Privacy Policy

Privacy Policy

Effective date: 2024-01-15

Dear user, CHC Navigation Technology Co., Ltd (abbreviated as CHCNAV). and its affiliates (hereinafter referred to as "Huace" or "we" collectively) attach great importance to the protection of your personal privacy. When you use the "CHC Cloud" website operated by us with the domain name cloud.huace.cn (including “CHC Cloud” WeChat applet, “CHC Cloud” PC client, "Aerial Survey Cloud" PC client, and mobile client, hereinafter referred to as "this Platform"), we will protect your personal information in accordance with the Privacy Policy (hereinafter referred to as "this policy") published on this Platform.

This policy is designed to help you understand what personal information we will collect, why we collect such personal information, and how we protect such personal information. We will collect and process your personal information in accordance with the Cybersecurity Law of the People's Republic of China, the Personal Information Protection Law of the People's Republic of China, the Data Security Law of the People's Republic of China, and other relevant laws and regulations, and provide you with services.

Normally, we only collect and process your personal information for the purpose of fulfilling the contract, providing services, or with your consent, unless otherwise stated in the specific services we provide. At that time, concerning the collection and processing of personal information, we specifically publish or explain other privacy policies related to the product or service. Please refer to the specific privacy policy. In addition, we may also explain to you our rules for processing your personal information through page notifications, pop-up prompts, information pushes, and other means. The personal information processing rules corresponding to the specific product or the business functions of service shall be subject to our notifications.

This Platform may contain links to third-party websites, third-party plugins, and other services (collectively referred to as "third-party services"). This policy is not applicable to third-party services connected to our services. Your use of the aforementioned third-party services (including any personal information you provide to the third party) will be subject to the terms and conditions of the third party service and private policy (other than this Policy). Please carefully read the relevant terms and conditions of the third party for specific provisions. Please protect your personal information properly and only provide it to a third party where necessary.

Before interacting with us, please carefully and completely read and understand this Policy, especially the bold and/or underlined parts. If you do not agree with it, please do not use this Platform or provide us with your personal information.

This Policy will help you understand the following content:

1.How We Collect and Use Your Personal Information

2. How We Use Cookie and Similar Technologies

3. How We Share, Transfer, Publicly Disclose, and Entrust to Process Your Personal Information

4. How We Store and Protect Your Personal Information

5. Your Rights

6. How We Process the Personal Information of Minors

7. Update of this Policy

8. Contact Us

9. Miscellaneous

1.How We Collect and Use Your Personal Information

For the convenience of your understanding, we will list the following business functions, processing purposes, and the collection and use of personal information as follows:

1.1 Account Registration and Login

1.1.1 Given that all functions and services on this Platform can only be used after you register and log in with your account, you are unable to use them if you have not registered or logged in to this Platform. When you use the services on this Platform, we will require you to register and log in with your account on the CHC Cloud platform.

1.1.2 We implement a unified management of user accounts, and the account information provided by you when opening your account will be automatically synchronized to this Platform when you use Huace (including the operating entity of this Platform and all affiliated parties) products or services. If you have opened a Huace account through other channels before, you can directly enter the existing account information in the CHC Cloud platform to complete the login without the need to register again.

1.1.3 If you register for the first time, you can complete registration and login through three means: (a) mobile login; (b) WeChat login; (c) email login. When you register and log in to this Platform, you need to provide us with your personal information as follows:

Collection and use purposes	Necessary personal information	Non-essential personal information
To complete the registration and login of the Huace account	Mobile phone number, user name, password, WeChat user name, mailbox	/

We will send a verification code to the mobile phone number you provide, the mobile phone number bound with WeChat, or your email to complete the authentication of your account identity.

1.1.4 If you already have a Huace account, there is no need for registration again. In addition to the methods described in Clause 1.1.3, you can also log in directly through your account information. When you log in to this Platform, you need to provide us with your personal information as follows:

Collection and use purposes	Necessary personal	Non-essential personal
To complete the login of the Huace account	Mobile phone number, user name, mailbox, password	/

1.2 Value-added Services for Membership

1.2.1 In principle, when you upgrade your membership or purchase our membership value-added services, we will not collect any additional personal information from you.

1.2.2 When you request us to produce an invoice based on the payment amount for purchasing our membership value-added services, you need to provide us with the following personal information:

Collection and use purposes	Necessary personal information	Non-essential personal information
Invoicing	Name and mailbox	/

1.3 Main Functional Services of Cloud Drive

1.3.1 When you use the main cloud drive functional services provided by this Platform, the specific personal information we need you to provide is as follows:

Collection and use purposes	Necessary personal information	Non-essential personal information
Device management of CHC Cloud, Aerial Survey Cloud, and Unmanned Ship Cloud;Data storage and sharing	Device SN, name, model, and video SN	Channel number
Background authentication of flight permission authorization service	Device SN, name, ID card number and mobile phone number	Gender, name of work unit and current address
Maintenance application service for Aerial Survey Cloud	Name, mobile phone number, region, detailed address	Postal code

1.3.2 Some of the above services require you to authorize us to obtain the read-write access/storage permissions of local files. You may cancel the permissions at any time through the webpage settings on your device to stop us from collecting your information. Afterwards, you may not be able to use the upload function. Although this does not affect your normal use of other business functions that are not based on the above permissions, it may not be convenient for us to provide you with better and more efficient services. Please consider carefully.

1.4 Workgroup Management Function

When you use the workgroup management function provided by this Platform, the specific personal information we need you to provide is as follows:

Collection and use purposes	Necessary personal information	Non-essential personal information
Monitoring of collaborative work among team members, implementing personnel and personal risks	Name and mobile phone number	/

1.5 Road Editing Services

When you use the workgroup management function provided by this Platform, the specific personal information we need you to provide is as follows:

Collection and use purposes	Necessary personal information	Non-essential personal information
Activation and use of road editing activities	Device SN	/

1.6 Huace Customer Service Center

Huace Customer Service Center provides you with comprehensive management of personal information, cloud drive information, and commercial information as well as use channel. The personal information you may provide to us through Huace Customer Service Center is as follows:

Collection and use purposes	Necessary personal information	Non-essential personal information
Management of user and account information	Real name, mobile phone number, mailbox, username, password, nickname	Industry, company, and user avatar
Adding or modifying address	Name, mobile phone number, region, detailed address	/
Invoicing	Name and mailbox	/

1.7 Ensuring Service Security, Optimizing and Improving Service Purposes

We may automatically receive and record the following to ensure the security and continuity of this Platform, identify abnormal account status, more accurately solve the problems you encounter while using our services, improve and optimize our service experience, prevent, detect and investigate fraudulent acts, acts undermining security, illicit acts or acts violating our agreement with you, our policies or rules, and protect the legitimate rights and interests for you, us, our partners, and the general public:

(a) Device and network information, which refers to the information on your browser and computer, and which we use for conducting internal analysis and improving service quality and relevance for you.

(b) Log information: We need to retain necessary logs to record the operational status of our service website portal for the purpose of complying with applicable data protection laws.

1.8 Collection of Your Personal Information through a Third Party

You know and agree that in order to provide you with better services, or to jointly provide services to you, we have collected your address information through a third party in accordance with laws and regulations, agreement with you, or with your consent, and may also collect other personal information about you or others through the third party. We will use the same protective means and measures as we have taken to process the user personal information to protect personal information indirectly obtained from the third party.

1.9 Device Permission Call

1.9.1 In the process of providing services, we may apply to the system for the system device permissions of your device to ensure that you can use the service functions normally, and you can cancel the authorization at any time in your device. Your canceling authorization will prevent you from using the relevant business functions, but it won't prevent you from using other business functions.

1.9.2 The current call of the system privacy permissions by this Platform is as follows:

Device permissions	Use purposes
Wireless network	Network connection for various business functions
Access to local pictures and videos of the user	Repairing the device, serving the customer and describing the failure picture and video
Access to the user's local documents	Real-name authentication of flight permission authorization service, document submission by the user
Obtaining the location	Obtaining the current location of device
Making a call	Calling the dial plate

1.10 Rules for the Use of Personal Information

1.10.1 We will use your personal information in accordance with the purposes and means disclosed in this Policy. If we need to make changes to the above purposes and types of information, or if we use the information for other purposes not specified in this Policy, or if we use the information collected based on specific purposes for other purposes, we will obtain your prior consent in accordance with the data protection law.

1.10.2 After collecting your personal information, we will timely use technical means to desensitize and process the data where necessary to ensure the security of your information. Please be aware that we have the right to mine, analyze, and utilize the anonymized database (including commercial use), and have the right to conduct statistics of service use and share statistical information with the public/third parties that cannot identify or associate your identity.

2. How We Use Cookie and Similar Technologies

2.1 When you use this website, we store small data files called Cookies on your computer or mobile device. Cookies typically contain identifiers, site names, and some numbers and characters. We use such information to determine whether you have logged in, and improve service quality and optimize user experience at the same time. If you do not want your personal information to be saved in cookies, you can configure your browser and choose to disable the Cookie function.

2.2 In addition to Cookies, we may also use technologies similar to Cookies to improve your user experience when you use this website.

2.3 We will not use Cookies for any purpose other than those stated in this Policy. The main types of Cookies currently operated on this website and their use purposes are as follows:

Cookie name	Cookie owner	Purpose	Duration	Function
CHC_TOKEN_REF	CHCNAV	Session State Management	30 days	Refreshing the token
CHC_TOKEN	CHCNAV	User login status	2 hours	Obtaining the user token

You can manage or delete Cookies according to your preferences. For details, please refer to aboutcookies.org.

3. How We Share, Transfer, Publicly Disclose, and Entrust to Process Your Personal Information

3.1 Sharing

3.1.1 Unless with your prior separate consent or in compliance with other laws and regulations, we will not share your personal information with any third party other than Huace, except for the processed information which cannot be identified for specific persons and cannot be restored.

3.1.2 Some of our services may involve sharing some of your personal information with partners to provide better customer service and user experience. We will only share your personal information for lawful, legitimate, necessary, specific, and definite purposes, and only share personal information necessary for providing services. Unless otherwise authorized by you or required by laws and regulations, our partners have no right to use the shared personal information for any other purpose.

3.1.3 We will investigate the data security environment of companies, organizations, and individuals with which and whom we share personal information, sign strict confidentiality agreements with them, and require them to take confidentiality and security measures to handle personal information in accordance with law.

3.2 Transfer

3.2.1 We will not transfer your personal information to any other company, organization, or individual other than Huace, except under the following circumstances:

（a）Where we obtain your explicit prior authorization or consent;

（b）Where the requirements of laws, regulations, legal procedures, or mandatory government requirements or judicial rulings are met;

（c）If we are involved in transactions such as mergers, divisions, liquidations, acquisitions or sales of our assets or businesses, your personal information may be transferred as part of such transactions. We will ensure the confidentiality of such information at the time of transfer, inform you of the recipient's name or contact information, and make our utmost effort to ensure that the new company or organization owning your personal information continue to be bound by this Privacy Policy. Otherwise, we will require the company and organization to obtain your authorization and consent again.

3.3 Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

（a）Where we obtain your separate consent;

（b）Where it is required by laws and regulations, legal procedures, litigation, or mandatorily required by government regulatory authorities;

（c）When imposing penalties on illegal accounts and behaviors, we will disclose information about the relevant accounts, which inevitably includes account-related authentication information and violations.

3.4 Entrusted Processing

3.4.1 We may entrust a third-party partner to process your personal information to provide you with better services. We will only entrust the third-party partner to process your information for lawful, legitimate, necessary, specific, and definite purposes. We will strictly limit the information processing purposes of the trustee and require it to take sufficient data security measures. If our third-party partner uses your information for purposes beyond our entrustment, it shall obtain your consent separately.

3.4.2 Explanation of Third-party SDK

To provide you with our services, ensure the normal provision of services, and other necessary purposes, we will embed our authorized partner's SDKs or other similar applications, as follows:

Name of Third-party SDK	Application Scenarios of SDK	Type of Personal Information Collected and Used	Name of Third-party Company	Third-party Rules for Personal Information Processing
Amap Development Platform-Web Services API-Search POI	Map display	Address information	Amap Software Co., Ltd.	https://lbs.amap.com/pages/privacy/
Amap Development Platform-Web Services API-Geocoding/Inverse Geocoding	Map display	Address information	Amap Software Co., Ltd.	https://lbs.amap.com/pages/privacy/
Amap Development Platform-Map JS API-Map	Map display	Address information	Amap Software Co., Ltd.	https://lbs.amap.com/pages/privacy/
WeChat OpenSDK JS-SDK	WeChat Pay	Order information	Shenzhen Tencent Computer System Co., Ltd.	https://support.weixin.qq.com/cgi-bin/mmsupportacctnodeweb-bin/pages/RYiYJkLOrQwu0nb8
Alibaba Cloud SDK 2.0	Sending SMS and email	Device information and operation behavior information	Alibaba Cloud Computing Co. Ltd.	https://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud202107091605_49213.html?spm=5176.8195934.J_9220772140.29.23534378pDzn5k
Huawei Cloud SDK	Sending SMS, user information interaction, file storage	Device information and operation behavior information	Huawei Cloud Computing Technology Co. Ltd.	https://www.huaweicloud.com/declaration/sa_prp.html
VK SDK	User file storage	Operation behavior information	VK Cloud Platform	https://cloud.vk.com/docs/en/additionals/start/legal/policy-privacy
CMB Polypay	User payment	Order information	China Merchants Bank Co., Ltd.	https://polypay-app.paas.cmbchina.com/privacy.html

3.4.3 Without your valid authorization, we will not entrust third-party partners to process information that leads to direct identification of your personal identity. If you voluntarily leave your contact information, address information, and other personal information for a specific third-party partner to contact you, it may directly process your personal information.

3.5 Exceptional circumstances where prior authorization and consent is required when sharing, transferring, or publicly disclosing personal information

Under the following circumstances, sharing, transferring, and publicly disclosing personal information does not require prior authorization and consent from the subject of personal information:

(a) Where national security or national defense is directly involved;

(b) Where is necessary for signing and performance of a contract to which the individual is a party;

(d) Where public security, public health or major public interests are directly involved, for example, where it is necessary to respond to public health emergencies or in emergency situations to protect the life, health, and property safety of natural persons;

(e) Where criminal investigation, prosecution, trial, and enforcement of judgments are directly involved;

(f) Where it is necessary to protect the significant legitimate rights and interests of personal information subjects or other individuals, such as life and property, yet it is difficult to obtain the consent from the person whose information is at stake;

(g) Where the information voluntarily disclosed by a person or other personal information publicly disclosed is processed within a reasonable range in accordance with laws and regulations, such as legitimate news reports, government information disclosure, and other channels;

(h) Other circumstances stipulated by laws and regulations.

4. How We Store and Protect Your Personal Information

4.1 Storage Location and Duration

4.1.1 In principle, personal information collected and generated within the territory of the People's Republic of China will be stored within the said territory. If your personal information may be transferred to or accessed from overseas jurisdictions outside the country/region where you use the service, we will strictly fulfill our obligations stipulated by laws and regulations and obtain your separate prior consent in accordance with legal provisions.

4.1.2 We will keep your personal information for the duration required for the provision of services. However, where laws and regulations have other provisions on the storage period, where you agree to keep it for a longer period, or where it is required to ensure the safety and quality of the service, or for the purpose of resolving disputes, or where it is difficult to realize technically, after the expiration of the aforementioned storage period, we prolong within a reasonable range the storage period in accordance with the law and the contract (for example, the E-Commerce Law stipulates that the storage period of goods and service information and transaction information shall be kept for less than three years from the date when the transaction is completed). After exceeding the storage period, we will delete your personal information or anonymize it in accordance with the law.

4.1.3 Where the services provided by this Platform for you are terminated prematurely, we will continue to store your data within 30 calendar days from the date of early termination. The date won't be retained after the said period, you will be liable for all consequences arising from the destruction of your data at your own discretion.

4.2 Data Security Measures and Capabilities

4.2.1 To ensure the security of your information, we strive to take various reasonable security and technology measures physically, electronically, and managerially to protect your information and prevent unauthorized access, use, modification, public disclosure, damage, or loss of your information. We have taken all reasonable and feasible measures to protect your personal information. For example,

（a）we ensure personal information security from various aspects such as security management, strategies, processes, network architecture, etc;

(b) Our network services adopt security protection technologies such as the HTTPS transport layer security protocol. Through SM4 encryption technology and the formulation of encryption strategies to encrypt sensitive user information, we ensure the confidentiality of electronic data transmission and guarantee the security of your personal information during the transmission process;

(c) We have deployed the access control mechanism, established a data classification and grading system, and adopted hard coding to restrict user access, to ensure that only authorized personnel can access personal information.

4.2.2 We will build a complete set of data security protection system for the services of this Platform, including:

(a) We have conducted classified management of data assets, and followed the overall security protection strategy to construct the information system in a "zoning, hierarchical and domain-based" manner;

(b) We have established the internal network security work and data security management system and operating procedures. To ensure data security, we have implemented security management measures such as encrypted storage, access control, log auditing, and data backup management. There are strict process requirements for collection, use, transmission, or anonymization, which can effectively avoid the illegal use of personal information;

(c) We have implemented permission management for employees, established specialized positions responsible for user permission management, as well as the construction, operation, and maintenance of the authorization and access control system;

(d) We have implemented a review system for access to the information system, taken measures such as intrusion prevention and virus protection, used professional vulnerability scanning and evaluation techniques to conduct regular security assessments of network equipment, and repair the system based on the results;

(e) We will regularly assess the security skills of personnel involved in information security management, inspection, and execution, as well as assess the security knowledge of personnel in various positions.

4.2.3 You understand that the Internet environment and electronic data transmission mode are not 100% secure, and we cannot guarantee that these measures will completely prevent any attempts for unauthorized access, use or disclosure of your information.

4.2.4 We will take all reasonable and feasible measures to ensure that unrelated personal information won't be collected. We will only retain your personal information for the period necessary to achieve the purposes stated in this Policy, unless there is a reasonable and necessary reason or it is permitted by law.

4.3 Security Incident Handling and Notification

4.3.1 In the event of an unfortunate information security incident (such as personal information leakage, damage, loss, etc.), we will timely inform you of the basic situation and possible impact of the security incident in accordance with laws and regulations, the disposal measures we have taken or will take, suggestions for you to prevent and mitigate risks, and remedial measures for you, etc.

4.3.2 We will timely inform you of the relevant situation of the incident through the in-website notifications, emails, and other means. Where it is difficult to inform the information subject one by one, we will take reasonable and effective measures to make public announcements.

4.3.3 Please understand that according to laws and regulations, if the measures we take can effectively prevent information leakage, tampering, or loss from causing harm, we may choose not to notify you of the personal information security incident unless it is required so by the regulatory authorities.

5. Your Rights

In accordance with relevant laws, regulations, and general standard practice in China, we will strive to safeguard your rights in our personal information processing activities, including but not limited to:

5.1 Accessing, Copying, and Correcting Your Personal Information

5.1.1 Unless otherwise stipulated by applicable data protection laws, you have the right to access, copy, and correct your personal information.

5.1.2 You can access, copy, and correct your personal information on your own in the "Personal Center" on the CHC Cloud website.

5.2 Deletion of Your Personal Information

5.2.1 You can contact us through the contact information contained in this Policy to delete the personal information you voluntarily submitted after registration.

5.2.2 Under the following circumstances where we do not delete your personal information, you may request us to delete your personal information through the contact information contained in this Policy:

（a）Where we collect and use your personal information in a way against laws and regulations;

（b）Where our processing of personal information violates our agreement with you;

（c）Where we terminate our operations and services, or if the storage period has expired;

（d）Other circumstances stipulated by laws and administrative regulations.

5.2.3 We will try our best to reply within 15 working days after receiving your request to delete your personal information.

5.2.4 Where the storage period stipulated by laws and administrative regulations has not expired, or where it is technically difficult to delete your personal information, we will take necessary security measures except for stopping storage.

5.3 Canceling Your Account

5.3.1 If you need to cancel your user account, you can contact us through the contact information contained in this Policy for the cancellation.

5.3.2 After account cancellation, we will stop providing services to you and delete your personal information at your request, except as otherwise stipulated by laws and regulations.

5.3.3 You should understand and be aware that a unified management is adopted for Huace accounts, and your account is directly related to the personal information stored in the login ports of all Huace websites, applications, and applets, and you will be unable to restore your account after cancellation.

5.4 Response to Your Requests Above-mentioned

5.4.1 We will try our utmost to respond to your request within 15 working days. If you are not satisfied with our response, you can also lodge a complaint with us through the contact information contained in this Policy.

5.4.2 Under the following circumstances, we will not be able to respond to your request according to legal and regulatory requirements:

（a）Where it is related to the personal information processor's fulfillment of obligations as stipulated by laws and regulations;

（b）Where national security or national defense is directly involved;

（c）Where public security, public health or major public interests are directly involved,

（d）Where criminal investigation, prosecution, trial, and enforcement of judgments are directly involved;

（e）Where personal information processors have sufficient evidence to demonstrate that the personal information subject has subjective malice or abuses its rights;

（f）Where it is necessary to protect the significant legitimate rights and interests of personal information subjects or other individuals, such as life and property, yet it is difficult to obtain the consent from the person whose information is at stake;

（g）Where response to your request will result in serious damage to the legitimate rights and interests of the personal information subject or other individuals or organizations;

（h）Where trade secrets are involved.

6. How We Process the Personal Information of Minors

6.1 Huace attaches great importance to protecting the personal information of minors. Please know that our website, products, and services are only for adults with full capacity for civil conduct.

6.2 If we discover that we have collected personal information of minors under the age of 18 without authorization from their parents or guardians, we will take reasonable measures to delete it as soon as possible. If you find that we have collected personal information of minors under your guardianship without your consent, you can contact us through the contact information contained in this Policy, and we will delete such information.

7. Update of this Policy

We reserve the right to update or modify this Policy from time to time. If our privacy policy changes, we will promptly update the latest version of our Privacy Policy on the homepage of this Platform. If we make a major change to our privacy policy, we may also send you change notifications through different channels. If you disagree with the modified content that has already taken effect, you can notify us through the contact information contained in the Policy. If you continue to use this Platform, it means that you have agreed to accept the modified content of this Policy.

8. Contact Us

8.1 If you wish to exercise your data subject rights, or have any questions, complaints, or suggestions as to this Policy or any of the above content, please contact us through the following methods:

Company name: CHCNAV

Registered address: Block C, No. 599, Gaojing Road, Xujing Town, Qingpu District, Shanghai (enterprise with one business license yet multiple addresses)

Contact information: customer_center@huacenav.com

Contact address: No. 577, Songying Road, Qingpu District, Shanghai

You can also contact us through our publicly available contact number 400-620-6818.

8.2 Generally, we will verify and respond after receiving your relevant contact information within 15 working days.

8.3 We may refuse requests for information that is not directly related to your identity, requests for unreasonable duplicate information, or requests that require multiple technical means (such as developing a new system or radically changing current practices), requests posing risks to the legitimate rights and interests of others, or unpractical requests.

9. Miscellaneous

9.1 This Policy may have multiple language versions. In case of any inconsistency or conflict between the terms and conditions of each language version, the simplified Chinese version of this Privacy Policy shall prevail.

9.2 The headings in this Policy are for convenience and reading only, and do not affect the meaning or interpretation of any provision in this Policy.

9.3 Definition of Terms

9.3.1 Personal information:

It refers to various information recorded electronically or otherwise related to an identified or identifiable natural person, such as name, personal phone number, citizenship ID card number, etc.

9.3.2 Sensitive personal Information:

It refers to personal information that, once leaked or illegally used, can easily undermine the personal dignity of a natural person or cause harm to personal and property safety, including information about biometric identification, religious belief, health, financial account, as well as personal information of minors under the age of 14.

9.3.3 Personal information processor:

It refers to an organization or individual that independently decides on the processing purpose and method during the personal information processing.

9.3.4 Processing:

It includes the collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal information.

9.3.5 Collection:

It refers to gaining the control over personal information which allows the collector to independently decide on the purpose and method of processing personal information, including "automatic collection methods" such as being provided to us by the personal information subject, our interacting with the personal information subject or our recording of the personal information subject's behavior, as well as "indirect collection methods" such as receiving other personal information and/or collecting publicly available information.

9.3.6 Use:

It refers to the processing and utilization of data by us to achieve storage, access and display, integration, statistical analysis, and other uses.

9.3.7 Storage:

It refers to the act of recording personal information in electronic or non-electronic form in the media that we can access and retrieve.

9.3.8 External provision:

It refers to the act of a personal information processor providing personal information to another personal information processor, and the recipient processing personal information according to the category, for the processing purpose, and with the processing method as the personal information subject is informed of.

9.3.9 Entrusted processing:

It refers to the act of a personal information processor entrusting a trustee to process personal information and supervising the trustee's processing of personal information. The trustee can only process personal information within the scope of the entrustment. Without the consent of the personal information processor, the trustee shall not delegate another person to process personal information.

9.3.10 Sharing:

It refers a process in which a personal information processor provides personal information to another processor, and both parties have an independent control over the personal information.

9.3.11 Anonymization:

It refers to a process in which personal information is processed and cannot be identified as a specific natural person, and cannot be restored after processing. The anonymized information does not fall in the category of personal information.

9.3.12 Affiliated party:

9.It refers to a company or institution that currently or in the future controls CHCNAV, or that is controlled by CHCNAV, or that is controlled, as CHCNAV is, by the same company or institution. Control refers to the ability to directly or indirectly influence the management/operation of the controlled object through ownership, voting shares, contracts, actually operational relationships, or other legally recognized means.