X-DOOR

X-DOOR Platform Privacy Policy

Release Date: March 31, 2026

Effective Date: April 1, 2026

Introduction

The platform named “X-DOOR” (including but not limited to APP, websites, and mini-program, collectively referred to as the “X-DOOR Platform”) is legally owned and operated by Kuangyewujie (Shanghai) Technology Co., Ltd. (hereinafter referred to as “Kuangyewujie” or “we/us”). The term “our” shall be construed accordingly. For the avoidance of doubt, we also reserve the right to change the name of X-DOOR Platform.

“User” or “you” refers to any person who uses X-DOOR Platform, and “your” shall be construed accordingly.

Kuangyewujie (Shanghai) Technology Co., Ltd. (hereinafter referred to as “Kuangyewujie” or “we/us”) fully understand the importance of personal information to you. We attach great importance to your privacy, and protecting user privacy is a key principle of Kuangyewujie.

We solemnly undertake that Kuangyewujie shall strictly abide by the relevant provisions of laws and regulations, and exert our best efforts to ensure the security of your personal information and its reasonable use within a proper scope. Concurrently, Kuangyewujie shall implement appropriate security measures to protect your personal information. Accordingly, Kuangyewujie has formulated this X-DOOR Platform Privacy Policy (hereinafter referred to as "this Policy") pursuant to the Cybersecurity Law of the People's Republic of China, the Personal Information Protection Law of the People's Republic of China, the Information Security Technology—Personal Information Security Specification (GB/T 35273-2020), and other applicable laws, regulations, and technical standards, and hereby specifically draws your attention to the following:

This Policy constitutes an integral and inseparable part of X-DOOR Platform User Service Agreement. Prior to using the various products and services offered by X-DOOR Platform, please read this Policy carefully and fully understand it. You may use the relevant products and services only after confirming that you fully understand and agree to it. Key provisions have been highlighted in bold by Kuangyewujie, for your special attention. Furthermore, you shall ensure that the personal information you provide to Kuangyewujie, as well as the collection, processing, storage, sharing, transfer or public disclosure of relevant personal information that you authorize Kuangyewujie to conduct within the scope described in this Privacy Policy, do not infringe upon the legitimate rights and interests of others.

I. Confirmation and Consent to the Privacy Policy

If a user accesses or uses products or services of X-DOOR Platform on X-DOOR Platform (collectively referred to as the “Services”), the user shall be deemed to have accepted this Privacy Policy. Please read the following provisions carefully, particularly the provisions highlighted in bold. If you do not agree with any of the following terms, please immediately cease accessing or using this website or any other APPs or software.

If you are under the age of 18 or below the minimum age required in your place of residence to use X-DOOR Platform, or if you are otherwise not legally competent to engage in user-related activities, please (A) refrain from using X-DOOR Platform, or (B) read this Policy under the accompaniment and guidance of your guardian ("Guardian") and use X-DOOR Platform only after ensuring that the Guardian has consented to the content of this Policy, as required by applicable laws.

II. Information Collection

Our purposes for information collection are to provide users of X-DOOR Platform with more smooth and convenient Services. The information we may collect includes:

1) Registration Information: Including personal information you provide when registering on X-DOOR Platform, such as your name, address, contact number, email address, WeChat account, and third-party social media accounts;

2) Browsing Information: Including your browsing history and search records on web pages or mobile applications;

3) Other information obtained through customer service inquiries, complaints, feedback or other similar channels;

4) Device Information: Including the IP address used when accessing the network, device hardware and software information (such as device model, serial number, operating system, etc.), and the geographic location of the device;

5) Activity Registration and Payment Information: Including the name, identity document (ID) number, address, contact number, and emergency contact information of the registrant and traveler(s) when you sign up for activities on X-DOOR Platform, as well as information contained in the payment order upon successful registration, such as the payer, payment method, payment amount, and bank account details.

The above information includes personal information, which refers to various information recorded electronically or by other means that can identify a specific natural person's identity alone or in combination with other information, or reflect the activity situation of a specific natural person.

Kuangyewujie will collect and use your personal information that you voluntarily provide or generated during your use of the Services, in accordance with the principles of lawfulness, legitimacy and necessity, and for the purposes stated in this Policy.

Please understand and agree that, in order to provide you with an enhanced product and service experience, we are continuously striving to improve our technologies. Consequently, we may from time to time launch new or optimized features, which may require the collection and use of new categories of personal information, or involve changes to the purposes or methods of processing personal information, or require updates to this Privacy Policy. In such events, we will separately explain the purpose, scope, and method of use of the corresponding information through policy updates, pop-up windows, page prompts, interactive workflows, website announcements, or other means. We will provide you with the option to voluntarily consent when necessary, and collect and use such information only after obtaining your consent.

You fully acknowledge that in accordance with the provisions of relevant laws and regulations, your personal information may be collected without obtaining your prior authorization and consent under the following circumstances:

1) Directly related to national interests such as national security and defense security;

2) Directly related to major public interests such as public security, public health, and public awareness;

3) Directly related to criminal investigation, prosecution, trial and judgment execution;

4) For the purpose of safeguarding your or other individuals' major legitimate rights and interests including life, property and reputation, but it is difficult to obtain your consent;

5) The personal information collected is disclosed by yourself to the public;

6) Collecting personal information from legally publicly disclosed information, such as legitimate news reports, government information disclosure and other channels;

7) Necessary for concluding and performing a contract at your request;

8) Necessary for maintaining the safe and stable operation of the provided Services, such as detecting and handling failures of Services;

9) Necessary for conducting legitimate news reports;

10) Necessary for conducting statistical or academic research in public interest, provided that the personal information contained in the results is de-identified when such academic research or descriptive results are provided externally;

11) Other circumstances as stipulated by laws and regulations.

III. Use of Information

3.1. In general, X-DOOR Platform collects and uses your personal information for the following purposes:

1) To provide you with functional features, including information browsing, posting, liking, favoriting, sharing, commenting and product comparison analysis;

2) When you use the “translation” function, we may provide the content to be translated to a translation service provider. We will only provide the content that needs to be translated and will not provide your username or any other personally identifiable information;

3) To respond to your inquiries and requests;

4) To collect, process or refund payments;

5) To improve our Services through data analysis;

6) To prevent and pursue legal liability for illegal or criminal activities, or violations of our policies and rules;

7) Other purposes with your consent.

3.2. Sharing, Disclosure and Transfer of User Information

3.2.1. Sharing

User information is a significant part of our business. While conducting our business, we are committed to safeguarding user privacy and personal information security. We do not sell or otherwise share your personal information, except in the circumstances described below:

1) Sharing with partners providing travel, information, technology, or payment-related Services: In order to provide you with more comprehensive and high-quality Services, certain Services of Kuangyewujie may be provided by authorized partners or jointly by Kuangyewujie and authorized partners, and Kuangyewujie may share certain personal information with partners. Kuangyewujie will only share your personal information for legitimate, proper, necessary, specific and explicit purposes, and only share your personal information necessary for providing the Services. Partners are not authorized to use the shared personal information for purposes unrelated to the Services.

2) Sharing with affiliated companies: Considering the development strategy and future planning of Kuangyewujie, and to facilitate the provision of more comprehensive Services to you, recommend information that may interest you, identify abnormal member account status, and protect your personal and property safety from infringement, your personal information may be shared among the affiliated companies of Kuangyewujie. Kuangyewujie will only share necessary personal information, and such sharing is subject to the purposes stated in this Policy. If an affiliated company intends to change the purpose of processing personal information, it will seek your authorized consent again.

3) Sharing under statutory situations: Sharing of your personal information as required pursuant to applicable laws, regulations, legal procedures, mandatory government orders, or judicial rulings.

4) Providing your personal information to a third party when necessary to protect the interests, property or safety of Kuangyewujie, you or other users or the public from damage, within the scope required or permitted by law;

5) Obtaining your explicit consent in advance.

3.2.2. Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

1) Transfer with explicit consent: We may transfer your personal information to other parties after obtaining your express consent;

2) In the event of a merger, acquisition, or bankruptcy, if the transfer of personal information is involved, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy. Otherwise, we will require such company or organization to obtain your authorization and consent again.

3.2.3. Disclosure

We will disclose your personal information only in the following circumstances:

3.2.3.1. Disclosure with Your Consent

1) With your consent, we may disclose your information (including personal information, feedback and comments, etc.) in accordance with the instructions you provided at the time of consent, such as when you authorize a third-party application or website to access your X-DOOR Platform account, or when you participate in promotional activities conducted by partners of X-DOOR Platform or other third parties.

2) Where permitted by applicable law, we may use certain limited personal information (e.g., feedback and comments, etc.), add thematic tags to it, and share it with social media platforms including Weibo and WeChat to generate potential customers, drive traffic to our website, or promote our Services or X-DOOR Platform.

3) The social media platforms with which we share your personal information are not controlled or supervised by X-DOOR Platform. Therefore, any questions regarding how your social media platform service providers process your personal information should be directed to such providers.

4) Please note that you may send an email to support@x-door.cn at any time to request that X-DOOR Platform cease processing your data for these purposes.

3.2.3.2. Disclosure Based on Law

When required by law, legal procedures, litigation, or mandatory orders from government authorities, we may publicly disclose your personal information. In compliance with applicable laws and regulations, when Kuangyewujie receives a request for such disclosure, we will require the corresponding legal documents (such as a subpoena or investigation letter) and implement security measures that comply with legal and industry standards to protect the information being disclosed.

3.2.4. Exclusions

In accordance with applicable law, regulations and national standards, the sharing, transfer and public disclosure of your personal information under the following circumstances do not require your prior authorization and consent:

1) Those related to national security and defense security;

2) Those related to public security, public health and other significant public interests;

3) Those related to criminal investigation, prosecution, trial and judgment execution;

4) Those conducted to protect the major legitimate rights and interests such as the life and property of you or other individuals, but it is difficult to obtain your consent;

5) Personal information that you voluntarily disclose to the public;

6) Personal information collected from legally publicly disclosed information, such as legitimate news reports and government information disclosure channels;

7) Please be advised that in accordance with legal provisions, the sharing and transfer of personally identifiable information that has been de-identified, provided that the data recipient is unable to restore and re-identify the individual data subject, shall not constitute the external sharing, transfer or public disclosure of personal information. The storage and processing of such data shall not require separate notification to you or obtaining your consent.

IV. Security

X-DOOR Platform strives to implement security measures, including backing up data to other servers and encrypting user passwords, to prevent personal information from unauthorized access, public disclosure, use, modification, damage, or loss. For example, we may utilize encryption to enhance the security of personal information; implement trusted defense systems to protect personal information against malicious attacks; deploy strict access control mechanisms and require all personnel with access to information to sign confidentiality agreements, using our best endeavors to ensure that personal information is accessible only to authorized personnel; conduct security and privacy protection training courses to strengthen employees' awareness of the importance of personal data protection; establish monitoring and auditing mechanisms and other security measures to ensure data security.

Despite these security measures, please note that no security measures on the Internet are completely infallible. You are advised to properly protect your own personal information and not improperly disclose it to third parties. If you discover any leakage of your personal information, please contact Kuangyewujie immediately so that we can take appropriate measures to minimize your potential loss.

V. Use of Cookies

To provide you with a smoother and more convenient experience, when you visit the X-DOOR Platform or use Services we provide, we may store small data files called Cookie on your device or system to verify your identity. This helps you to bypass the step of repeatedly entering registration information, assists in optimizing advertising selection and interaction, and helps assess the security status of your account. Kuangyewujie will not use Cookies for any purposes other than those stated in this Policy. You may manage or delete Cookies according to your preferences. You may remove all Cookies stored on your computer. While most web browsers automatically accept Cookies, you can typically modify your browser settings to decline Cookies according to your needs. Additionally, you may clear all Cookies stored within the software application. However, if you choose to do so, you may be required to manually adjust your settings upon every visit to Kuangyewujie, and any previously recorded information will be deleted. Furthermore, this may impact the security of the Services you use and may prevent you from fully experiencing the Services.

VI. Special Considerations for Minors

VII. How to Contact Kuangyewujie

If you have any questions, comments or suggestions regarding this Policy or matters related to your personal information, please contact us via email. We will respond within 5 working days.