Version: V2.0  ·  Effective Date: September 1, 2026

Privacy Policy of the DTV·AI Footwear Intelligence Platform

Article 1General Provisions

1.1We attach great importance to the security of your personal information and data. This Policy is formulated in accordance with the Cybersecurity Law of the People's Republic of China, the Data Security Law of the People's Republic of China, the Personal Information Protection Law of the People's Republic of China and other applicable laws and regulations, and is used to separately inform you of how we collect, use, store and protect your data.

1.2When you register for and use the Platform, you are required to separately check and agree to this Policy. We will not bundle this Policy with other non-essential authorizations, and you have the right to refuse non-essential authorizations.

1.3You may register an account with a mobile phone number or an email address; overseas users may register only with an email address.

1.4Enterprise customers who require customized data isolation, access control, data export and other arrangements may sign a written Enterprise Service Agreement with us. Such special agreement only adjusts commercial and service-level arrangements and does not alter the personal information and data compliance obligations under this Policy; matters not covered by the special agreement shall be governed by this Policy and the User Service Agreement.

Article 2Scope of Information We Collect

2.1 Account identity information

• Individual users: mobile phone number, email address, account nickname, login device identifier.
• Enterprise users: enterprise name, contact person and contact information, invoicing information, and information such as the mobile phone numbers of employees whose sub-accounts are activated with enterprise authorization. When an enterprise customer activates sub-accounts for its employees and provides relevant employee information, it shall ensure that it has obtained the authorization and consent of such employees.

2.2 Business creation data

All business data that you upload, enter or generate through the Platform's AI features on your own initiative, such as last parameters, pattern drawings, upper materials, logos, design sketches, rendering files and project records. Such data constitutes your core commercial assets, and ownership belongs to you.

2.3 Platform operation logs

Operation records, access IPs, device models, troubleshooting records and security risk-control logs. Such data is used only for platform operations, security risk control and feature optimization, and not for any other commercial purposes.

2.4 Cookie and login state statement

To maintain your login state and provide a smooth experience, we use cookies on your device to store login state information. Such cookie is a persistent cookie that automatically recognizes your login state when you visit the Platform again within its validity period; it is used only for login verification and session maintenance, does not contain your design content, and remains valid for 24 hours before expiring automatically. You may manage or clear cookies through your browser settings, but you may need to log in again after clearing them.

Article 3How We Use Your Data (Important Commitments)

3.1We process your personal information on the following legal bases: (i) necessity for providing Platform services to you and performing the service contract; (ii) your separate consent; (iii) performance of obligations under laws and regulations. We process your data only within the necessary scope to provide services to you:

1. Providing, maintaining and improving the features you are using (including invoking AI models to complete generation tasks based on your instructions);
2. Safeguarding the security of the Platform and accounts, and preventing risks and fraud;
3. Performing obligations required by laws and regulations, or responding to your requests.

3.2Data training commitment (key): We solemnly commit that:

1. Your business creation data will not be used for AI model training, nor for training any model oriented to other users or third parties;
2. Your design data will not be provided to other users, partners or third parties for any generation tasks;
3. We will not sell, rent out or otherwise provide to third parties information that can identify you personally or your business data (except as otherwise provided by laws and regulations or with your written authorization);
4. Data processed by third-party model service providers is subject to the applicable terms of use of such providers.

Exclusive model boundary statement: After the Platform's "exclusive model" feature is launched, when you actively use this feature, we will, within the scope of your authorization, generate an exclusive model that serves only your own account based on the data you upload, in order to improve your personal design generation results. Such exclusive model is not open to any other users, does not constitute a public general-purpose model oriented to the public, and does not fall within the scope of public models that this Article promises not to train; its generation, storage, use and disposal rules are subject to Article 3 of the DTV·AI User Service Agreement.

3.3Personalized memory (Agent memory) statement: To improve your experience, when you use the AI assistant feature, we will save the content of your conversations with the assistant (such as your preferred shoe styles, colors, materials and business needs) as personalized memory that serves only you, in order to provide continuous and consistent service in your subsequent conversations. Such personalized memory is used only within your own account, will not be used for AI model training, and will not be provided to any other user or third party. If you wish to clear such personalized memory, you may contact us via the contact information stated in this Policy, and we will process it after verifying your identity.

3.4We may analyze anonymized statistical data containing no identifiable information (such as overall Platform usage) for product experience optimization; such statistics do not point to any specific user and do not involve your design content.

3.5Guarantee of content legality: You shall warrant that the images, materials and design content you upload to the Platform are lawfully owned by you or duly licensed. You shall bear the liability arising from your uploaded content infringing third-party intellectual property rights or other lawful rights and interests; if we suffer losses as a result, we have the right to seek compensation from you.

Article 4Data Storage and Protection

4.1 Storage location and period

• All Platform servers are deployed within mainland China, and your data is stored on servers within China.
• During the life of your account, we keep all your data in full; after account cancellation, we will clear all your business creation materials and account personal information within 15 business days.
• Contract, audit and risk-control compliance logs that must be retained by law shall be retained for no less than 3 years.

4.2 Security protection measures

• Data transmission and storage use high-strength encryption;
• Tiered access control is implemented, all operations are logged, and only authorized personnel may access data within the necessary scope;
• Security testing, vulnerability remediation and compliance self-inspection are conducted regularly;
• Partner cloud service providers are all compliant entities within mainland China that have signed confidentiality and data compliance agreements.

4.3 Data breach emergency response

In the event of data tampering, loss or leakage, we will promptly take remedial measures, notify affected users in writing within 72 hours, and report to the regulatory authorities.

Article 5Information Sharing and Entrusted Processing

We will not sell your personal information to any third party. Only in the following circumstances may we provide or entrust necessary data to third parties:

1. Entrusted processing: To provide Platform services to you, we may entrust third parties such as cloud service providers and model technology service providers to process necessary data. Such third parties shall abide by confidentiality obligations and the requirements of this Policy, shall not use the data for purposes beyond the agreement, and shall not use it to train public general-purpose models (except for generating an exclusive model that serves only your own account);
2. Statutory circumstances: as required by laws and regulations, or where necessary to protect the lawful rights and interests of you or others;
3. Other circumstances with your separate written consent.

Article 6Your Rights

You enjoy the following rights over data under this Policy, which you may exercise through in-Platform features or by contacting us:

1. Access and export: access and export your personal information and original design data;
2. Correction: correct your personal information;
3. Deletion and cancellation: delete your materials and personal information, or apply for account cancellation; after cancellation, we will clear your data in accordance with Article 4.1 of this Policy.

Ownership of rights over enterprise customer account data: For accounts held by enterprise customers through an Enterprise Service Agreement or batch activation, the business data generated thereunder (such as design drawings and project files) constitutes enterprise assets, and management rights such as access, export, deletion and cancellation shall be exercised by the enterprise administrator or its authorized personnel. For the sub-account user's own personal information (such as mobile phone number, email and login records), the user may still exercise rights of access, correction and deletion under this Article.

Article 7Enterprise Customer Service Arrangements

7.1Enterprise customers (including foreign-trade enterprise customers) may separately agree with us in an Enterprise Service Agreement on the following matters:

1. Data isolation: providing enterprise customers with dedicated data storage space and resource isolation;
2. Access control: stipulating access permissions, approval and audit mechanisms for enterprise internal personnel and our personnel;
3. Data export and deletion: stipulating the format and frequency of data export, and the complete export and deletion arrangements (including deletion receipts) after the end of cooperation;
4. Security standards: higher encryption standards, security audits and compliance commitments.

7.2The above arrangements do not alter the compliance requirements of this Policy regarding the collection and use of personal information; enterprise customer data storage is by default still completed on servers within mainland China.

Article 8Data Storage and Cross-Border Statement

8.1Storage location: All Platform servers are deployed within mainland China; your account information, business creation data and operation logs are all stored and processed on servers within mainland China. We will not actively transfer your data outside mainland China or to the Hong Kong, Macao or Taiwan regions, nor do we provide overseas server deployment, overseas storage or overseas backup services.

8.2Use by overseas users: When overseas individual and enterprise users register for and use the Platform, their data is still stored on servers within mainland China, with all computation and storage completed by domestic servers; the relevant data processing does not change its storage location based on the user's location.

8.3Special enterprise customer needs: Where enterprise customers have special requirements regarding data export format and frequency, data isolation solutions, data disposal after the end of cooperation, etc., specific arrangements may be agreed separately in the written Enterprise Service Agreement signed by both parties; such arrangements do not affect the basic principle of this Policy that data is stored within mainland China.

Article 9Protection of Minors

9.1The Platform is oriented to professionals and enterprise users in the footwear design and manufacturing fields and, in principle, does not provide specialized services to minors.

9.2The personal information of minors under the age of 14 constitutes statutory sensitive personal information, and we in principle do not actively provide services to such minors. If an account of a minor registered without guardian consent is discovered, the guardian may contact us with proof of guardianship to handle the account and related data.

9.3We will not knowingly collect the personal information of minors under the age of 14.

Article 10Policy Revisions and Contacting Us

10.1When this Policy undergoes major changes involving the scope of information collection, purposes of use, data sharing or cross-border matters, we will publicize them 30 days in advance through in-Platform pop-ups, official website announcements and other means, and obtain your consent again; for adjustments involving only operational content, your continued use of the Platform after the announcement constitutes acceptance.

10.2If you have any questions, comments or complaints regarding this Policy or your data rights, you may contact us as follows:

• Contact email: dtv-ai@qdsunway.com
• Operating entity: Qianli Zhixing (Shanghai) Technology Co., Ltd.

We will respond to your request within 15 business days.

Article 11Governing Law and Supplementary Provisions

11.1All data processing under this Policy is uniformly governed by the laws of the People's Republic of China (for the purposes of this Policy, excluding the laws of the Hong Kong, Macao and Taiwan regions). Where the laws of an overseas user's location impose higher mandatory requirements for personal information protection, such requirements shall prevail.

11.2This Policy has the same legal effect as the DTV·AI User Service Agreement; matters not covered in this Policy shall be governed by the User Service Agreement and national laws and regulations.

11.3This Policy is concluded and interpreted in Chinese. If we provide versions in other languages, such versions are for reference only; in case of any discrepancy with the Chinese version, the Chinese version shall prevail.

11.4This Policy takes effect on September 1, 2026.