HBH Smart User Confidentiality Undertaking

I. Platform Entity Statement

HBH Smart App and its related digital service platforms (hereinafter referred to as the “Platform”)

are legally developed, operated, and managed by Hande Education Technology (Wuxi) Co., Ltd.,

which holds the lawful ownership and operational rights to the Platform’s system architecture, data structures, and operational management.

II. User Information and Data Confidentiality Commitment

The Platform hereby solemnly undertakes that:

1. Lawful, Legitimate, and Necessary Principle

The Platform collects and uses user information strictly in accordance with applicable laws and regulations, and only within the reasonable scope necessary for providing educational services, learning support, course booking, activity registration, and recommendations of third-party cooperative products and services.

2. Strict Protection of User Information

The Platform adopts appropriate technical and administrative measures to protect users’ personal identification information, contact details, learning records, consumption records, and behavioral data, preventing unauthorized access, disclosure, alteration, or misuse.

3. No Disclosure to Irrelevant Third Parties

Without the user’s explicit authorization, the Platform will not sell, lease, disclose, or exchange users’ personal information with any unrelated third party.

III. Third-Party Services and Data Usage Explanation

Certain functions or content within the HBH Smart Platform may be provided by third-party partners or technical service providers, including but not limited to:

• AI learning tools

• Educational games

• Online courses

• Local lifestyle and family services

In such cases:

1. The Platform will only provide third parties with the minimum necessary technical information required to deliver the relevant services;

2. Third parties are prohibited from using such data for any purposes unrelated to the provision of the agreed services;

3. Users accessing third-party services through HBH Smart remain protected under the Platform’s overall data compliance standards and cooperation governance mechanisms.

IV. Data Ownership and Platform Rights Statement (Important)

1. Ownership of Platform Systems and Data Structures

The system architecture, data models, user relationship structures, operational data, and derived analytical outcomes of the HBH Smart Platform are lawfully owned by Hande Education Technology (Wuxi) Co., Ltd.

2. Scope of User Data Usage

Data generated by users on the Platform shall be used solely for the following purposes:

• Optimization of educational services

• Improvement of products and platform functionalities

• Enhancement of user experience

• Lawful and compliant statistical analysis

The Platform does not claim ownership of users’ personal data but retains the lawful right to manage and use such data within the scope of compliance.

V. User Obligations and Commitments

Users of the HBH Smart Platform undertake that they shall:

1. Not use the Platform for any illegal or improper purposes;

2. Not scrape, copy, reproduce, or disseminate Platform data or content without authorization;

3. Not engage in any activities through the Platform that infringe upon the lawful rights and interests of others.

VI. Governing Law and Dispute Resolution

1. The formation, execution, and interpretation of this Undertaking shall be governed by the laws and regulations of the People’s Republic of China;

2. Any disputes arising from the use of the Platform shall first be resolved through amicable negotiation. If such negotiation fails, the dispute shall be submitted to the competent People’s Court at the place where the Platform’s operating entity is located.

VII. Confirmation and Effectiveness

By clicking “Agree” or continuing to use the HBH Smart App, the user shall be deemed to have:

✔ Fully read

✔ Fully understood

✔ Accepted and agreed to all terms of this User Confidentiality Undertaking

Platform Operating Entity:

Hande Education Technology (Wuxi) Co., Ltd.

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Platform Operating Entity:

Hande Education Technology (Wuxi) Co., Ltd.