Momenta Privacy Policy

Welcome to Momenta.cn. Momenta Group appreciates your attention and interest in its products and your visit to this website.

Beijing Momenta Technology Co., Ltd. (hereinafter referred to as "we" or "us") respects your right to privacy and values the protection of your Personal Information. This Momenta Privacy Policy (hereinafter referred to as the "Privacy Policy") explains how we collect and process your Personal Information when you access the Momenta official website (https://www.momenta.cn) and use the related functions (the "Services"), how we protect your Personal Information, and how you may exercise your rights with respect to your Personal Information.

For the avoidance of doubt, this Privacy Policy does not apply to our processing of Personal Information for specific purposes in the context of providing specific products or services. For information about our practices regarding the processing of Personal Information in such scenarios, please refer to the privacy policy or equivalent document that we provide to you separately. This Privacy Policy also does not apply to software, products or services provided by third parties. If you access third-party software, products or services through a link on this Website, you will be subject to the relevant agreements or other documents of such third party, and the third party shall be responsible for the processing of your Personal Information in accordance with its relevant agreements or policies.

"Personal Information" herein refers to various information related to identified or identifiable natural persons recorded by electronic or other means, excluding information that has been anonymized. Personal Information generally includes a natural person's name, identification document number, contact address, residential address, account information, financial status, location tracks, etc. Personal Information includes Sensitive Personal Information as specified under applicable laws and regulations.

If you have any questions about this Privacy Policy, please contact us using the contact details provided at the bottom of this Privacy Policy.

This Privacy Policy informs you of the following information:

1. How we collect and use your Personal Information

2. How we use cookies and similar technologies

3. How we process minors' Personal Information

4. How we share and entrust the processing of your Personal Information

5. How we protect your Personal Information

6. How we store your Personal Information

7. Lawful basis for processing your Personal Information

8. Your rights as a data subject

9. Updates to this Privacy Policy

10. How to contact us

1. How we collect and use your Personal Information

When you approach us for business cooperation or make inquiries through the contact information shown on the Momenta official Website or otherwise, we will collect (depending on the circumstances) your contact information (e.g., phone number, email address, contact address) and other information you may voluntarily provide (e.g., name, name of your organization, specific inquiry, location, etc.), in order to contact you regarding business cooperation or to respond to your inquiry.

We may also use the above contact information to send you or your organization information about products and services that may interest you, or to solicit feedback or suggestions from you or your organization. If you or your organization do not wish to receive such information about our products and services or to provide feedback, you may decline at any time during the communication.

When you follow Momenta's public accounts on social media platforms such as Twitter, LinkedIn, WeChat and Zhihu, we will collect information about your account on the respective social media platform (usually including your nickname, avatar, gender, region and other public information) and records of your interactions with us.

When you submit inquiries to us through our Investor Relations webpage, in order to understand the identity of the submitter and the substance of the inquiry, and to contact the person submitting the inquiry, we may collect your name, company name, email address, country/region, and the inquiry content you proactively provide.

If you provide us with any Personal Information of any data subjects other than yourself, please bring this Privacy Policy to their attention. You hereby represent and warrant that you have obtained their consent or satisfied the conditions required under other lawful bases for the processing of Personal Information (in lieu of consent) before providing such Personal Information to us. By submitting such information to us, you confirm that you are entitled to provide and we are entitled to process the relevant Personal Information for the purposes set forth in this Privacy Policy.

In general, we will use your Personal Information only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect such Personal Information. However, where permitted by applicable laws and regulations, we may also process Personal Information for other purposes that are not incompatible with the purposes disclosed to you.

2. How we use cookies and similar technologies

When you visit the Momenta official Website, we may use Cookies to automatically collect certain technical information from your device, such as IP address, access time and how your device interacts with the Momenta official Website (such as pages visited or links clicked on).

Such information allows us to better understand the visitors to the Momenta official Website, such as where they come from and what content attracts them to the Website. We use this information for internal analysis and troubleshooting, and to improve the quality of the Momenta official Website's content. We also maintain appropriate logs to record the status of the Momenta official Website in order to comply with applicable laws and regulations.

Please note that if you disable cookies by changing your browser settings or use your browser's "anonymous browsing" feature function, cookies will no longer collect your Personal Information. For more information about the cookies we use on the Momenta official Website, please refer to our Cookie Policy.

3. How we process minors' Personal Information

We place great importance on the protection of minors' personal information. Our services are primarily oriented to adults. We do not knowingly collect personal information of minors. If you become aware that we have inadvertently collected personal information of a minor, please notify us immediately, and we will take steps to delete the relevant data as soon as possible.

4. How we share and entrust the processing of your Personal Information

In order to improve the efficiency of information processing, we may engage third parties (such as those who assist us in developing and operating the Momenta official Website) to process your Personal Information on our behalf. For third parties entrusted by us to process Personal Information, we will enter into strict confidentiality agreements with them and require them to process Personal Information in accordance with our requirements, this Privacy Policy, and the confidentiality and security measures required by applicable laws and regulations.

We will treat your information with a high duty of diligence. Except as expressly provided by laws and regulations, in principle, we will not share your information with any third-party company, organization or individual without your separate consent. You acknowledge and understand that we may share your Personal Information with our affiliates and third parties (such as authorized cooperation partners). At present, third parties include the following categories:

In the event of any change, merger, acquisition, reorganization, or liquidation involving the transfer of Personal Information, we will require the new company or organization holding your Personal Information to continue to process your Personal Information in accordance with this Privacy Policy. If the new company or organization holding your Personal Information needs to use your Personal Information for purposes not stated in this Privacy Policy, the new company or organization will obtain your consent in accordance with applicable laws and regulations.

We may disclose your Personal Information to relevant competent law enforcement authorities, regulatory bodies, government agencies, courts or other third parties where we believe such disclosure is necessary to: (1) comply with applicable laws or regulations; (2) exercise, establish or defend our legal rights; or (3) protect the vital interests of you or any other person.

We may cooperate with third-party service providers in specific fields to provide services to you. We may share your Personal Information with such third-party service providers, and will ensure that they process your Personal Information in accordance with our instructions and the purposes and requirements set forth in this Privacy Policy, and adopt appropriate confidentiality and security measures to safeguard data security. For example, we may disclose information collected through the Investor Relations webpage to professional service providers such as law firms and accounting firms in order to respond to and process your inquiries; we may disclose contact information you provide to us to logistics service companies to arrange the delivery of event gifts.

5. How we protect your Personal Information

We adopt appropriate technical and organizational measures to protect the Personal Information we collect and process. Such measures are applied based on the level of risk associated with your Personal Information. However, please be aware that the Internet is not an absolutely secure environment. If you discover that your Personal Information has been compromised, please contact us using the contact details provided in "How to contact us" immediately so that we can take corresponding measures.

In the event of any accident, force majeure event or other circumstances resulting in a breach of your Personal Information, we will make every effort to control the situation and promptly inform you of the cause, the security measures we have taken and the measures you may take, and other relevant information. In the event of a security incident relating to Personal Information, we will report to the competent authorities in accordance with the requirements of applicable laws and regulations, promptly investigate the problem, and take emergency measures.

6. How we store your Personal Information

Storage and Cross-border Transfer:

We store within China the Personal Information we collect and generate in the course of our operations in China. At present, we do not transfer the above information outside of China. If a cross-border transfer of Personal Information becomes necessary in the future, we will adopt necessary compliance measures in accordance with the requirements of applicable laws and regulations, including but not limited to obtaining your consent in accordance with applicable laws.

Retention Period:

We will store your Personal Information only for the period necessary for the proper business needs of our company (e.g., for the purposes of providing services to you or complying with legal, tax and financial requirements), except as otherwise provided by applicable laws or regulations. When there is no longer such business need to use your Personal Information, or the retention period required by applicable laws or regulations has expired, we will delete or anonymize your Personal Information.

7. Lawful basis for processing your Personal Information

If our processing of your Personal Information falls within the jurisdiction of a particular legal regime that requires us to have and disclose a lawful basis under applicable laws, the relevant lawful bases are set forth as follows:

Our lawful basis for collecting and using the Personal Information described in this Privacy Policy will depend on the Personal Information concerned and the specific context in which we collect it. The lawful bases on which we rely for each of the purposes for which we process your Personal Information are set forth below:

Purposes	Lawful basis (as applicable)
Collect contact information and other information you may voluntarily provide (via contact or your following of our public accounts)	If the contact relates to a product or service you have ordered or otherwise contracted for: necessary for the conclusion and performance of the relevant contract; In all other cases: Legitimate Interests to provide services or Consent.
Contact you with voluntarily provided information to respond to your inquiry
Contact you to provide promotion and marketing information about our products, or to determine whether you would like to establish a business relationship with us
Comply with regulatory, compliance, or legal obligations and/or requirements, or to assist law enforcement and government authorities as permitted or required by applicable laws	Necessary for the performance of legal obligations

8. Your rights as a data subject

We attach great importance to your control over your Personal Information, and will take every effort to protect your rights with respect to your Personal Information:

Right to Access and Copy Your Personal Information

You have the right to access and obtain a copy of your Personal Information, except as otherwise provided by applicable laws and regulations.

Right to Rectification and Supplementation

When you find that the Personal Information about you that we process is inaccurate or incomplete, you have the right to correct or supplement the inaccurate or incomplete information. You may contact us using the contact information set forth in this Privacy Policy to exercise your right to rectification and supplementation.

Right to Deletion

You may contact us using the contact information set forth in this Privacy Policy to request that we delete or cease using your relevant Personal Information. After the deletion request is processed, we will, to the extent technically feasible, complete the deletion or anonymization within a reasonable time, and will no longer retain any personally identifiable information unless otherwise required by laws and regulations.

In addition, you may contact us to request the deletion of Personal Information in any of the following circumstances:

(1) the purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve the processing purpose;

(2) we cease to provide the products or services, or the retention period has expired;

(3) you withdraw your consent;

(4) we process your Personal Information in violation of laws, administrative regulations or the agreement; or

(5) other circumstances as provided by laws and administrative regulations.

Where you delete information from our services, we may not immediately delete the corresponding information from the backup system, but will delete such information when the backup is updated.

Right to Withdraw Consent

With respect to processing activities of Personal Information conducted on the basis of your consent, you may change the scope of your consent or withdraw your authorization. Certain business functions and services require your information to be provided; once you withdraw your consent, we will be unable to continue providing the corresponding services to you and will no longer process the corresponding Personal Information. However, your withdrawal of consent will not affect the collection, processing and use of information previously conducted based on your consent.

Right to Deregister Your Account

Where our services involve account registration and you wish to deregister your account, please contact us in the manner described in this Privacy Policy. Upon receipt of your application, we will process it within the time limit prescribed by law. Before you deregister your account, we may verify your personal identity, security status, device information, etc., and you agree to authorize and cooperate with our account deregistration procedure. Once you have deregistered your account, we will delete or anonymize your Personal Information in accordance with this Privacy Policy, except as otherwise provided by laws and regulations.

Right to Transfer Personal Information

Where you request the transfer of your Personal Information to a personal information handler designated by you, and the conditions stipulated by the relevant laws, regulations and the requirements of the cyberspace administration authority are satisfied, we will provide a means of transfer in accordance with the applicable requirements.

Right to Restrict or Object to Processing

If you wish to restrict or object to our processing of your Personal Information, you may contact us using the contact information disclosed in this Privacy Policy and submit your request. Please note that, where you restrict or object to our processing of your relevant Personal Information, you may be unable to normally use some or all of the services we provide.

Response to Your Requests

To ensure security, when exercising the above rights, you will need to provide a written request, or otherwise prove your identity. We will first verify your identity before processing your request. For your reasonable requests, in principle we do not charge any fees; however, for repeated requests that exceed reasonable limits, we may, depending on the circumstances, charge a certain cost-based fee. We may decline requests that are gratuitously repetitive, require excessive technical means (for instance, requiring the development of new systems or fundamentally changing existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical (for example, involving information stored on backup tapes).

Please understand that, in any of the following circumstances and in accordance with the requirements of laws and regulations, we will be unable to respond to your above requests:

(1) matters directly related to national security or national defense security;

(2) matters directly related to public security, public health or significant public interests;

(3) matters directly related to criminal investigation, prosecution, trial and enforcement of judgments;

(4) where we have sufficient evidence that you have subjective malice or are abusing your rights (such as where your request would jeopardize public safety and the legitimate rights and interests of others, or where your request exceeds the scope that can be covered by general technical means and commercial costs);

(5) where responding to the personal information subject's request would cause serious harm to your legitimate rights and interests or those of other individuals or organizations;

(6) matters involving trade secrets;

(7) matters related to the performance of our obligations under laws and regulations; and

(8) other circumstances as provided by laws and regulations.

If we terminate our services or operations, we will notify you at least thirty (30) days in advance and will delete or anonymize your Personal Information after the termination of services or operations.

Please be aware that, in accordance with applicable laws, you may be entitled to other rights as a personal information subject, and we will take measures to safeguard your legitimate rights.

9. Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to legal, technical or business developments. When we update this Privacy Policy, we will notify you through appropriate means, depending on the significance of the changes. We will obtain your consent for any material changes to this Privacy Policy where required by applicable laws and regulations.

You can check when this Privacy Policy was last updated by referring to the "last updated" date displayed at the top of this Privacy Policy. If you continue to use the functions on the Momenta official Website or contact us through the contact information displayed on the Website, you are deemed to have accepted the updated Privacy Policy.

10. How to contact us

If you have any questions or concerns about this Privacy Policy or your Personal Information held by us, especially if you believe that our processing of your Personal Information has impaired your legitimate rights and interests, please contact us at dataprotection@momenta.ai. We will review the matter promptly and respond in a timely manner according to the applicable laws and regulations.

Generally, we will respond within twenty(20) business days. If you are not satisfied with our response, particularly where you believe our processing of your Personal Information has impaired your legitimate rights and interests, you may also lodge a complaint or report with the relevant competent regulatory authorities.