Privacy Policy

Notice Clauses

Effective Date: November 6, 2024

Updated Date: March 20, 2026

Notice Clauses

Your trust is very important to us. We fully understand the importance of user information security and will take security protection measures in accordance with laws and regulations to keep your user information secure and controllable. Accordingly, GPUGEEK, also referred to as “we” or “us”, has formulated this Privacy Policy, hereinafter referred to as this “Policy”, and reminds you as follows:

Your trust is very important to us. We fully understand the importance of personal information to you. This Policy is formulated in accordance with laws and regulations including the Personal Information Protection Law of the People’s Republic of China, the Cybersecurity Law of the People’s Republic of China, the Provisions on the Scope of Necessary Personal Information for Common Types of Mobile Internet Applications, the General Data Protection Regulation (“GDPR”), and the California Consumer Privacy Act (“CCPA”). Please read this Policy together with our User Service Agreement.

Before using any services on the GPUGEEK website, please carefully read and fully understand this Privacy Policy, and use the relevant products and services only after confirming that you fully understand and agree to it. Once you start using GPUGEEK services, you will be deemed to have accepted and acknowledged the contents of this Policy. If you have any questions, comments, or suggestions regarding this Policy, you may contact us through GPUGEEK work orders, the GPUGEEK WeChat official account, or our customer service hotline.

Definitions

GPUGEEK Website: refers to the official GPUGEEK website, with the domain name gpugeek.com.

User Information: refers to user registration information that you submit or that GPUGEEK collects when you register a GPUGEEK website account, use GPUGEEK services, or when GPUGEEK provides services to you, such as your name and contact information. The specific information is described in Article 2 of this Privacy Policy.

Personal Information: refers to various information recorded electronically or otherwise that relates to an identified or identifiable natural person, excluding anonymized information.

Sensitive Personal Information: refers to personal information which, once leaked or illegally used, may easily cause harm to the dignity of a natural person or endanger personal or property safety, including biometric facial recognition information, religious beliefs, specific identity information, medical and health information, financial accounts, location tracking information, and personal information of minors under the age of fourteen.

Anonymization: refers to the process by which personal information is processed so that a specific natural person cannot be identified and the information cannot be restored.

Business Data: distinct from user information, refers to data uploaded, downloaded, distributed, or otherwise processed through GPUGEEK technical services by GPUGEEK users using GPUGEEK services.

Composition of this Policy: this Policy consists of two parts: (I) General Terms and (II) Special Terms.

(a) The “General Terms” apply to GPUGEEK global cloud users located in any jurisdiction outside Mainland China.

(b) The “Special Terms”, as part of this Policy, contain provisions applicable only to GPUGEEK global cloud users in specific jurisdictions where GPUGEEK global cloud provides products and/or services. For avoidance of doubt, the Special Terms apply only to GPUGEEK global cloud users in the specific jurisdictions described therein.

If there is any inconsistency between the General Terms and the Special Terms, the Special Terms shall prevail to the extent necessary.

This Policy will help you understand the following: Part I General Terms: 1. Scope of Application of this Policy; 2. How We Collect and Use Your User Information; 3. How We Share, Transfer, and Publicly Disclose Your User Information; 4. User Business Data and Public Information; 5. How You Manage Your User Information; 6. How We Use Cookies and Similar Technologies; 7. How We Protect and Store Your User Information; 8. Special Provisions on Minors’ User Information; 9. Updates to this Privacy Policy; 10. How to Contact Us; 11. Miscellaneous. Part II Special Terms.

Part I General Terms

1. Scope of Application of this Policy

1.1 This Privacy Policy applies to all services on the GPUGEEK Website. The services include page browsing, website login services, and technical services provided to you through the GPUGEEK Website.

1.2 This Privacy Policy does not apply to services provided to you by other third parties. The processing and protection of your information shall be governed by the privacy policies or similar documents of such third parties. We assume no legal responsibility for any improper use or disclosure by any third party of information provided by you.

1.3 In particular, as a GPUGEEK user, if you use GPUGEEK technical services to provide services to your own users, your business data belongs to you, and you should separately agree on a privacy policy with your users.

2. How We Collect and Use Your User Information

We follow the principles of legitimacy, legality, and necessity, and collect and use personal information that you proactively provide during your use of our services or that is generated from your use of our products and/or services for the purposes described in this Policy. If we intend to use your personal information for purposes not stated in this Policy, or to use information collected for a specific purpose for another purpose, we will notify you in a reasonable manner and obtain your consent again before such use. You may view the details through Website Homepage Top Menu — Help Documentation — Privacy Policy. Because different users may choose different products and/or services, the type and scope of information collected and used may vary. Please refer to the specific functions of the relevant products and/or services.

This Privacy Policy may involve sensitive personal information, primarily used to satisfy registration and login, real-name verification, invoice application, and work order application functions. After such information is combined, associated, and analyzed, it may produce highly sensitive information. Unauthorized viewing or unauthorized modification may cause serious harm to the security of your personal information and property. Sensitive personal information referred to in this Article includes:

(1) Basic identity information: including user name, contact information (mobile phone number and email address), company name, as well as the type, number, validity period, and front/back images of valid identity documents, and facial recognition information used for real-name verification.

(2) Online identity information: including system account, IP address, and email address.

(3) Personal payment information and invoice information: payment information includes bank account information.

2.1 How GPUGEEK Collects Your Personal Information

2.1.1 User Registration: When you create an account on the GPUGEEK Website, you must provide an account name, set and confirm your login password, and provide your mobile phone number within the People’s Republic of China. The mobile phone number you submit is used to receive verification codes for registration, account binding, and password recovery, and serves as one of the designated contact methods between you and GPUGEEK for receiving relevant business notifications, such as new product launches, service changes, and service-related notices. If you refuse to provide the above information, you will be unable to register a GPUGEEK account, but this will not affect your browsing of GPUGEEK web pages or product introductions.

2.1.2 Real-Name Verification: According to the laws of the People’s Republic of China, when you use specific technical services, you shall provide your true identity information through your account.

If you complete real-name verification by enterprise verification, you need to submit to GPUGEEK your enterprise name, enterprise type, unified social credit code, business license image, and legal representative identity information, including the legal representative’s name, mobile phone number, ID number, and front/back images of the ID card. The enterprise information you provide is used only for information verification when GPUGEEK completes your real-name verification.

If you complete real-name verification by member verification, you need to submit to GPUGEEK your name, mobile phone number, ID number, and upload photos of the front and back of your ID card to verify your identity. The member information you provide is used only for information verification when GPUGEEK completes your real-name verification.

If you complete real-name verification by student verification, you need to submit to GPUGEEK your name, student ID number, mobile phone number, and ID number, and upload photos of the front and back of your student ID card, or verify your identity by receiving or replying to our verification email through an email address with your school’s domain suffix opened for you by your school. The member information you provide is used only for information verification when GPUGEEK completes your real-name verification.

During the real-name verification process, if you use facial recognition for verification, you will also need to provide facial biometric information and authorize us to verify the information through a nationally authoritative and trusted identity verification institution. Please note that we will only use the above information to verify your identity and record and store the verification result, and will not store such sensitive personal information or use it for any other purpose not expressly authorized by you.

You acknowledge and understand that identity document information and, depending on the identity verification method you choose, Alipay account information, bank account information, or facial biometric information, are necessary for real-name identity verification as required by law.

The above information contains your sensitive personal information. Once leaked or illegally used, it may cause harm to your personal dignity or endanger your personal or property safety. Please carefully consider which method to use for identity verification. However, if you refuse to provide any of the above identity verification information, we will be unable to complete your real-name verification and provide you with the corresponding technical services.

2.1.3 Service Ordering: If you order and use computing machines on the GPUGEEK platform, in order to help you complete order payment, protect transaction security, and perform contractual obligations, when you purchase products and/or services we need to collect transaction-related information, including product and/or service information, transaction amount, order time, order number, order status, payment method, payment transaction number, payment status, and other necessary information required by anti-money laundering laws.

2.1.5 Security Settings: When you use security settings services, in order to protect the security of your GPUGEEK account information, we may need to collect your account name and mobile phone number when you modify personal information in security operations.

2.1.6 Log Information: When you use services provided by our website or client, we automatically collect details of your use of our services, including your IP address, browser type, language used, and access date and time, which are stored as network logs.

2.1.7 Message Receipt: After you register a GPUGEEK account, you may submit or modify message recipient information, including mobile phone number and WeChat notifications, under Console — Account Center — Notification Settings. GPUGEEK may use the above information to send you product messages, account fund messages, or conduct business communications with you.

2.1.8 Customer Service: When you request support or services through work orders, customer service calls, or other means, we may need to collect your name or account information, email address, mobile phone number, consultation records, cloud service operation and maintenance logs, resource information such as service resource names and configuration information, and content you proactively submit to us, such as text, images, and videos.

2.1.9 Invoice Application: After you register a GPUGEEK account, when we provide specific services and issue invoices to you, you need to provide true, accurate, and valid information, which may include invoice title, invoice type, unified social credit code, bank name, basic bank account number, enterprise registered address, and telephone number. If you do not provide the above information, the invoice application cannot be completed.

2.1.10 Where permitted by law, we may also obtain your personal information from third parties or other lawful public channels within the scope of your authorization and consent. For example, in order for us to promptly learn and confirm the progress and status of your order payment and provide after-sales and dispute resolution services, you agree that we may collect information related to payment progress from the transaction counterparty you choose or other financial institutions you select.

2.1.11 When providing business functions or specific services to you, we will collect, use, store, provide externally, and protect your user information in accordance with this Policy and the corresponding product service agreements. If we collect your user information beyond the scope agreed in this Policy and the corresponding product service agreements, we will separately explain to you the scope and purpose of such information collection and obtain your consent before collecting the information necessary to provide the corresponding service. If you choose not to provide the above information, it may affect your use of the corresponding product, but will not affect your use of the basic functions of the GPUGEEK Website and other products.

2.2 Circumstances in Which We Use Your User Information

We use the user information you submit and that we collect for the following purposes:

2.2.1 Registration, account login, identity verification, and authentication. With your consent or as necessary to perform a contract with you, when you use GPUGEEK services, we provide account registration, login, identity verification, and permission management to protect the security of accounts and services.

2.2.2 Contact and communication. In order to provide services to you, we send you notifications by email, telephone, or other means, such as product messages, account fund messages, or business communications.

2.2.3 Performance of our contractual obligations to you. This includes fulfilling your transactions or service requests, such as orders, change requests, or information requested by you, including service materials, delivery, activation or verification of services, technical support, and enhancement of service security.

2.2.4 Responding to your interaction requests. When you visit our website or contact us regarding any questions or service information, such as obtaining technical support or providing comments, suggestions, or inquiries, we respond to your inquiries, comments, or suggestions.

2.2.5 Conducting internal audits, data analysis, and research to improve our products and services. We may design, develop, and promote new products and services based on user information statistics. We may compile statistics on the use of our services and may share such statistics with the public or third parties, but these statistics will not contain any information that identifies you.

2.2.6 Protecting the information technology security of our products, services, and users. To improve the security of your use of services provided by us and our affiliates and partners, ensure the security of the operating environment, identify abnormal account status, protect your or other users’ or the public’s personal and property safety, better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, cyberattacks, and network intrusions, and more accurately identify violations of laws and regulations or GPUGEEK agreements and rules, we may use your member information and integrate device information, network logs, and information lawfully shared by our affiliates and partners to assess account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and handling measures in accordance with law.

2.2.7 Complying with and enforcing applicable legal requirements or relevant industry standards. For example, if the law requires real-name verification, information collected, including ID numbers, will be used only for real-name verification and not for other purposes.

2.2.8 Other purposes authorized by you.

2.3 Circumstances Where Your Authorization or Consent Is Not Required

You fully understand that, under applicable laws, we do not need your authorization or consent to collect and use your personal information in the following circumstances:

2.3.1 Where national security and interests or public interests are involved.

2.3.2 Where necessary for us to perform statutory duties or statutory obligations or respond to instructions from government authorities.

2.3.3 Where necessary for the conclusion and performance of an agreement or other written document to which you are a party.

2.3.4 Where necessary to respond to public health emergencies, or in emergency situations to protect the life, health, and property safety of you and others.

2.3.5 Processing personal information disclosed by you to the public by yourself within a reasonable scope.

2.3.6 Processing your personal information collected from legally publicly disclosed information within a reasonable scope, such as lawful news reports and government information disclosure channels.

2.3.7 Other circumstances prescribed by laws and regulations.

3. How We Share, Transfer, and Publicly Disclose Your User Information

3.1 Sharing

We will not share your user information with other organizations or individuals, except in the following circumstances:

3.1.1 Sharing with explicit consent: after obtaining your explicit consent, we will share your user information with other parties.

3.1.2 Sharing personal information necessary for the performance of relevant agreements signed between you and us, including agreements and platform rules, and other legal documents.

3.1.3 Sharing under statutory circumstances: we may share your user information externally in accordance with laws and regulations, for litigation or arbitration dispute resolution needs, or as required by administrative or judicial authorities in accordance with law.

3.1.4 Necessary sharing with our affiliates: we may share your personal information with our affiliates. We will only share necessary personal information, and such sharing is subject to the purposes stated in this Policy. If an affiliate changes the purpose of processing personal information, it will again obtain your authorization and consent.

3.1.5 Sharing with authorized partners: we may entrust trusted partners to provide services, and therefore we may share certain user information with partners to provide better customer service and optimize user experience. We will share your user information only for lawful, legitimate, necessary, specific, and explicit purposes, and only share user information necessary to provide services. Our partners have no right to use shared user information for any other purpose. Partners may have their own independent privacy policies and user agreements. We recommend that you read and comply with third-party user agreements and privacy policies.

Currently, our authorized partners include suppliers, service providers, authorized payment partners, and other partners. We send information to suppliers, service providers, authorized payment partners, and other partners that support our business. Such support includes providing basic technical services, consulting and analysis services, and, in order to complete order payments, providing your account information, order information, payment account information, and other information necessary to complete payment to third-party authorized payment partners.

3.2 Transfer

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

3.2.1 Transfer with explicit consent: after obtaining your explicit consent, we will transfer your user information to other parties.

3.2.2 Transfer based on your own request.

3.2.3 Provision as necessary according to applicable laws and regulations, legal procedures, or mandatory administrative or judicial requirements.

3.2.4 If GPUGEEK is involved in a merger, acquisition, bankruptcy liquidation, or other circumstances involving merger, acquisition, or bankruptcy liquidation with another legal entity, and if user information transfer is involved, we will require the new company or organization holding your user information to continue to be bound by this Policy; otherwise, we will require such company, organization, or individual to obtain your authorization and consent again. If bankruptcy is involved and there is no successor, we will delete the data in accordance with law.

3.3 Public Disclosure

We will publicly disclose your user information only in the following circumstances:

3.3.1 After obtaining your explicit consent or based on your proactive choice, we may publicly disclose your user information.

3.3.2 Where disclosure of your personal information is required by laws or regulations or mandatory administrative enforcement or judicial requirements, we may publicly disclose your user information according to the required type of personal information and method of disclosure.

3.4 Exceptions to Prior Authorization or Consent for Sharing, Transfer, or Public Disclosure of User Information

In the following circumstances, sharing, transfer, or public disclosure of your user information does not require your prior authorization or consent:

3.4.1 Where related to national security or national defense security.

3.4.2 Where related to public security, public health, or major public interests.

3.4.3 Where related to criminal investigation, prosecution, trial, or enforcement of judgments.

3.4.4 Where necessary to protect the life, property, or other major lawful rights and interests of you or other individuals and it is difficult to obtain your consent.

3.4.5 Personal information that you disclose to the public by yourself.

3.4.6 Personal information collected from legally publicly disclosed information, such as lawful news reports and government information disclosure channels.

3.4.7 Where necessary for us to perform statutory duties or statutory obligations or respond to instructions from government authorities.

4. User Business Data and Public Information

Unlike your user information, GPUGEEK will process user business data as follows:

4.1 Data that you process, store, upload, download, distribute, or otherwise handle through services provided by GPUGEEK is your user business data. You fully own your user business data. As a cloud service provider, GPUGEEK will process your business data strictly according to your instructions and will not use or disclose your business data without authorization except as agreed with you or required by explicit laws and regulations.

4.2 You are responsible for the source and content of your user business data. GPUGEEK reminds you to carefully assess the legality of data sources and content. You shall bear all consequences and responsibilities arising from any violation of laws, regulations, departmental rules, or national policies by the content of your user business data.

4.3 As agreed between you and GPUGEEK, GPUGEEK stores user business data in data centers with data storage qualifications and capabilities. GPUGEEK abides by its security commitments to users and protects data stored by users on the GPUGEEK platform in accordance with applicable laws.

4.4 Data Compliance and Cross-Border Data Processing

4.4.1 Data Nature and Compliance Warranties

(1) You warrant and undertake that all data involved, transmitted, processed, submitted through service interfaces, or generated during your use of the services under this contract (“Your Data”) does not contain any types of data subject to special regulation by laws and regulations, including but not limited to:

a. important data, core data, or national security data as defined by laws and regulations of any country or region;

b. industry-sensitive data that requires specific administrative licenses or special protection measures for transmission or processing, such as human genetic resource information, geographic information, and financial account information.

(2) You confirm that you independently bear full responsibility for the legality, legitimacy, accuracy, and completeness of Your Data.

4.4.2 Service Role and Data Processing Definition

(1) Both parties confirm that GPUGEEK acts only as a neutral technical service provider and provides agreed technical capabilities and support to you through application programming interfaces (APIs) or other technical means.

(2) GPUGEEK does not proactively contact, receive, store, process, analyze, or use any of Your Data. Unless necessary to provide basic technical services and expressly authorized by you, such as temporary log recording for troubleshooting, GPUGEEK does not access the content of Your Data. The services provided by GPUGEEK shall not be interpreted as any form of processing or control of Your Data.

4.4.3 Allocation and Limitation of Liability

(1) Your scope of responsibility: you bear full and ultimate responsibility for the content of Your Data, the way you use the services, and all legal consequences arising therefrom, including but not limited to data security, personal information protection, content compliance, and intellectual property infringement. If GPUGEEK suffers any claims, penalties, or losses due to your violation of the warranties under Article 4.4.1 or any laws and regulations, you shall be responsible for full compensation.

(2) GPUGEEK’s scope of responsibility: GPUGEEK’s responsibility is limited to ensuring the technical availability and stability of the technical services it provides, such as API interfaces, and the accuracy of technical documentation, and compliance with service level agreement (SLA) commitments publicly released by GPUGEEK or signed as an appendix to this agreement.

(3) Limitation of liability: in any case, GPUGEEK shall not bear legal liability for any claims, data leaks, compliance penalties, goodwill losses, or any form of indirect, incidental, or punitive damages directly or indirectly arising from Your Data or your use of the services. The cumulative total amount of GPUGEEK’s data compliance liability under this contract shall not exceed the service fees actually paid by you for the service matter giving rise to the liability.

4.4.4 Cross-Border Data Transfer

(1) Your cross-region data operations based on the services may cause your cloud business data to be transmitted to the region you select or the product deployment region. You shall ensure that you have full disposal rights over the relevant cloud business data, adopt sufficient data security protection technologies and strategies, and ensure that the data transfer complies with applicable laws and regulations, including ensuring that the transferred data does not contain any content restricted or prohibited from transmission or disclosure by applicable law.

(2) If your relevant operations may result in cross-border data transfer, such as transfer of data from within China to outside China or transfer of data between different countries/regions, you shall ensure that the relevant cross-border data transfer complies with applicable laws, regulations, and regulatory policies, such as obtaining valid authorization from personal information subjects, completing standard contract signing and filing, and completing security assessment and other statutory obligations where applicable.

If you carry out cross-region data operations without complying with the foregoing statements and warranties, you may bear corresponding legal consequences. If GPUGEEK and its affiliates suffer actual losses as a result, you shall bear compensation liability.

5. How You Manage Your User Information

5.1 Query, Correction, and Supplementation: You may log in to the GPUGEEK Website and go to Console — Account Center to query and manage the basic business information and contact information submitted when using GPUGEEK services.

5.2 Copying: After completing the information query through the path listed in Article 5.1, you may copy your personal information yourself.

5.3 Deletion

5.3.1 You may submit a work order through GPUGEEK Website — Console — Work Orders — Create Work Order — Account Work Order — Other. We may assist you in deleting part of the submitted information or delete all information in your account by canceling your GPUGEEK account, except as otherwise required by laws, regulations, or industry regulatory rules.

5.3.2 In the following circumstances, you may contact us through the contact information disclosed in this Policy and request deletion of user information:

(1) If our processing of user information violates laws and regulations;

(2) If we collect and use your user information without obtaining your explicit consent;

(3) If our processing of personal information seriously violates our agreement with you.

5.3.3 After you or we assist you in deleting relevant information, due to applicable legal and security technology limitations, we may not be able to immediately delete the corresponding information from backup systems. We will securely store your personal information and restrict any further processing of it until the backup can be cleared or anonymized.

5.4 Changing or Withdrawing Authorization Scope

5.4.1 You may submit a work order through GPUGEEK Website — Console — Work Order List — Create Work Order — Account Work Order — Other. We will assist you in changing or withdrawing the scope of authorization for our collection and processing of your personal information. Please note, however, that for some types of personal information, such as information necessary to implement GPUGEEK basic functions or information necessary for us to perform statutory obligations, we may be unable to respond to your request to change the authorization scope.

5.4.2 After you withdraw consent, we will no longer process the corresponding personal information. However, your withdrawal of consent will not affect personal information processing previously conducted based on your authorization.

5.5 Account Cancellation

5.5.1 You may submit an account cancellation application through GPUGEEK Website — Console — Work Order List — Create Work Order — Account Work Order — Other, and we will assist you in canceling your account.

5.5.2 After you actively cancel your account, we will stop providing products or services to you, and delete or anonymize your personal information in accordance with applicable legal requirements.

5.6 How We Respond to Your Rights Requests

To ensure security, you may need to provide a written request or otherwise prove your identity. We may first require you to verify your identity before processing your request. We will respond within fifteen days.

5.7 Exceptions to Responding to Your Rights Requests

5.7.1 Where related to our performance of obligations prescribed by laws and regulations.

5.7.2 Where directly related to national security or national defense security.

5.7.3 Where directly related to public security, public health, or major public interests.

5.7.4 Where directly related to criminal investigation, prosecution, trial, or enforcement of judgments.

5.7.5 Where we have sufficient evidence showing that you or another personal information subject has subjective malice or is abusing rights.

5.7.6 Where necessary to protect the life, property, or other major lawful rights and interests of you or another personal information subject and it is difficult to obtain authorization and consent.

5.7.7 Where responding to your or another personal information subject’s request would seriously harm the lawful rights and interests of you, another personal information subject, or an organization.

5.7.8 Where trade secrets are involved.

6. How We Use Cookies

6.1 We may collect and use your information through Cookies and other related technologies. Our specific uses of Cookies include:

6.1.1 Remembering your identity. For example, Cookies help us identify you as our registered user.

6.2 You may reject or manage Cookies through your browser settings. Please note, however, that if Cookies are disabled, you may not be able to enjoy the best service experience, and the availability of certain functions may be affected.

6.3 Information recorded through GPUGEEK Cookies will be governed by this statement.

6.4 If you click a hyperlink from the GPUGEEK official website to a third-party website, such third-party website may send Cookies to you. Third-party websites have their own Cookies policies, and we cannot control third parties. For more information on Cookies of such third-party websites and how to manage such Cookies, please contact the third party.

6.5 We may update this Cookies policy and recommend that you review this Policy from time to time to stay informed about how we use Cookies.

7. How We Protect and Store Your User Information

7.1 GPUGEEK attaches great importance to your information security. We strive to take various reasonable physical, electronic, and managerial security measures to protect your user information and prevent unauthorized access, public disclosure, use, modification, damage, or loss of user information. For example, we provide secure browsing through the HTTPS protocol on the GPUGEEK Website; we use encryption technology to improve the security of user information; we use trusted protection mechanisms to prevent malicious attacks on user information; we deploy access control mechanisms and strive to ensure that only authorized personnel can access user information; and we conduct security and privacy protection training to enhance employees’ awareness of the importance of protecting user information.

7.2 We will take reasonable and feasible measures to avoid collecting irrelevant user information as much as possible. We will retain your user information only for the period necessary to achieve the purposes described in this Policy, unless retention is permitted by law. After the above retention period expires, we will delete or anonymize your personal information.

7.3 Please use a strong password to help us protect the security of your account. We will endeavor to ensure the security of any information you send to us. If our physical, technical, or managerial safeguards are compromised, resulting in unauthorized access, public disclosure, tampering, or destruction of information and harm to your lawful rights and interests, we will bear corresponding legal liability.

7.4 In the unfortunate event of a user information security incident such as leakage or loss, we will notify you in a timely manner in accordance with laws and regulations of the basic situation and possible impact of the security incident, the measures we have taken or will take, recommendations for you to independently prevent and reduce risks, and remedial measures for you. We will notify you of the incident by email, letter, telephone, push notification, or other means. If it is difficult to notify user information subjects one by one, we will publish an announcement in a reasonable and effective manner. At the same time, we will report the handling of user information security incidents as required by regulatory authorities.

7.5 We store the user information we collect from you within the territory of the People’s Republic of China. If personal information needs to be transferred overseas for business purposes in compliance with applicable law, we will obtain your consent in advance and, in the specific scenario, clearly inform you of the overseas recipient’s name, contact information, processing purpose, processing method, type of personal information, and the ways and procedures by which you may exercise rights against the overseas recipient, and obtain your separate consent where applicable.

7.6 If GPUGEEK products and services cease operation, we will take reasonable measures to protect the security of your user information, including promptly stopping continued collection of user information. Notice of cessation of operation will be delivered individually or announced to users, and the personal information we hold will be deleted or anonymized.

8. Special Provisions on Minors’ User Information

8.1 We mainly provide products and services to adults. If you are a minor, we require you to ask your parents or guardians to carefully read this Privacy Policy, and to use our services or provide information to us only with the consent of your parents or guardians.

8.2 Please understand that during real-name verification, if we identify that you are a child under the age of 14, we may refuse to provide verification services to you.

8.3 Where we collect personal information of minors who use our products or services with the consent of their parents or guardians, we will use, share, transfer, or disclose such information only as permitted by laws and regulations, with explicit consent from parents or guardians, or as necessary to protect minors.

8.4 Due to existing technology and business models, it is difficult for us to actively identify minors’ personal information during account registration. If you are the guardian of a minor and discover that we have obtained the minor’s personal information without authorization, you may contact us through the contact information disclosed in this Policy. After receiving notice, we will promptly verify the situation and delete or anonymize the relevant information if verified. If we discover such circumstances through active review, we will also proactively delete or anonymize the relevant personal information.

9. Updates to this Privacy Policy

9.1 Our Privacy Policy may be revised.

9.2 Without your explicit consent, we will not restrict the rights you are entitled to under this Privacy Policy. We will publish any revisions to this Privacy Policy on the GPUGEEK Website.

9.3 For major revisions, we will also provide more prominent notices, including website announcements for certain services or even pop-up notifications explaining the specific changes to the Privacy Policy.

9.4 Major changes referred to in this Policy include but are not limited to:

9.4.1 Major changes in our service model, such as the purpose of processing user information, the type of user information processed, or the way user information is used;

9.4.2 Major changes in our control or organizational structure, such as ownership changes caused by business adjustments, bankruptcy, mergers, or acquisitions;

9.4.3 Major changes in the primary recipients of user information sharing, transfer, or public disclosure;

9.4.4 Major changes in your rights to participate in user information processing and how you exercise such rights;

9.4.5 Changes in the responsible department for user information security, contact information, or complaint channels;

9.4.6 Where the user information security impact assessment report indicates high risk.

We will also archive historical versions of this Privacy Policy on the GPUGEEK Website for your review.

10. How to Contact Us

10.1 If you have any questions or comments regarding this statement and Policy, or any questions or comments regarding GPUGEEK’s practices and operations under this Privacy Policy, you may log in to the GPUGEEK official website and submit a work order through Console — Work Orders — Create Work Order, send an email to service@gpugeek.com, or call customer service at 18516569845 (business days, 10:00–18:00). We will respond to your request within 15 days.

Part II Special Terms

11. Supplemental Policy for EU Residents

11.1 Legal Basis for Processing Your Personal Information

GPUGEEK global cloud will process your personal information after obtaining your consent. The purposes for processing personal information and the types of personal information to be processed are described in detail in the preceding sections. If you have any questions about our personal information processing activities, you are welcome to contact us through the contact information published in Section 10 of this Policy.

Please note that, under the GDPR, GPUGEEK global cloud has the right to process your personal information without your prior consent in the following circumstances:

1. Processing necessary for the performance of a contract to which the personal information subject is a party, or in order to take steps at the request of the personal information subject prior to entering into a contract;

2. Processing necessary for compliance with a legal obligation to which the controller is subject;

3. Processing necessary to protect the vital interests of the personal information subject or another natural person;

4. Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

5. Processing necessary for the purposes of the legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, fundamental rights, and freedoms of the personal information subject, especially where the personal information subject is a child; in such case, the exception allowing processing without prior consent does not apply.

11.2 Cross-Border Transfer of Personal Information

GPUGEEK is headquartered in China. Personal information collected from you will be transferred to and stored in China. By agreeing to this Policy and using our products, you are deemed to permit us to process such cross-border transfer of personal information. In order to provide comprehensive services to you, your personal information may also be processed by third parties outside the EU for the purposes described above. To ensure that these third parties process your personal information in a manner compliant with EU data protection laws, we will enter into agreements with such third parties containing provisions for sufficient protection of your personal information.

We have also adopted strict measures to protect your personal information. If you have any questions about the security of your personal information and/or our method of cross-border transfer of personal information, or if you wish to withdraw your consent to cross-border transfer, you may contact us through the contact information published in Section 10 of this Policy.

11.3 Data Subject Rights

We recognize and protect your lawful rights under the GDPR. You may exercise your rights at any time through the methods specified in Section 8 of this Policy. In addition, you have the right to lodge a complaint with a supervisory authority, but we hope that you will first contact us regarding any issues or concerns.

Additional rights of French residents: French residents have the right to contact us through the contact information published in Section 10 of this Policy to give specific instructions regarding how we should process your personal information after your death.

12. Supplemental Policy for California Residents

12.1 Additional Rights of California Residents

We recognize and protect your lawful rights under the CCPA and other California laws. You may exercise your rights at any time through the methods specified in Section 8 of this Policy. In addition, you also have:

1. Right to know regarding participation in data sharing in exchange for financial incentives

   If we provide financial incentives before collecting your personal information, we will obtain your consent in advance.

2. Right to opt out of the sale of personal information to third parties

   You have the right to opt out of the sale of your personal information to any third party. Please note that this right does not apply to our sharing of personal information with service providers. Service providers are parties entrusted by us to perform functions on our behalf, and they are contractually obligated to use personal information only within the scope of such functions as agreed in the contract.

3. Right to non-discrimination

   You may exercise all rights at any time, and GPUGEEK will not discriminate against you for exercising your rights under the CCPA.

4. California “Shine the Light” Law

   California residents have the right to request information about third parties to whom a company disclosed certain types of personal information in the previous year for those third parties’ direct marketing purposes. If you are a California resident and wish us to stop such disclosure of personal information, you may send an email to service@gpugeek.com.

12.2 Collection and Disclosure of Personal Information

In the past twelve months, we have collected and disclosed the following personal information:

Category of Personal Information (Corresponding to categories listed in CCPA Section 1798.140(o)(1))	Collected	Disclosed
A. Personal identifiers such as real name, alias, mailing address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	✔	✘
B. Personal information as defined under California customer records laws, such as name, contact information, education, occupation, employment history, and financial information	✔	✘
C. Descriptive information related to protected classifications under California or federal law, such as gender and date of birth	✔	✘
D. Commercial information, such as transaction information, purchase history, detailed financial information, and payment information	✔	✘
E. Biometric information, such as fingerprints and voiceprints	✘	✘
F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with us and other websites, applications, systems, and advertisements	✘	✘
G. Geolocation data, such as device location	✘	✘
H. Audio, electronic, video, and similar information, such as images and audio, video, or call recordings related to our business activities	✘	✘
I. Professional or employment-related information, such as job title, employment history, and work experience	✘	✘
J. Education information under the federal Family Educational Rights and Privacy Act, such as student records	✘	✘
K. User profiles or summaries created by analyzing any of the above personal information, such as personal preferences and characteristics	✘	✘

For details of personal information collected and disclosed under each category, please refer to Appendix 1 and Appendix 2 of this Policy. Please note that in the past twelve months, we have not conducted any sale of your personal information as defined by the CCPA.

12.3 Changes to Content

We will update this section applicable to California residents from time to time as required by the CCPA.

13. Miscellaneous

13.1 This Policy is governed by the current laws and regulations of the People’s Republic of China. Any dispute related to this Policy shall be resolved through friendly consultation between the parties. If consultation fails, you agree that either party may submit the dispute to the Beijing Arbitration Commission for arbitration in accordance with its arbitration rules in effect at the time of application for arbitration. The place of arbitration shall be Beijing.

13.2 This Policy applies to countries and regions outside Mainland China, including Hong Kong, Macao, and Taiwan.

13.3 The headings in this Privacy Policy are provided only for convenience and readability, and do not affect the meaning or interpretation of any provision in this Privacy Policy.