services, including device and personal information.

2.1 Device Information

SANGFOR invites You to join to User Experience Improvement Program to help us improve product performance. Therefore, SANGFOR needs to collect your device information. Device information is any information that SANGFOR collects but cannot identify an individual or does not disclose business-related confidential data:

• 2.1.1 Device version information such as version, gateway ID; Device hardware information such as CPU, memory and disk.
• 2.1.2 Configurations like various configurations, physical and virtual devices and their status, enabled or disabled status of features, and resource usage.
• 2.1.3 Admin logs that record admin operations like login, click, search.
• 2.1.4 Device error information like black box, dump and stack information, unknown URLs and applications, etc.
• 2.1.5 Network security logs and relevant files such as content security logs, Web application protection logs, program files, suspicious traffic, etc.

This category of system information is also required by similar service providers or vendors, collected and uploaded by the system, so as to provide relevant features, upgrade system, improve user experience, meet user requirements, improve security, etc. The storage, usage and transmission of device data will not put Your identity data or personal information at risk.

2.2 Personal Information

SANGFOR collects data regarding Internet access activities to provide You online update and SANGFOR Neural-X services to constantly update products and improve performance, for the purpose of offering better products and services. Personal information refers to the information that is collected via email or other means and can be used to identify an individual or reflects activities of an individual with combination of other information. Personal information includes name, birth date, ID number, biometrics, address, contact information, account and password, property information, credit information, personal whereabouts, accommodation information, health information, transactions, etc. SANGFOR may collect personal information in the following scenarios:

• 2.2.1 You and authorized third party need to provide some necessary information for authentication or communication when purchasing, registering and using the products and services,

  including but not limited to address, WeChat name, WeChat OpenID, company name, contacts, phone number, email address, etc.

• 2.2.2 SANGFOR may collect, store, transmit and use your online behavior data to provide services according to your business's requirements.

  Specifically, to safeguard the network security of your company and prevent against virus and attacks, enterprise security products such as NGAF may enhance security capabilities by analyzing security logs and online activity logs of your company. To realize the aforementioned product functions and service targets, SANGFOR needs to collect the following personal information of your staff: network appliance settings (source IP address), unknown URL, browsing history of suspicious website, unknown executable file, unknown email sender, unknown email attachment (executable file), etc.

• 2.2.3 Other identity data for specific functions.

  SANGFOR promises to collect the least amount of information that SANGFOR needs and that the sole purpose of collecting data is for improving service, not directly or indirectly use (edit, employ, apply, develop) Your personal information for other purposes.

3. USER INFORMATION STORAGE

3.1 Any data produced and collected will be stored in your devices or your selected data center region.

3.2 In case of cross-border business that requires data collected within the territory to be transmitted to foreign organizations, the transmission will be performed in compliance with laws, administrative regulations and provisions of relevant regulatory institutions. SANGFOR will ensure proper protection for your data via anonymity, encryption and other methods.

3.3 For the sake of data safety and data backup, SANGFOR may store Your information and materials to servers of SANGFOR's affiliates.

4. USER INFORMATION MANAGEMENT

4.1. Based on legal obligations and commercial morality, SANGFOR promises that You have rights to manage information provided or expressed in this Privacy Policy, and SANGFOR will delete or modify Your information as per Your need. You may call us or send email to us or contact the Customer Services online and make Your requests.

4.2 You can require us to delete Your information in the following scenarios:

• 4.2.1 Our process of user information violates laws and regulations.
• 4.2.2 Your information is collected and used without your permission.
• 4.2.3 We severely violate the Privacy Policy with You on using and processing your information.

4.3 As previously expressed in this Privacy Policy, lack of certain personal information may conflict with the demand for registration or use of the Services, or even influence provisioning, update and optimization services provided by SANGFOR.

5. PERSONAL INFORMATION PROTECTION

5.1 SANGFOR will employ all kinds of security technologies, such as encryption, anti-intrusion, anti-virus, etc, to protect Your information from being accessed, used, disclosed, misused, changed or damaged by any unauthorized party.

5.2 SANGFOR will establish an information security management system and work process, and will provide training on security and confidentiality responsibility for personnels concerned.

5.3 SANGFOR promises that risk assessment will be carried out and You will be notified possible risks and obligations of the collection and use of personal information. If any term in this section is breached or might be breached, SANGFOR will immediately notify You.

5.4 Should any information security incident (information leakage, loss, etc.) occurs, SANGFOR will comply with the requirements of laws and regulations to inform You of the basic situation, potential influences, measures that we have taken or will take, suggestions for self-prevention and risk reduction, remedial measures, etc. in a reasonable and effective way.

5.5 Though SANGFOR spares no effort to employ reasonable measures to protect Your personal information, there is still possibility that personal information will be under risk. It is Your sole responsibility to prevent the service account and password from being disclosed and shared. SANGFOR is not liable to any direct or indirect loss caused by Your own offering or sharing of account, hack, computer viruses and acts of God.

6. SHARING, TRANSFER AND DISCLOSURE OF USER INFORMATION

6.1 Information Sharing

Except as expressly described as follows, in no case will SANGFOR disclose Your information.

• 6.1.1 You have agreed that only when You have granted the permission to SANGFOR,

  will SANGFOR share Your information with other enterprises, organizations or individuals.

• 6.1.2 Under certain circumstances, SANGFOR needs to disclose and provide all or part of Your personal information to SANGFOR's affiliate or authorized third party in cooperation of any kind:

  For better customer service and user experience, SANGFOR may need to cooperate with a third party and share part of your information between ourselves so as to diversify our service and satisfy your demand. For example, SANGFOR may upload and share the security logs with partners or providers in order to boost service quality and make our service more secure.

  SANGFOR will only share necessary user information to SANGFOR’s affiliate or authorized third party for purposes of provisioning or improving services and appropriate marketing, not for any other purposes. All parties involved will be restrained by this Privacy Policy when processing your information. SANGFOR will prohibit SANGFOR’s affiliate or authorized third party from processing the shared information for other purposes. If they intend to do so, they need to seek Your permission and agreement.

6.2 Information Transfer

We will not transfer your information to any other company, organization and individual except the following scenarios:

• 6.2.1 You have agreed that your information can be transferred to a third party.
• 6.2.2 In case SANGFOR encounters business or company reconstruction, merge or sale to a third party, SANGFOR may transfer all the collected information to the third party.

6.3 Information Disclosure

We will not disclose your information except the following scenarios:

• 6.3.1 You agree or choose to disclose your information.
• 6.3.2 Your information may be disclosed according to the requirements of the laws:

  Your information is required by law, lawsuit, judicial authority or government of the country where SANGFOR Software or services are provided.

• 6.3.3 It is public interest and reasonable

  for SANGFOR to disclose Your information, in order to comply with the terms and conditions of SANGFOR, retain control over SANGFOR’s operations, protect users or involved public’s interests of greater importance.

6.4 However, Your information can be shared, transferred and disclosed without Your permission in the following scenarios:

• 6.4.1 The information is concerned about national security and defense.
• 6.4.2 The information is related to public safety, public health and major public interest.
• 6.4.3 The information is associated with crime detection and investigation, prosecution, judge and execution of judgment.
• 6.4.4 When purpose of using the information is to protect your or others’ life and property safety and other major legitimate rights and interests but cannot get Your permission.
• 6.4.5 The information is disclosed by You out of your own accord to the public.
• 6.4.6 The information is collected from legitimate public sources, such as news reports, government information publicities.

7. PRIVACY POLICY UPDATE

7.1 We may revise, update the Privacy Policy irregularly.

7.2 Without Your permission, we will not restrict the rights You deserve according to this Privacy Policy. We will issue all revisions made to this policy on a dedicated webpage.

7.3 For major revisions, we will notify You through a noticeable notice (for example, we may publicize the notice on website to elaborate on the revision) or other possible channels and methods. Please check the latest update while visiting our website.

7.4 Major revisions in this Privacy Policy include but is not limited to

• 7.4.1 Major changes in control over the company, organizational structure, etc. such as change of business ownership due to merges and acquisitions, business adjustments and the like.
• 7.4.2 Major changes in service mode, such as the intent of processing user information, type of information, method of using information and so on.
• 7.4.3 Changes in main objects of information sharing, transfer and disclosure.
• 7.4.4 Major changes in your rights and way of exercising rights when participating in information processing.
• 7.4.5 Changes in the department responsible for user information security, contacts and channel for complaint.
• 7.4.6 Evaluation Report on User Information Security indicates high risks.

8. AFTER-SALE SERVICES AND OTHER TERMS

During the process of using SANGFOR Software, if You encounter any problem, You may call us or send email to us or contact the Customer Services online for technical support and information security consulting.

Terms of Use

This Terms of Use is between you (hereinafter “You” or “the USER”) and Sangfor Technologies Inc. (hereinafter SANGFOR) relating to the rights and liabilities of both parties on the use of licensed software and services (hereinafter “Service”). Please carefully read and thoroughly understand this Terms of Use. By using SANGFOR products or enjoying relevant Services, You agree to be bound by the terms here, and be bounded by updates, corrections or modifications to this Terms of Use.

1 GRANT OF LICENSE

STATEMENT OF INTELLECTUAL PROPERTY

All the intellectual properties of the software(hereinafter the “Software”) and pertinent materials are held by SANGFOR. The pertinent materials include but not limited to the following: text description, icon, symbol, table, color, UI design, interface frame, data, program (dll, Exe, etc), attached user guide, materials printed or in electronic format and any copy of this Software. All the intellectual properties are under the protection of the Protection of Computer Software Regulations in People’s Republic of China, copyright laws, public international rules and regulations, and other patents laws and regulations. You are only granted with the right to use this Software.

LIMITATIONS

You may not modify, adapt, tamper with, translate or create derivative works of the Software, or reverse-engineer decompile, disassemble, reverse-engineer or use any other ways to detect the source code of the Software. You may not sell, rent, lease, lend, redistribute, sub-license this Software to any entity or individual with or without profit, or grant to any person or entity the right to use the Software.

2. INFORMATION PROTECTION

By using SANGFOR products or enjoying relevant Services, You may be asked to provide relevant information. It depends on You whether to provide, disclose or upload information required by SANGFOR. But in most cases, failure to do that may make SANGFOR unable to cater to your needs, provide You with satisfying services, enhance user experience, or solve the problems You may encounter.

SANGFOR attaches great importance to USER's personal information and rights and will abide by the following provisions to protect USER's personal information. According to the variety and amount of services that You choose, SANGFOR may collect two categories of data, personal information and system information.

1.1 Personal information refers to data that can be used independently or together with other identity data to identify You, or other non-public data, including but not limited to the following:

Address, company name, name, phone number, email address, etc., that are necessary for SANGFOR or authorized third parties to identify and communicate with You, provided when You are purchasing, registering or using the Services.

other identity data for specific functions.

1.2 System information refers to the data required for chosen features during USER's use of SANGFOR Services, including but not limited to the following: a. system version information such as version number, authorization and gateway ID; b. hardware information such as CPU, memory and disk information of physical host; c. configuration information such as the amount and status of physical and virtual devices, status of features and usage of resources, d. error information such as blackbox, dump and stack information, unknown URL, unknown applications; e. network security logs and relevant files, such as content security logs, Web application protection logs, program files, suspicious traffic, etc.

This category of system information is also required by similar service providers or vendors, collected and uploaded by the system, so as to provide relevant features, upgrade system, improve user experience, meet demands of the USER and enhance security eventually. The storage, usage and transmission of system information will not put USER’s asset or personal information at risk.

2. The terms on using, protecting or disclosing information are applicable to USER identity data, and partially applicable to system information. All system information is subjective to relevant laws and regulations, general conventions of the industry, technology development, principles of public interest, etc. SANGFOR promises to collect the least amount of information that SANGFOR needs and that the sole purpose of collecting data is for improving service, not directly or indirectly use (edit, employ, apply, develop) USER’s personal information for other purposes.

3. Based on legal obligations and commercial morality, SANGFOR promises that You have rights to manage information provided or expressed in this Terms of Use, and SANGFOR will delete or modify Your information as per Your need. You may call Sangfor and request for contact change. As previously expressed in this Terms of Use, managing personal information may bring about demand conflicts with that from registration or use of the Services, or even influence provisioning, update and optimization services provided by SANGFOR.

4. SANGFOR will employ all kinds of security technologies, such as encryption, anti-intrusion, anti-virus, etc, to protect USER’s information from being accessed, used, disclosed, misused, changed or damaged by any unauthorized party. If any term in this section is breached or might be breached, SANGFOR will immediately notify You. Though SANGFOR spares no effort to employ reasonable measures to protect Your personal information, there is still possibility that personal information will be under risk. It is Your sole responsibility to prevent the service account and password from being disclosed and shared. SANGFOR is not liable to any direct or indirect loss caused by Your own offering or sharing of account, hack, computer viruses and acts of God.

Without your consent, SANGFOR will not disclose your data or information to any third parties other than SANGFOR. Sangfor may have to disclose information when required by law, legal process, litigation, and/or requests from public and governmental authorities.

6. For more information about how SANGFOR collects, uses, stores and protects your data and information and what rights you have, please read the Privacy Policy.

3. DISCLAIMER AND LIMITATION OF LIABILITY

1. In no event will SANGFOR be liable to You for any loss or damage caused by inapplicable uses except the express functionalities in the user guide (if any) of SANGFOR product.

2. You must comply with any additional terms and conditions applicable to any product, software or technology supplied by third parties for use in connection with, or incorporated within, SANGFOR product. SANGFOR is not responsible for and does not endorse, support or guarantee the quality, reliability or suitability of any such Third-party Software. Any reliance on or use of such Third-party Software is at your own risk.

3. You acknowledge and agree that when using our product, You may confront force majeure factors such as network failure, computer virus, hackers attack, emergencies and communication failure, etc. SANGFOR will bear no responsibility for your loss with any such factors.

4. If any term in this Terms of Use is breached, leading to third-party claims of payment, requirement or loss including lawsuit fees, it is You that are liable for paying for the loss to SANGFOR and its associated companies, and exempting them from any loss. SANGFOR reserves the right to take the actions including, but not limited to, terminating immediately the use of the software license, stopping furnishing associated services, restricting the use of the software and lodging a complaint.

4. AMENDMENT

SANGFOR reserves the right, in its sole discretion, to amend this Agreement from time to time without prior notice, in accordance of improvement of service quality and development of the Internet industry, adjustment of laws in the nation of jurisdiction, as well as the changing operating state and strategy of SANGFOR. Your rights and liabilities construed herein are subject to the provisions in the latest version of Terms of Use. The modified Terms of Use will be attached with the latest version of software and put on SANGFOR’s official website (www.sangfor.com). By accepting these terms, You acknowledge and agree with the updates and revisions made to this Terms of Use. SANGFOR recommends You to pay special attention to the terms, read it carefully and take the risks into consideration. The power of interpretation and amendment of the Terms of Use shall be vested in SANGFOR.