                                                          The Risk Reminder and Disclaimer
    The Risk Reminder and Disclaimer (RRD) is prepared to help users better understand and use the Software and services provided by the Software. The RRD also aims to remind users of and help reduce risks in using the Software, as well as clearly define the disclaimer scope. Given this, users are advised to carefully read the RRD before using the Software. Users shall carefully read the RRD and cautiously use the Software and services provided by the Software. Limitation and exclusion of liability clauses may be highlighted with asterisk (*) to remind users to pay special attention.

1. Obtaining and using the Software
    Users may directly download the Software from Esunny International (HK) Co., Ltd. (Hereinafter referred to as "Esunny International") or a third party authorized by Esunny International. If a user doesn't obtain the Software from Esunny International or an authorized channel, then Esunny International doesn't guarantee that such unauthorized Software can function properly, and Esunny International shall not be held responsible for any loss suffered by such user for use of such unauthorized Software.
Esunny International has developed supporting Software versions for different terminal equipment, and users shall download and install the suitable Software version based on their actual situations. Esunny International may from time to time update Software versions to enhance the Software's performance. Users shall update their Software versions according to the given reminders. If any user fails to do so, Esunny International shall not be held responsible for any Software malfunction caused by such failure. Before using the Software, users shall carefully read and understand the use instructions of the Software, and shall seek advice from Esunny International timely when necessary, so as to avoid any loss arising from misunderstanding about use of the Software. Under no circumstance will Esunny International be held responsible in any way for such loss.
    * A user shall use the Software in a lawful manner and ensure that such use is in line with applicable laws prevailing in the place where the Software is used. A user shall not pose as another person to register for and use the Software. A user may be required to provide necessary data or information in the process of using the Software. If such user fails to do so, or provides inaccurate information, then such user may not be able to use the Software or may face restrictions when using certain features of the Software. Such user shall be held solely responsible for all legal liabilities and negative consequences arising from such inability to use or restrictions. If a user fails to properly keep account-opening information, transaction account information, transaction password or any other important information (Collectively referred to as "Important Information"), and as a result another person has stolen such user's account, carry out any unauthorized transaction or make any unauthorized capital withdrawal, then such user shall be held solely responsible for all negative consequences arising therefrom, and Esunny International shall not bear any liability under such circumstance.
    
2. Information for reference
    Information provided by Esunny International and Information Provider with respect to the Software, including but not limited to quotes data, shall be used as general information for reference only, and shall not in any way constitute any invitation to treat, solicitation, invitation or offer for trading any futures contract, option contract or any other product, or any investment advice or any form of service.
    The K-line charts, indicators and other charts, position-opening/position-closing reminders, and other contents displayed in the Software are for reference only, and are generated via in-depth processing of the Exchange's quotes data according to Esunny International's proprietary statistical algorithm, and may be impacted by various negative factors, including but not limited to data source problem at the Exchange, service interruptions, network delays, equipment downtime, computer viruses and other types of hardware and software failures, and network failures. Esunny International and the Information Provider shall not be held responsible in any way for claims, losses, liabilities or transaction consequences directly or indirectly arising from the use of such service or the inability to use such service.

3. Functional risk reminder
(1) Cloud Conditional Order
    Cloud Conditional Order is a software service provided by Esunny International, and its underlying working mechanism is that Cloud Conditional Order is stored on the server provided by the Futures Company, and the authorized server automatically triggers Cloud Conditional Order at the latest price according to conditions set by the user. Due to restrictions under trading rules of the Exchange, the commissioned order placed through the Software features, including but not limited to those with various self-help and preset triggers, may be unable to be executed. If a feature malfunctions due to any failure in server, network, software or other reason, then users of such feature shall solely bear all transaction losses arising from such malfunction, and neither Esunny International nor Futures Company shall be held responsible for such losses.
    With respect to Cloud Conditional Orders, users shall also bear in mind that: 
    1. For Cloud Conditional Position-Closing Order and Cloud Stop-Loss Order Trigger, if the position is in sufficient, then only the available position will be closed;
    2. For Market Order placed at the contractual upper limit price/lower limit price, if market quotes change suddenly and quickly, such order will be executed at the latest quotes, which can be different from the quoted prices seen by the user when placing the order or the trigger prices set for Conditional Order. 
    3. In a market where trading is inactive or quotes change quickly, the execution prices of Stop-Loss Order and Conditional Order may not be the designated prices.
    4. For an account using Stop-Loss Order and Conditional Order, the backstage system will allow at least 2 concurrent pending orders online; 
    5. When Cloud Conditional Order is in place, changing transaction password can lead to inability to trigger Cloud Conditional Order.
(2) Automatic Order
    Automatic Order's underlying working mechanism is that the information of a user's commissioned order is stored at the Futures Company's transaction counter server, and when continuous transaction signal is received by the server, the commissioned order is placed. Before using the service, please fully understand the logic in such working mechanism. Due to restrictions under trading rules of the Exchange, the commissioned order placed through the Software features, including but not limited to those with various self-help and preset triggers, may be unable to be executed. If a feature malfunctions due to any failure in server, network, software or other reason, then users of such feature shall solely bear all transaction losses arising from such malfunction, and neither Esunny International nor Futures Company shall be held responsible for such losses.
(3) Multi Orders
    Some features of the Software are formed by Multi Orders, and users shall by themselves confirm whether all orders are successfully executed. When Multi Orders are being executed, users shall ensure the Software is not shut down. If Multi Orders are not able to be fully executed due to factors including but not limited to Internet disconnection and software shutdown, Esunny International shall not be held responsible or liable for any issue caused by such inability to fully execute Multi Orders.
    (a) Reversed Order includes Position-Closing Order and Reverse-Direction Position-Opening Order. Users shall by themselves pay attention to whether related Position-Closing Order and Position-Opening Order are effectively executed;
    (b) Price Change Order includes Cancellation Order and Commissioned Order. Users shall by themselves pay attention to whether related Cancellation Order and Commissioned Order are effectively executed;
    (c) Other operations involving Multi Orders.

4. Disclaimer
    Given the risks and unpredictability in futures market and software information, Esunny International does not give any form of commitment or guarantee with respect to the stability, timeliness, accuracy and completeness in the Software and related services. Before using the Software and related services, a user shall fully understand and accept that in the process of using such Software and related services, a user may be impacted by various negative factors, including but not limited to service interruptions, network delays, equipment downtime, computer viruses and other types of hardware and software failures, and network failures. Users shall put in place adequate and effective backup plans in advance so as to prevent and reduce the risk of such negative impact. 
    Users shall * cautiously use the Software and related services after fully reading and understanding the RRD. Esunny International shall not be held responsible or liable in any way for claims, losses, liabilities or any transaction issue directly or indirectly arising from the user's use of the Software and the contents & services related to the Software.
    Esunny International shall not be held legally responsible for, or be required to pay compensation for any consequences of abnormal information transmission that is caused by factors including but not limited to malfunctions at any Exchange, satellite link, a network operator, hardware, a network service provider and an information service provider. Users need to adopt adequate precautions to consistently avoid, reduce, or remove any impact of negative factors such as missing, inaccuracy, loss, delay or interruption of quotes data or commissioned transaction information. Users shall not file any claim against Esunny International for any of the above-mentioned causes. Moreover, if any force majeure event, including but not limited to earthquake, typhoon, war and change in law or policy, has negative impact on any related service, Esunny International shall not be held responsible for any loss arising therefrom.

5. Other important matters
    A user's continued use of the Software and related services will be deemed as an acknowledgment that such user has read, understood and accepted the RRD. A user that cannot accept the RRD shall immediately stop using the Software and related services. If a user has any question about any matter mentioned hereunder, such user may timely inform Esunny International of such question, and Esunny International will answer such question, give a solution or provide other service as required by such user. 

                                                            Privacy Policy
    This Privacy Policy applies to the international edition of Epolestar.
    Lasted update: April, 2024
    This Privacy Policy will help you understand the following:
	I. How we collect and use your personal information
	II. How we share, transfer, and publicly disclose your personal information
	III. How we protect your personal information
	IV. Your rights
	V. Global transfer of your personal information
	VI. Updates to this term
	VII. Updates to this Privacy Policy
	VIII. How to withdraw the consent to this Privacy Policy
	IX. Special protection for minors
	X. How to contact us

    Esunny International (HK) Co., Ltd. (Hereinafter referred to as "We" or "Esunny") deeply understands the importance of personal information to you and will try our best to protect the security and reliability of your personal information. We are committed to maintaining your trust in us and will stick to the following principles in the protection of your personal information: principle of rights in accord with responsibilities, principle of definite purpose, principle of obtaining consent, principle of minimum and enough, principle of ensuring security, principle of subject participation, principle of openness and transparency, etc. Moreover, Esunny undertakes to protect your personal information using corresponding security measures in accordance with mature security standards in the industry.
Please read and understand this Privacy Policy carefully before using our products (or services). If you click "Agree to this Policy", or check an option with a similar meaning, or log in and use related products (or services), you will be deemed to have consented to our collection, use, storage, sharing, transfer and disclosure of your personal information in accordance with this Privacy Policy (including updated versions). 

I. How We collect and use your personal information
    Personal information refers to various information that may be recorded electronically or in any other form and can be used to identify, individually or in combination with other information, a specific natural person or reflect a specific natural person's activities. Source of the aforementioned information: the information provided by you to us via this software; the information made publicly available by you; the information disclosed through lawful and public channels (such as lawful news reports, government information disclosure, etc.) or lawfully retained at any third party by you.
    (I) We will use your personal information in the following circumstances:
    1. We use your personal information for collecting and using personal information as stated herein.
    2. We use your personal information for sending to you commercial electronic messages and providing you with the product information relating to you.
    3. To use your personal information for any purpose not specified herein, We will separately obtain your consent in any form, such as confirmation of an agreement, confirmation of acts in specific scenario, etc.
    (II) We will collect and use your personal information only for the following purposes:
    1. To perform the obligation of anti-money laundering, carry out management under the real-name registration system, supervise futures, carry out registration and clearing of futures, abide by the provisions of stock exchanges, protect investors, and ensure network security in accordance with laws, regulations, and regulatory provisions.
    When using the services of this software, you need to provide your identity information, contact information, address, etc. If you fail to provide the above-mentioned information, you might be unable to view quotations and enjoy relevant services normally; in addition, in order to verify the accuracy and completeness of such type of information, We might check and verify the information provided by you with the information that has been retained lawfully by you at relevant organizations (such as government departments, public institutions, and commercial institutions).
    2. Risk prevention
    In order to prevent your funds, personal information, and other important information or materials from being acquired by any lawbreaker, We need to collect your information stated below to judge the risks in your account: when you visit this software, We might record the type and form of the services used by you and your operating information at the time of using the services, such as your IP address, software version used by you, device identification code, device identifier, your geographic location and/or the logs of other relevant services. If you choose to disable the function of collecting location information, We will stop collecting your location information, which will not affect the processing of your trading but might affect the effect of our judgment on security status.
    3. Provision of personalized services and improvement of service quality
    In order to improve the service quality, prevent risks, and give you better service experience or recommend better or more suitable services to you, We will collect your search history at the time of using the software services, the information provided by you when communicating with our customer service team, the reply information sent by you to us when participating in the questionnaire survey, the type and form of the services used by you, your operating information at the time of using the services, etc. We will make statistics of and analyze the aforementioned information so as to provide you with more accurate, personalized, smooth, and convenient services.
    4. Provision of the services of notification of and inquiry about service state
    Subject to applicable laws, regulations, and regulatory provisions, for the convenience of inquiry about the trading state or history by you, We will place on file your identity information, trading information, and behavior information at the time of using the services of this software and properly keep the aforementioned information in strict accordance with laws and regulations. In order to keep you informed of the use state of the services of this software, We will send to you the notice of service state according to relevant information.
    5. Other circumstances
    To the extent permitted by laws and regulations, We might collect and use your personal information without your authorization or consent in any of the following circumstances:
    (1) Such information directly concerns state security or national defense security;
    (2) Such information directly concerns public security, public hygiene, or major public interests;
    (3) Such information directly concerns criminal investigation, prosecution, trial, or enforcement of judgment;
    (4) Such information will be used for protecting the lawful and material rights and interests, such as life and property, of the subject of the personal information or any other individual, but it is difficult to obtain your personal consent;
    (5) Such information has been made public by you to the general public;
    (6) Such information is one of any information that has been disclosed publicly and lawfully, such as lawful news report and government information release;
    (7) Such information is necessary for executing and performing a contract as required by you;
    (8) Such information is necessary for maintaining safe and stable operation of a product or service provided, such as locating and shooting troubles in the product or service;
    (9) The controller of such information is a news agency and such information is necessary for lawful news reporting by the news agency;
    (10) The controller of such information is an academic research institution, such information is necessary for the statistics made or the academic research conducted by such institution for public interests, and the personal information included in the academic research results or the statistical results is de-identified when the results are provided to others or are described; or
    (11) Any other applicable circumstance related to laws, regulations or regulatory rules. 
    (12) Any other applicable circumstance stipulated by laws and regulations occurs.

II. How We share, transfer, and publicly disclose your personal information
    We will not share or trade with, or transfer, sell, or lease to, any company, organization, or individual your personal information, unless:
    1. Such transfer has been consented to or authorized by you explicitly;
    2. Such personal information must be provided to competent authority, organ, or organization as required by applicable laws or regulations or mandatory administrative or judicial requirements;
    3. Such personal information is transferred for merger, acquisition, or bankruptcy liquidation. In this case, We will require the company or organization holding your personal information to be bound by this Privacy Policy, otherwise We will require such company or organization to obtain your authorization or consent separately;
    4. Such personal information has been de-identified when being transferred and the receiver of such personal information cannot reidentify the subject of such personal information;
    5. Any other applicable circumstance stipulated by law occurs.

III. How We protect your personal information
    We undertake to keep the information security protection at a reasonable level. In order to protect your information security, We are committed to using security technologies, such as encrypted transmission using various secure sockets layer (SSL) software, encrypted information storage, strict restriction on access to the data center, use of private network channel, and network agency, and supporting management system to protect your information from being disclosed, damaged, destroyed, or lost.
You have fully understood and agreed that due to technical limitations and possible malicious attacks, our protection of your information may still be subject to uncertainties arising from accidents beyond our reasonable control, such as war, serious network virus attacks and other factors, and therefore We do not make any commitment and guarantee for absolute information security. 
    If We stop operation, We will stop collecting your personal information in time and delete or anonymize your personal information in the possession of us.

IV. Your rights
    According to the relevant laws, regulations and standards prevailing in the places where you use our products or services, as well as the common practices of other countries and regions, We guarantee that you can exercise the following rights with respect to your personal information:
    (I) Right to access your personal information
    Unless otherwise stipulated by laws or regulations, you have the right to access your personal information. You may exercise your right to access data by the following means:
    Account information--you may visit http://pay.epolestar.xyz/Home to access or edit your personal information and account information of your account, change your password, and add security information.
    Search information--you may access or wipe your search history and view relevant data at the search bar.
    If you are unable to access such personal information in the above-mentioned means, you may dial 400-6156869, our official customer service hotline, or send an E-mail to epolestar@esunny.com.cn at any time. We will give a reply to your request for access within thirty days.
    (II) Right to correct your personal information
    When you find that your personal information that has been processed by us is incorrect, you have the right to require us to correct such information. You may file an official application by the means stated in "(I ) Right to access your personal information".
    If you cannot correct such personal information by the above-mentioned website link, you may dial 400-6156869, our official customer service hotline, or send an E-mail to epolestar@esunny.com.cn at any time. We will give a reply to your request for access within thirty days.
    (III) Right to delete your personal information
    You may make a request to us for deleting personal information if:
    1. Our processing of the personal information is in violation of laws or regulations;
    2. We collect or use your personal information without your consent;
    3. Our processing of the personal information is in breach of the agreement between you and us;
    4. You will not use our products or services any more or you have cancelled your account; or
    5. We decide not to provide you with products or services any more.
    If We decide to respond to your request for deletion, We will also notify each entity that has obtained your personal information from us to require it to delete the personal information in time, except to the extent that it is otherwise stipulated in laws or regulations or such entity has obtained a separate authorization from you.
    After you delete the information from our services, We might not delete corresponding information from our backup system immediately, but We will delete such information when the backup is updated.
    (IV) Right to alter the scope of your authorization or consent
    Each business function can be realized only when some basic personal information is available (please refer to Part I). You may grant or withdraw, at any time, your authorization for or consent to the collection and use of your personal information collected additionally.
    You may dial 400-6156869, our official customer service hotline, or send an E-mail to epolestar@esunny.com.cn at any time. We will give a reply to your request within thirty days.
    After you have withdrawn your consent, We will not process corresponding personal information any more. However, your decision to withdraw your consent will not affect prior personal information processing based on your authorization.
    (V) Response to your requests mentioned above
    In order to ensure security, you might need to make a written request or prove your identity by other means. We might require you to authenticate yourself before processing your request.
We will give you a reply within thirty days.
    In principle, We will not charge any fee for your reasonable requests. However, We may charge certain cost for repeated requests beyond reasonable scope according to the circumstance. We may reject any request that is repeated for no reason, needs too many technological means (such as development of new system or fundamental change of existing practices), endangers any other person's lawful rights or interests, or is highly impracticable (such as the one concerning the information stored at a backup tape).
    According to laws or regulations, We will be unable to respond to your request if:
    1. Such request directly concerns state security or national defense security;
    2. Such request directly concerns public security, public hygiene, or major public interests;
    3. Such request directly concerns criminal investigation, prosecution, trial, or enforcement of judgment;
    4. There are sufficient evidences indicating that you have subjective malevolence or misuse rights;
    5. Response to your request will cause serious damage to lawful rights or interests of you or any other individual or organization;
    6. Such request concerns trade secrets.

V. Global transfer and retention period of your personal information
    The personal information collected or generated by us is governed by and shall be construed in accordance with the laws of the places where such personal information is used. If relevant domestically collected personal information is transferred to any overseas organization as authorized by you for handling a cross-border business, We will carry out such transfer in accordance with laws, regulations, and the provisions of related regulatory authorities and require the overseas organization to keep confidential the personal information obtained by it by effective measures, such as execution of an agreement with such overseas organization. We will retain your personal information only for the reasons stated herein for such necessary period as required by applicable laws and regulations.

VI. Third-party services
    In order to provide you with better services, We engage third parties to provide certain services, such as Tencent Bugly breakdown information collection service and mobile phone terminal operator's push service for the Futures Internet Account Opening Cloud which are operated by relevant third parties. When you use a third-party service, the third-party service provider might collect, use, and store your relevant information. So, you must agree to be bound by the third party's terms of service and information protection statement before deciding to use such service. This Privacy Policy only applies to any information collected by us and We bear no liability for any third party's use of the information provided by you.

VII. Updates to this Privacy Policy
    We reserve the right to modify this Privacy Policy from time to time.
    Without your express consent, We will not reduce your rights that you are entitled to under this Privacy Policy. Any change in this Privacy Policy will be published by us on this page.
    For material changes, We will also send a more obvious notice (with respect to certain services, We will send a notice by system announcement to specify the specific changes in this Privacy Policy).
    The above-mentioned material changes include but are not limited to:
    1. Material change in our service mode, such as change in the purpose of processing personal information, the type of processed personal information, or the manner of using personal information;
    2. Material change in our ownership structure or organizational structure, such as change of the owner arising from business adjustment, bankruptcy, merger and acquisition, etc.;
    3. Change of main object with which personal information may be shared or to which personal information may be transferred or publicly disclosed;
    4. Material change in your rights to participate in processing of personal information and the form of exercise thereof;
    5. Change of our department that is responsible for the security of personal information, the contact information of such department, and the channel of complaint; and
    6. High risks revealed in the impact assessment report regarding personal information security.
    We will place on file the old versions of this Privacy Policy for your future reference.

VIII. How to withdraw the consent to this Privacy Policy
    You may contact us to withdraw your consent to this Privacy Policy at any time, provided that you do not owe any debt to us. We reserve the right to use a customer's personal information before the withdrawal date. We undertake not to use such customer's personal information after such withdrawal. Note: if you withdraw your authorization for privacy, you might be unable to use this product.

IX. Special protection for minors
    Minors should not access our services and We will not receive personal information from minors. If you believe that We may have unknowingly collected information about your child or ward under the age of 18, please contact us according to Part X of this Privacy Policy and We will delete such information.

X. How to contact us
    (a) If you have any question or feedback about our personal data protection policy or products (or services), or if you want to make any request, you can contact use through the following ways: E-mail address: epolestar@esunny.com.cn.
    (b) Under most of cases, We will reply to you within 15 workdays after receiving your request. If you are not satisfied with our reply, especially if you think that our personal information processing practice has damaged your legitimate rights and interests, then you can also call us to lodge a complaint (phone number: 400-6156869) or take other measures to safeguard your legitimate rights and interests according to laws.

Esunny International (HK) Co., Ltd. 
                                                          April 9, 2024
