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[Sharing] Sangfor's Approach to Data Privacy and Compliance

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Last Updated: May 30, 2025

END USER LICENSE AGREEMENT

This End User License Agreement (“EULA” or “Agreement”) is between you (or “Customer”) and Sangfor Technologies (Hong Kong) Limited or its subsidiaries. (“Sangfor” “we” “our” or “us”). This Agreement governs your use of Sangfor’s products including but not limited to hardware, software, cloud-delivered security service, and Software-as-a-Service (collectively, “Product”).

Your download, installation, registration, access, evaluation, use of the Product, or your clicking of “I accept” or similar button or check box presented to you as part of the sign-up or log-in process, whichever is earlier, constitutes acceptance by you of the terms in this EULA. Please carefully read and fully understand all terms and conditions of this EULA before using the Product, especially the Restrictions and Disclaimer clauses which are in capitalized or bolded form. If you do not agree to any portion of this EULA, you must not use or access the Product.

Evaluation. The Evaluation provided by Sangfor to you is limited to test scenarios, you shall not use the Evaluation with production data and shall cease using the Evaluation upon the period of the Evaluation agreed by you and Sangfor being expired or terminated. The Evaluation is provided “AS-IS” without indemnification, support, or warranty of any kind, express or implied.

1. DEFINITIONS

1.1

“Affiliate” means any entity that a party directly or indirectly controls (e.g., subsidiary) or is controlled by (e.g., parent), or with which it is under a common control (e.g., sibling), as applicable, where “control” means having the power, directly or indirectly, to direct or cause the direction of the management and policies of the entity, whether through ownership of voting securities, by contract or otherwise.

1.2

“Approved Source” means Sangfor, a distributor, or reseller directly or indirectly authorized by Sangfor to sell the Product.

1.3

“Customer” means any legal entity, organization or individual that acquires the Product from an Approved Source or other authorized marketplace and uses the Product principally for its own use. Non-authenticated User is included in the Customer.

1.4

“End User” means any individual authorized by the Customer to use the Product on behalf of the Customer and has completed the relative authentication procedure to be associated with the Customer.

1.5

“Non-authenticated User” means any subject who has not registered an account or has only registered but has not completed any authentication procedure to be associated with an entity or an organization, and only browses Product-related information or uses the Product within the restricted scope.

1.6

“End User Data” means data that is provided by or on behalf of Customer to Sangfor during the relationship governed by this Agreement.

1.7

“Evaluation” means a product for proof of concept, beta testing, trial, evaluation, or other similar purposes.

1.8

“Hardware” means hardware-based products supplied by Sangfor regardless of whether a fee is charged for such hardware.

1.9

“Software” means any software embedded in Hardware and any standalone software that is provided without Hardware, including updates, regardless of whether a fee is charged for the use of such software.

1.10

“Subscription” means Software-as-a-Service and cloud-delivered security service, including updates, provided by Sangfor, regardless of whether a fee is charged for its use. Technical support, customer success plans, and professional services are not considered Subscriptions under this Agreement.

1.11

“Product” means, collectively, Hardware, Software, Subscription, or any combination thereof.

1.12

“Published Specifications” means the user manual and other corresponding materials published by Sangfor and customarily made available to the Customer of the Product.

1.13

“Service Level Agreement” means all service level agreements that we offer with respect to the Subscription, as they may be updated by us from time to time.

1.14

“Update” means any update, upgrade, or bug fix, which is made generally available by Sangfor to its Customer.

1.15

“Your Content” means content that any Customer transfers to us for processing, storage, or hosting by the Subscription in connection with your account and any computational results that any Customer derives from the foregoing through their use of the Subscription.

2. USE AND RESTRICTIONS

2.1

Software Use Grant and Access to Subscriptions. Subject to your compliance with this Agreement, Sangfor grants you a limited, non-exclusive right to access and use Sangfor’s Software or Subscriptions:

in accordance with this Agreement and other Published Specifications for the Product;

ii.

solely within the scope of the license or usage capacity purchased;

iii.

solely for your internal use, unless agreed otherwise in a separate written contract with Sangfor; and

iv.

through your third-party contractor providing IT services solely for your benefit, subject to their compliance with this Agreement.

All other rights in the Software or to the Subscriptions (including but not limited to the intellectual property, the ownership of source code for the software, and tools used in technical services) are expressly reserved by Sangfor.

2.2

Use Restriction. Sangfor is responsible for complying with the relevant laws and regulations applicable to the delivery of the Products, but the configuration of the functions and the use of the Products are decided by the Customer independently. Therefore, the Customer shall assess independently whether the applicable legal or regulatory requirements are met based on the impact of the network and data relevant to the implementation of the product functions. And during the use of the Product, you shall not:

use the Product beyond the scope of the license and/or capacity purchased or in any manner not authorized by the Published Specifications of the Product or this EULA;

ii.

sell, resell, sublicense, or assign or otherwise transfer the Product or any rights or interests in the Product to any third party except in accordance with the express terms herein;

iii.

transfer, sublicense, or assign your rights under this Agreement to any other person or entity except as expressly provided in article 2.2.3 below, unless expressly authorized by Sangfor in writing;

iv.

disclose, publish, or otherwise make publicly available any benchmark, performance or comparison tests that you (or a third party contractor) run on the Product, in whole or in part;

modify, translate, adapt or create derivative works from the Product, in whole or in part;

vi.

disassemble, decompile, reverse engineer, or otherwise attempt to derive the source code, methodology, analysis, or results of the Product, in whole or in part, unless expressly permitted by applicable law in the jurisdiction of use despite this prohibition;

vii.

remove, modify, or conceal any Product or service identification, copyright, proprietary, intellectual property notices or other such marks on or within the Product;

viii.

use the Product to engage in any activity that violates this Agreement or applicable laws and regulations, or infringes any third party’s legitimate rights or interests, including, without limitation, sabotaging or attempting to sabotage cyber security, accessing the network, using network resources or deleting, modifying, adding data and application programs stored, processed or transmitted in the network without authorization;

ix.

perform penetration or load testing on the Product or Sangfor’s platform or environment without the prior written consent of Sangfor and agree to certain conditions and requirements for such penetration or load testing;

dig/detect possible vulnerabilities or flaws in Products or Sangfor’s platform and system by scanning and other means, or release vulnerabilities or flaws in violation of relevant laws, or use the relevant vulnerabilities or flaws to engage in any behavior that damages the relevant Products and Sangfor.

xi.

use the Software that is licensed for a specific device, whether physical or virtual, on another device, unless expressly authorized by Sangfor in writing;

xii.

duplicate the Software, its methodology, analysis, or results unless specifically permitted in accordance with Published Specifications for such Software or for the specific purpose of making a reasonable number of archival or backup copies, and provided in both cases that you reproduce in the copies the copyright and other proprietary notices or markings that appear on the original copy of the Software as delivered to you;

xiii.

use the Subscription to store or transmit infringing, libelous, or otherwise unlawful or tortious materials including but not limited to viruses, worms, time bombs, Trojan horses or other harmful or malicious code, files, scripts, agents or programs, or to store or transmit materials in violation of third-parties privacy or intellectual property rights;

xiv.

interfere with, disrupt the integrity or performance of, or attempt to gain unauthorized access to the Subscription, their related systems or networks, or any third-party data contained therein.

2.3 Customer’s Representation and Responsibility

2.3.1

Account. You may assign an End User or a third party (including but not limited to your contractors and/or agents) to your account and authorize them to access or use the Product. You shall be responsible for all the operations conducted by the End User or authorized the third party under your account, any breach of this Agreement by the End User or third party shall be deemed a breach by you. You shall defend, indemnify, and hold harmless Sangfor from and against any claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys’ fees) arising out of or relating to any claim concerning the dispute between you and any End User or third party.

2.3.2

Security. You shall be solely responsible for maintaining the confidentiality and security of your accounts and authentication credentials providing access to the Product and taking appropriate action to secure, protect, and backup your End User Data, Your Content, and your account information in a manner that will ensure appropriate security and protection. You shall notify Sangfor without undue delay about any misuse of your accounts or authentication credentials you are aware of. Under no circumstance will Sangfor be liable for any unauthorized access or misuse of your account, Your Content, or End User Data, unless such incidents are directly caused by our violation of the terms and conditions hereunder.

2.3.3

Affiliate. If you purchase the Product for use by an Affiliate of yours, you shall:

provide the Affiliate with a copy of this Agreement;

ii.

ensure that the Affiliate complies with this Agreement;

iii.

be responsible and liable for any breach of this Agreement by such Affiliate; and where applicable, be responsible and liable for any local law that imposes any tariffs, fees, penalties, or fines arising from your Affiliates’ use of the Product in such jurisdictions.

2.3.4

Compliance with applicable laws and regulations. You shall:

have the full legal right, power, and authority to enter into this Agreement and your performance of this Agreement will not violate the terms of any contract, obligation, law, regulation, or ordinance to which you are or may become subject;

ii.

obtain all necessary licenses or approvals for your business activities or use of the Sangfor Product that are required by relevant authorities and will comply with all applicable laws and regulations enacted from time to time;

iii.

have sole responsibility for the accuracy, quality, integrity, legality, reliability, and appropriateness of all End User Data.

3. ACQUISITION AND FEES

You may purchase or subscribe to the Product from an Approved Source and are obligated to carefully verify the authenticity of the sales qualification of the Approved Source and contact us if you have any doubts. You acknowledge and agree that if you obtain the Product having the same name as Sangfor through any unauthorized third party, we do not warrant the normal use of such Product and will not be liable for any corresponding losses or damages brought to you.

Applicable fees will be set forth based on a quotation at the time of purchase or in the applicable invoice, signed sales contract, or other trade documents. You understand and agree that Sangfor reserves the right to:

adjust the free-of-charge Product, as well as the period of free use or other conditions to be met;

ii.

charge for any Product that is not indicated in writing as free for the Customer and will only provide the Customer with the corresponding technical support and protection within the scope of legal provisions or Sangfor’s explicit statement;

iii.

terminate or suspend your access to or use of the Product at its discretion if you are in default with any payment obligations concerning the Product due to the Approved Source.

4. WARRANTIES, EXCLUSIONS, AND DISCLAIMERS

4.1 Warranty

Sangfor warrants that:

Hardware and Software will perform substantially in accordance with the applicable Published Specifications. Sangfor will work jointly with distributors and system integrators to provide you with after-sales service in accordance with warranty policies signed between you and Sangfor.

ii.

Subscriptions will be provided in accordance with the Service Level Agreement and substantially conform to the applicable Published Specifications for the entire duration of the selected term.

Sangfor may make available to you the third-party products and/or services that contain features designed to interoperate with the Product. Unless Sangfor provides you with certain commitments in writing, Sangfor maintains independence from products of any third party and makes no warranty about the mutual compatibility.

Sangfor reserves the right to adjust the functions of the Product at any time according to our operational arrangements (including but not limited to offline, iteration, integration of the relevant functions, etc.) without prior notice, but any changes to the Product will be subject to the terms of the agreement in force at the time. For any changes to the relevant Product that may affect the business of the Customer, Sangfor will notify the Customer in advance as far as possible, so that the Customer can make preparations for data transfer and backup or business adjustments, etc., and avoid unnecessary costs or losses as far as possible.

4.2 Exclusions

The warranty set forth above shall not apply if the failure of the Product results from or is otherwise attributable to:

repair, maintenance, or modification of the Product by persons other than Sangfor or its designee;

ii.

accident, negligence, abuse, or misuse of a Product;

iii.

use of the Product other than in accordance with Published Specifications;

iv.

improper installation or site preparation or your failure to comply with environmental and storage requirements set forth in the Published Specifications including, without limitation, temperature or humidity ranges; or

causes external to the Product such as, but not limited to, failure of electrical systems, fire or water damage.

4.3 Disclaimers

4.3.1

EXCEPT FOR THE WARRANTIES EXPRESSLY STATED AND TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE PRODUCT IS PROVIDED “AS IS”. SANGFOR AND ITS SUPPLIERS MAKE NO OTHER WARRANTIES AND EXPRESSLY DISCLAIM ALL OTHER WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION ANY WARRANTY AGAINST INFRINGEMENT OF THIRD-PARTY RIGHTS, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND ANY WARRANTIES ARISING OUT OF THE COURSE OF DEALING OR USAGE OF TRADE. SANGFOR DOES NOT WARRANT THAT (I) THE PRODUCT WILL MEET YOUR REQUIREMENTS, (II) THE USE OF THE PRODUCT WILL BE UNINTERRUPTED OR ERROR-FREE, OR (III) THE PRODUCT WILL PROTECT AGAINST ALL POSSIBLE THREATS WHETHER KNOWN OR UNKNOWN.

4.3.2

UNDER NO CIRCUMSTANCES WILL SANGFOR BE LIABLE FOR ANY DAMAGE, LOSS OF DATA, OR INTERRUPTION OF BUSINESS DUE TO THE FOLLOWING REASONS:

FORCE MAJEURE, INCLUDING BUT NOT LIMITED TO EARTHQUAKE, FLOOD, FIRE, STORM, NATURAL DISASTER, ACT OF GOD, WAR, TERRORISM, ARMED CONFLICT, LABOR STRIKE, LOCKOUT, BOYCOTT, EPIDEMIC, UNAVAILABILITY OF NETWORK AND TELECOMMUNICATIONS SERVICES, OR OTHER SIMILAR EVENTS BEYOND ITS REASONABLE CONTROL;

ii.

SERVICES OF TELECOM FOUNDATION PROVIDER, INCLUDING BUT NOT LIMITED TO TECHNICAL ADJUSTMENT OF TELECOM DEPARTMENT, DESTRUCTION OF ELECTRICITY LINES, INSTALLATION, RENOVATION, MAINTENANCE OF TELECOM NETWORK OR ELECTRICITY RESOURCES BY TELECOM/ELECTRICITY DEPARTMENT;

iii.

NETWORK SECURITY INCIDENTS, INCLUDING BUT NOT LIMITED TO COMPUTER VIRUSES, TROJAN HORSES OR OTHER MALICIOUS PROGRAMS, HACKER ATTACKS;

iv.

OTHER REASONS THAT CAN’T BE ATTRIBUTABLE TO SANGFOR AND BEYOND SANGFOR’S CONTROL OR REASONABLE FORECAST.

5. LIMITATION OF LIABILITY

5.1

DIRECT DAMAGES. 5.1 EXCEPT TO THE EXTENT THE FOLLOWING LIMITATION OF LIABILITY IS PROHIBITED BY LAW: SANGFOR’S TOTAL LIABILITY TO THE CUSTOMER SHALL BE LIMITED TO DIRECT DAMAGES SUSTAINED BY THE CUSTOMER. SANGFOR’S TOTAL LIABILITY FOR ANY CLAIM UNDER THIS AGREEMENT: I) FOR THE SOFTWARE AND HARDWARE, WILL NOT EXCEED THE GREATER AMOUNT OF THE LICENSE FEES YOU PAID FOR THE APPLICABLE SOFTWARE DIRECTLY OR THROUGH THE APPROVED SOURCE TO SANGFOR; FOR THE SUBSCRIPTION, WILL NOT EXCEED THE AMOUNT EQUAL TO THE TOTAL FEES PAID OR PAYABLE FOR YOUR USE OF THE PARTICULAR SUBSCRIPTION GIVING RISE TO THE CLAIM IN THE 12 MONTHS PRIOR TO THE EVENT GIVING RISE TO THE CLAIM. Provided that, regardless of the law, no claim or cause of action, regardless of form, arising out of or in connection with these terms may be asserted by the Customer more than twelve (12) months after the facts giving rise to the cause of action have occurred, regardless of those facts by that time are known to, or reasonably ought to have been discovered by Customer.

5.2

DISCLAIMER OF INDIRECT DAMAGES. NEITHER SANGFOR NOR ANY OF ITS LICENSORS SHALL BE LIABLE FOR ANY SPECIAL, INDIRECT, INCIDENTAL, PUNITIVE, EXEMPLARY, OR CONSEQUENTIAL DAMAGES OF ANY KIND (INCLUDING BUT NOT LIMITED TO LOSS OF BUSINESS, DATA, PROFITS, OR USE OR FOR THE COST OF PROCURING SUBSTITUTE PRODUCTS, SERVICES OR OTHER GOODS), ARISING OUT OF OR RELATING TO SANGFOR PRODUCT TO WHICH THIS AGREEMENT RELATES, REGARDLESS OF THE THEORY OF LIABILITY AND WHETHER OR NOT EACH PARTY WAS ADVISED OF THE POSSIBILITY OF SUCH DAMAGE OR LOSS.

6. INDEMNIFICATION

6.1

Sangfor’s Indemnification and Procedure. Sangfor will defend, at its expense, any third-party action or suit against you alleging that the Product infringes or misappropriates such third party’s patent, copyright, trademark, or trade secret (“IP Claim”), and Sangfor will pay damages awarded in the final judgment against you or agreed to in settlement by Sangfor to the extent attributable to any such Claim; provided that you:

promptly notify Sangfor in writing of the IP Claim;

ii.

give Sangfor sole control of the defense and settlement of the IP Claim; and

iii.

reasonably cooperate with Sangfor’s requests for assistance with the defense and settlement of the IP Claim. Sangfor will not be bound by any settlement or compromise that you enter into without Sangfor’s prior written consent.

6.2

Customer’s Indemnification. You will defend, at your expense, any IP Claim against Sangfor arising from infringement by combinations of the Product or Your Content, as applicable, with any other product, service, software, data, content, or method. In addition, Sangfor will have no obligations or liability arising from your or any End User’ use of the Products after Sangfor has notified you to discontinue such use.

6.3

Exclusions. Sangfor’s obligations under this article 6.1 shall not apply to the extent any IP Claim results from or is based on:

modifications to Sangfor made by a party other than Sangfor or its designee;

ii.

the combination, operation, or use of Sangfor with hardware or software not supplied by Sangfor, if an IP Claim would not have occurred but for such combination, operation, or use;

iii.

failure to use the most recent version or release of Sangfor, or an equally compatible and functionally equivalent, non-infringing version of Sangfor supplied by Sangfor to address such Claim;

iv.

Sangfor’s compliance with your explicit or written designs, specifications, or instructions;

use of the Product not in accordance with Published Specifications;

vi.

your failure to modify or replace the Product as required by Sangfor; or

vii.

any Product provided on a no-charge, beta, or evaluation basis.

6.4

Remedy. THE FOREGOING TERMS STATE Sangfor’S SOLE AND EXCLUSIVE LIABILITY AND YOUR SOLE AND EXCLUSIVE REMEDY FOR ANY THIRD-PARTY CLAIMS OF INTELLECTUAL PROPERTY INFRINGEMENT OR MISAPPROPRIATION.

7. CONFIDENTIALITY

7.1

“Confidential Information” means non-public information (including but not limited to price, marketing plan of products and/or services, business planning and strategy, customer list and information, financial information, product development status or relevant, or technical solutions.) that is exchanged between the parties, provided that such information is identified as confidential at the time of initial disclosure by the disclosing party (“Discloser”), or disclosed under circumstances that would indicate to a reasonable person that the information ought to be treated as confidential by the party receiving such information (“Recipient”).

was in the public domain at the time it was communicated to the Recipient;

ii.

entered the public domain subsequent to the time it was communicated to Recipient through no fault of Recipient;

iii.

was in Recipient’s possession free of any obligation of confidentiality at the time it was communicated to Recipient;

iv.

was disclosed to the Recipient free of any obligation of confidentiality; or

was developed by the Recipient without the use of or reference to the Discloser’s Confidential Information.

7.2

Each party will not use the other party’s Confidential Information, except as necessary for the performance of this Agreement, and will not disclose such Confidential Information to any third party, except to those of its employees and subcontractors who need to know such Confidential Information for the performance of this Agreement, provided that each such employee and subcontractor is subject to use and disclosure restrictions that are at least as protective as those set forth herein. Recipient shall maintain the confidentiality of Discloser’s Confidential Information using the same effort that it ordinarily uses with respect to its own confidential information of similar nature and importance, but no less than reasonable cautiousness. The foregoing obligations will not restrict the Recipient from disclosing Discloser’s Confidential Information:

pursuant to an order issued by a court, administrative agency, or other governmental branches, provided that the Recipient gives reasonable notice to Discloser to enable it to contest such order;

ii.

on a confidential basis to its legal or professional financial advisors; or

iii.

as required under applicable securities regulations.

7.3

The foregoing obligations of each party shall be effective during the use of the Product.

8. DATA PROTECTION

Sangfor will process End User Data solely for the purpose of fulfilling its obligations under the terms of this Agreement. To the extent Sangfor processes End User Data, including personal data, as defined by applicable data protection laws, such personal data will be processed in accordance with the Data Processing Agreementhttps://www.paloaltonetworks.com/content/dam/pan/en_US/assets/pdf/legal/customer-data-processing-agreement.pdf Privacy Policy, or other related legal notice available to you on the Product interface or website.

9. INTELLECTUAL PROPERTY

Sangfor and its Affiliates retain all rights to intellectual and intangible property relating to the Sangfor Product, including but not limited to copyrights, patents, trade secret rights, trademarks, and any other intellectual property rights therein unless otherwise indicated. Except where agreed in writing, nothing in this Agreement transfers ownership in or grants any license to, any intellectual property rights to you. Sangfor may use any feedback you provide in connection with your use of the Product as part of its business operations, without your approval or compensation to you.

10. TERM AND TERMINATION

This Agreement is effective until terminated or, as applicable, in accordance with the terms of the Product you purchased.

10.1

Termination for Cause.

Either party materially breaches this Agreement or any applicable agreement with the Approved Source and does not cure that breach within thirty (30) days after receipt of written notice of the breach, the non-breaching party may terminate this Agreement for cause. For example, Sangfor may terminate or suspend your access to or use of the Product if Sangfor reasonably believes that you or the End User are using the Product in a manner or for a purpose that is likely to cause harm to Sangfor or any third party.

ii.

Sangfor will terminate this Agreement if you have ceased to operate in the ordinary course, made an assignment for the benefit of creditors or similar disposition of your assets, or become the subject of any bankruptcy, reorganization, liquidation, dissolution, or similar proceeding.

10.2

Effect of Termination. Upon termination, you shall immediately cease using the Product, and pay the Approved Source any unpaid fees calculated to the termination date. If you continue to use or access the Product after termination, the Approved Source may invoice you, and you agree to pay, for such continued use. Under no circumstances will Sangfor be liable for any loss or damage caused by the unilateral termination of this Agreement due to your violation or breach of this Agreement.

11. TEMPORARY SUSPENSION

11.1

Sangfor may suspend your right to access or use any portion or all of the Product under the following circumstances:

Regular or Emergency Maintenance. Sangfor may overhaul, maintain, upgrade, or optimize the Product at Sangfor’s discretion (“Regular Maintenance”) for the purpose of enhancing or refining the Product, during which time you may experience some disruption to the Product. In case of force majeure, fault of telecom foundation provider or other events, Sangfor may need to perform emergency maintenance and temporarily suspend your access to, or use of Sangfor’s Product.

ii.

Major Adjustments. To ensure the security and stability of the Product, Sangfor may make major adjustments (including but not limited to data center migration and device or server replacement). The aforesaid circumstances may cause the interruption or suspension of the Product within a reasonable time.

iii.

Customer’s Misuse of the Product or Required by Authorities. Sangfor reserves the right to suspend your access to or use of the Product in the event your use of the Product poses an imminent threat to Sangfor’s network, platform, system or if directed by a court or competent authority.

In such cases, Sangfor will:

suspend such Products only to the extent reasonably necessary to prevent any harm to Sangfor;

ii.

use our reasonable efforts to notify you in advance as soon as feasible or permitted and give you the opportunity to promptly change the configuration of your server(s) accordingly and/or work with you to promptly resolve the issues causing the suspension of such Products; and

iii.

reinstate any suspended Products immediately after any issue is abated. You understand and agree that to protect your legitimate interest or other major public interest, the Emergency Maintenance may be performed without providing you advance notice, but Sangfor will notify you as soon as possible.

11.2 Effect of Suspension.

If we suspend your right to access or use any portion or all of the Product in accordance with article 11.1, you remain responsible for all fees and charges you incur during the period of suspension; and you shall not be entitled to any service credits or warranty under the Service Level Agreements or other Published Specification for any period of suspension.

If we suspend the Product due to your reasons, and you fail to cure or take remedial measures within ten (10) business days upon receipt of Sangfor’s notice, Sangfor has the right to terminate your use and access to the Product.

12. MISCELLANEOUS

12.1

Relationship. We and you are independent contractors, and this Agreement will not be construed to create a partnership, joint venture, agency, or employment relationship. Neither party nor any of their respective Affiliates is an agent of the other for any purpose or has the authority to bind the other.

12.2

Assignment. You will not assign or otherwise transfer this Agreement or any of your rights and obligations under this Agreement, without our prior written consent. Any assignment or transfer in violation of this Section 12.2 will be void. We may assign this Agreement without your consent i) in connection with a merger, acquisition, or sale of all or substantially all of our assets, or ii) to any Affiliate or as part of a corporate reorganization, the assignee is deemed substituted for Sangfor as a party to this Agreement and Sangfor is fully released from all of its obligations and duties to perform under this Agreement. Subject to the foregoing, this Agreement will be binding upon, and inure to the benefit of the parties and their respective permitted successors and assigns.

12.3

Entire Agreement. This Agreement, the Addendum to the End User License Agreement, the Data Processing Agreement, the documents referenced herein, and other accepted orders, agreements, or contracts for the Product, that are officially published by Sangfor or customarily made available to you, constitute the entire agreement between the parties with respect to the subject matter of this EULA and supersedes all prior written or oral agreements, understanding, and communications between parties with respect to the subject matter hereof.

12.4

No Third-Party Beneficiaries. This Agreement does not create any third-party beneficiary rights in any individual or entity that is not a party to this Agreement.

12.5

No Waivers. The failure by us to enforce any provision of this Agreement will not constitute a present or future waiver of such provision nor limit our right to enforce such provision at a later time. All waivers by us must be in writing to be effective.

12.6

Severability. If any portion of this Agreement is held to be invalid or unenforceable, the remaining portions of this Agreement will remain in full force and effect. Any invalid or unenforceable portions will be interpreted to effect and intent of the original portion. If such construction is not possible, the invalid or unenforceable portion will be severed from this Agreement but the rest of the Agreement will remain in full force and effect.

12.7

Amendment. You acknowledge and agree that Sangfor may amend this EULA from time to time at Sangfor’s discretion by publishing an amended version through the activation registration, login, or update interface of the Product. If you continue to use the Product after the amendment, you represent that you have fully read, understood, and accepted the amended version.

12.8

Notice. We may provide notice to you under this Agreement by i) posting a notice on our website, pushing system notification, popping up on the Product interface or customer portal (which will be effective upon posting), ii) by email or text (which will be effective upon sending out, no matter you receive or read it). You shall be responsible to keep your contact information (including but not limited to your email address, and phone number) current and accurate.

12.9

Headings. The headings, including article titles, are given solely as a convenience to facilitate reference. Such headings shall not be deemed in any way material or relevant to the construction or interpretation of this Agreement or any of its provisions.

12.10

Language. This Agreement is prepared and executed in English. Any other language version (if applicable) of this Agreement is provided for reference only. In the event of any inconsistency between the English version and the other version, the English version shall prevail.

12.11

Cumulative Remedies. Except as expressly set forth in this Agreement, the exercise by either party of any of its remedies will be without prejudice to any other remedies under this Agreement or otherwise.

12.12

Trade Compliance. In connection with this Agreement, both parties shall comply with the applicable export and sanction laws and regulations of the United Nations, China, the Unites States, and other countries. You represent and warrant that you, or any party that owns or controls you, are not subject to sanctions or otherwise designated on any list of prohibited or restricted parties, including but not limited to the listed maintained by the United Nations Security Council, the United States Government, the European Union or its Member States, or other applicable government authority. You shall be solely responsible for compliance related to your subscription, access, and use of the Product.

12.13

Governing Law and Dispute Resolution. This Agreement shall be governed by and construed in accordance with the laws of Hong Kong, excluding its conflict of law principles. Any dispute, controversy, difference or claim arising out of or relating to this Agreement, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to it shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The seat of arbitration shall be Hong Kong. The number of arbitrators shall be three.The arbitration proceedings shall be conducted in English.

12.14

Auditing Customer Compliance. You shall retain records pertaining to Product usage. You grant to Sangfor and its independent advisors the right to examine such records no more than once in any twelve-month period solely to verify compliance with this Agreement. In the event that such an audit reveals non-compliance with this Agreement, you shall promptly pay the appropriate license or subscription fees, plus reasonable audit costs, as determined by Sangfor.

12.15

Survival. Articles regarding use restrictions, term, and termination, intellectual property, limitations of liability, disclaimers, indemnification, confidentiality, governing law, and dispute resolution, and this miscellaneous section shall survive termination of this Agreement.

12.16

Conflict. If there is any conflict between this Agreement and other proprietary agreement for the Product, the provisions of the proprietary agreement shall prevail; If there is any conflict between this Agreement and the purchase order, agreement, or contract, signed between you and the Approved Source in a specific project, the provisions of this Agreement shall prevail.

12.17

Contact Information. If the Customer has any questions, comments or suggestions during the use of the Product, you may contact Sangfor by sending an email to marketing@sangfor.com to obtain product-related technical support or to consult with the protection of your rights and interests. The Customer can also contact Sangfor and submit relevant demands by calling the following hotline:

Pre-sales consulting hotline: 4008066868

Sangfor technical support, remote, or after-sales hotline (within the service period): 4006306430

Last Updated: May 30, 2025

Thank you for your interest in the Sangfor Community! The Sangfor Community (“Platform”), developed by Sangfor, is provided to enable Users (or “you”) to share knowledge, exchange comments and suggestions on Sangfor products.

Sangfor takes your privacy concern seriously and fully respects your privacy. Sangfor is committed to strictly complying with applicable laws and regulations to take appropriate security measures to ensure your privacy in a secure and controllable status. To achieve this objective, the service provider of this Platform (hereinafter referred to as “Sangfor” or "we") has prepared and published this Privacy Policy (hereinafter referred to as the "Policy").

To protect your rights, this Policy will explain to you how Sangfor collects, uses, shares, discloses and stores your privacy and which security measures have been taken to protect the End User Data (including but not limited to personal information) and the rights to which you are entitled. In addition to this privacy, we may inform you of the processing details of other End User Data which are not described in this Policy by way of a separate privacy notice or statement in advance and seek your consent as necessary, for example when you choose to activate or use a new service.

This Policy is closely related to your use of the Platform and relevant services. Therefore, please carefully read and understand all terms of this Policy, and confirm that you have fully understood and agreed to them before using the Platform. Your clicking of the “I accept” or similar button or check box online or using the services of the Platform by any other means, constitutes your understanding and acceptance of this Policy, which shall have legal effect between you and Sangfor.

This Policy will help you understand the following:

1. Application scope of this Policy

2. How we collect and use your personal information

3. How we share, transfer, and disclose your personal information

4. How we store your personal information

5. How we protect your personal information

6. How you access and manage your personal information

7. How we use cookies and similar technologies

8. Protection of minors

9. Updates to this Policy

10. Contact us

1. Application scope of this Policy

Unless specifically stated or otherwise exclusively agreed, this Policy only applies to the Platform and other services you access through the Platform. This Policy does not apply to any products or services provided to you by third parties through this Platform. Before choosing any third-party products or services, you should fully understand the features and privacy policies of the third-party products or services and agree with third parties on the specific rights and obligations related to the use of products or services.

2. How we collect and use your personal information

In the course of your use of the Platform and the relevant services, the information we collect is as follows:

2.1 In order to help you complete the Platform account registration, we require you to provide mandatory including your username, email address, country/region of residence, and company affiliation.

Additionally, you may voluntarily provide optional information including your city of residence, profile avatar, personalized signature, occupation, and gender designation to further enhance your profile and platform interactions. You could also add submit your mobile number for convenient login authentication and password recovery, as well as residential or office address details when required for reward redemption.

2.2 When engaging in the Platform discussions by publishing posts or comments, we will process and retain the textual and multimedia content you submit.

2.3 In order to assist Users in participating in the relevant learning and examination activities, and to provide you with the necessary information and feedback, we will collect detailed engagement records during your participation in online learning modules and certification exams, which include accessed courses, exam timestamps, and submitted academic content (e.g., assignments or examination responses).

When User’s questions, interactions, comments or other published content during your engagement of these activities are selected for the Platform recommended topic, they may be viewed or accessed by other Users of the Platform.

2.4 In order to administer technical certification programs, we mandate the submission of personally identifiable information, including your full name, mobile number, identity document, email address, and scheduled examination details. This data is essential to verify your identity, coordinate examinations, and issue credentials. After you pass the relevant technical certification, we will retain your certification records indefinitely to support statistical analysis, program management, and user-initiated verification requests.

2.5 In order to deliver service notifications and informational updates, we may disseminate communications via SMS (linked to your registered mobile number), email, or in-platform messaging systems. You can stop receiving our service information through SMS unsubscribe, email unsubscribe, customer feedback and other ways.

2.6 To enhance use efficiency and improve user experience, the Platform provides User with an AI-powered Intelligent Customer Service, which is designed to accurately understand and resolve product-related inquiries, including but not limited to questions about product features, usage instructions, troubleshooting guidance, etc. To enable your interaction with the AI-powered Intelligent Customer Service, we will use your account information, including your username and email address.

2.7 In order to fulfill cybersecurity obligations under applicable laws and regulations, maintain the stable operation of the Platform, and to optimize your use experience, during your use of the Platform, we may collect information about your device and how you and your device interact with the Platform, including device identifiers (device name, device model, mobile phone model, IMEI, MAC address, serial number), IP address, operating system version,and usage patterns (session duration, interaction logs, system event reports such as errors or crashes). This information is analyzed to verify your identity, strengthen account security protocols, diagnose technical anomalies, and mitigate operational risks.

2.7 Exceptions

You are fully aware that, in accordance with applicable laws, we may collect and use relevant personal information without your authorization or consent under the following circumstances:

2.7.1 It is related to the performance of our obligations specified by laws and regulations.

2.7.2 It is directly related to national security and national defense security.

2.7.3 It is directly related to public safety, public health, or major public interests.

2.7.4 It is directly related to criminal investigation, prosecution, trial, or judgment execution.

2.7.5 It is for the purpose of safeguarding the life, property, or other significant legitimate rights and interests of you or other individuals while it is difficult to obtain your consent.

2.7.6 The personal information involved is disclosed to the public by you.

2.7.7 It is necessary to execute and perform the contracts or agreements between you and us.

2.7.8 The personal information is collected from the information disclosed to public legally, such as through legal news reports, government information disclosures, or other channels.

2.7.9 It is necessary to maintain the operational security and stability of our products or services, such as discovering and handling the failure of our products or services.

3. How we share, transfer, and disclose your personal information

3.1 Sharing

We will not share the personal information that we process or are authorized to process with any third party, except in the following circumstances:

3.1.1 Business Partner with Sangfor. To the extent necessary for the operation and relevant service provision of the Platform, we may share your personal information with our business partners. Under such circumstances, we will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, strictly limit such sharing to the minimum necessary scope, and take appropriate technical and management measures to safeguard End User Data. Our business partners include:

Distributor and Reseller: As Sangfor has conducted global business based on our Distributor and Reseller network, we may need to share your name, contact details, and other personal information stated in Section 2 with our Distributor or Reseller to deliver relevant support services.

To operate the Platform, Sangfor may engage some service providers, technical supporters, and other third parties for order inquiries, payment and invoicing, logistics and delivery, after-sales services and customer support, reward redemption, etc.

3.1.2 We have obtained your explicit consent. After informing you of the name, the contact details of the third parties, the purpose and manner of the processing, as well as the type of personal information involved, and obtaining your explicit consent, we will share the information with the third parties within the authorization scope.

3.1.3 Sharing for the performance of the legal obligation. We may share your personal information in accordance with applicable laws and regulations, legal proceedings, litigation/arbitration, compulsory governmental orders or regulatory requirements; for example, in order to meet the requirements for identification authentication of relevant laws and regulations, it is necessary to share your personal information with the relevant governmental authorities or authorized third parties.

3.1.4 To the extent required or permitted by law, it is necessary to provide your personal information to a third party in order to protect the interests, property or safety of you or the public from damage.

3.1.5 It is necessary to share your personal information in order to protect national security, public safety and the significant legitimate rights and interests of you and other subjects.

3.1.6 Personal information that you disclose to the public or that we can obtain from other legitimate public sources.

3.1.7 We may share your personal information with our affiliates to provide you with transaction support, service support or security support. For example, to avoid duplicate account registrations, we need to verify the uniqueness of the accounts to be registered; we will only share your information with our affiliates for specific, explicit and lawful purposes, and only to the extent necessary to provide the Services.

3.1.8 Sharing with business partners as necessary to provide services. We may provide your personal information to business partners with your consent for the purpose of providing you with the required Service or entering into a cooperation with you. Before introducing the partners, we will carry out information security related investigation or confirmation, and require the partners to take strict measures to protect your personal information through contractual instruments.

3.2 Transfer

We will not transfer the personal information that we process or are authorized to process to any companies, organizations, or individuals, except in the following circumstances:

3.2.1 We have obtained your explicit consent.

3.2.2 In the event of merger, acquisition, or bankruptcy liquidation where personal information transfer is involved, we will require that the new company or organization holding your personal information be bound by this Policy. Otherwise, we will require the company or organization to obtain your authorization or consent again. If such event does not involve the transfer of personal information, we will fully inform you of the relevant situation and delete or anonymize the personal information we hold.

3.3 Disclosure

We will not disclose relevant personal information, except in the following circumstances:

3.3.1 The disclosure is made with your express consent or at your request.

3.3.2 Disclosure in accordance with legal requirements: The disclosure is necessary to comply with compulsory requirements of laws, legal proceedings, litigation, or competent government authorities.

3.3.3 The disclosure is reasonable and necessary for the purpose of maintaining the public interests.

3.4 We may share, transfer, or disclose relevant personal information without your authorization or consent under the following circumstances:

3.4.1 It is for purposes related to national security and national defense security.

3.4.2 It is for purposes related to public safety, public health, or major public interests.

3.4.3 It is for purposes related to criminal investigation, prosecution, trial, or judgment execution.

3.4.4 It is for the purpose of safeguarding the life, property, or other significant legitimate rights and interests of you or other individuals while it is difficult to obtain your consent.

3.4.5 The personal information disclosed is from the information collected from legally publicly disclosed information, such as through legal news reports, government information disclosures, or other channels.

3.4.6 It is necessary to maintain the operational security and stability of our products or services, such as discovering and handling the vulnerability or failure of our products or services.

4. How we store your personal information

4.1 The Platform is deployed on Sangfor servers located in the Federation of Malaysia (hereafter referred to as Malaysia) and can be used by the User located outside of Malaysia. As the data processed by the Platform is triggered by the User’s independent login or use of the corresponding functions, before using the Platform, the User located outside of Malaysia shall be aware that their login and use data will be transferred to Malaysia. The User shall independently assess whether the cross-border transfer and processing of data involved in the use of the Platform meet the legal requirements applicable to you, and you shall be solely responsible for complying with the applicable legal requirements independently. As the service provider of the Platform, Sangfor will store data and take relevant management and technical measures to safeguard data security in accordance with the applicable laws and regulations.

4.2 If we need to transfer relevant personal information we process within one country or region to an overseas entity for the purpose of conducting cross-border business, we will obtain your separate consent and transfer the personal information in accordance with the applicable laws, regulations, and the provisions of the competent regulatory authorities. We will ensure to provide sufficient protection for related personal information, such as anonymizing the personal information or taking encryption or other security measures for the storage and transmission of personal information.

4.3 You understand and agree that, in order to better guarantee sufficient resources for the operation of the Platform servers so as to provide the User with more stable and high-quality services, or based on the demand for disaster recovery and backup, Sangfor may temporarily store some of the data uploaded by the User on servers other than the data center providing services, and such data will be strictly encrypted and compressed and will not be processed in any other way except for storage. And Sangfor will safeguard the data security in accordance with this Policy or other relevant agreements.

4.4 Audit log data for the Platform (which may contain the information listed in Articles 2.1 and 2.4) will be retained for not less than six months in accordance with legal requirements, and for other data uploaded by the User that contains no personal information, Sangfor will decide the retention period independently according to the business requirements of threat intelligence. In addition to the above, under the following circumstances and for the corresponding purposes, we may need to retain all or part of your information in accordance with the retention period specified in the relevant laws and regulations:

4.4.1 Comply with applicable laws and regulations and other relevant provisions.

4.4.2 Comply with a court judgment, decision or other legal process.

4.4.3 Comply with the requirements of the relevant administrative, judicial or other competent authorities.

4.4.4 Implement of this Policy or other relevant agreements, or handle any complaints/disputes, or protect the personal, property safety or legitimate rights and interests of you or other relevant subjects within the reasonable and necessary scope.

5. How we protect your personal information

5.1 Sangfor attaches great importance to your information security. We use various technical security measures to protect the information against unauthorized access, use, disclosure, abuse, alteration, destruction, or loss, for example, we provide secure browsing on the Platform using the HTTPS protocol; we use encryption technology to increase the security of End User Data; and we use trusted protection mechanisms to prevent malicious attacks on End User Data. In addition, we establish End User Data security management systems and work processes to strictly control access to End User Data; restrict the permissions of the staff having access to personal information and provide them with training relating to security and confidentiality; and regularly conduct personal information security risk assessments and promptly handle related risks, to continuously improve our ability to protect the security of personal information.

5.2 In addition to our obligation to protect your personal information, you are also responsible for the appropriate use and safekeeping of information relating to your account, so please set a password with a high level of complexity in order to maximize account security. If you identify that anyone is using your account without your authorization, you shall immediately report this to the personnel who has assigned the account access to you or contact us to assist you in stopping the unauthorized use.

5.3 In the event of a personal information security incident (information leakage or loss), we will, in accordance with applicable laws and regulations, promptly inform you of the basic information and possible impact of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and the remedies for you in a reasonable manner. We will promptly inform you of the incident-related situation by email, letter, phone call, online push and notification, etc. If it is difficult to inform the data subject separately, we will take a reasonable and effective way to make a public announcement. In addition, we will report our handling of the personal information security incident in accordance with the requirements of regulatory authorities.

5.4 THOUGH WE WILL USE OUR BEST EFFORTS TO TAKE REASONABLE MEASURES TO PROTECT THE SECURITY OF END USER INFORMATION, THERE ARE NEITHER COMPLETELY PERFECT SECURITY MEASURES NOR UNBREAKABLE SERVICES, PRODUCTS, WEBSITE, DATA TRANSFER, INFORMATION SYSTEM OR NETWORK CONNECTION IN THE EVENT OF ANY UNAUTHORIZED ACCESS TO, PUBLIC DISCLOSURE OF, UNINTENTIONAL ALTERATION OF, OR DESTRUCTION OF INFORMATION DUE TO A BREACH OF OUR PHYSICAL, TECHNICAL, OR MANAGERIAL SAFEGUARDS, WHICH RESULTS IN DAMAGE TO YOUR LEGAL RIGHTS AND INTERESTS, WE WILL ASSUME THE RESPONSIBILITIES AND LIABILITIES ARISING THEREFROM. IN THE EVENT OF ANY END USER DATA LEAKAGE, LOSS, OR OTHER SECURITY INCIDENT ARISING OUT OF YOUR DISCLOSURE OF THE PRODUCT OR SERVICE ACCOUNT AND PASSWORD TO A THIRD PARTY, YOUR BREACH OF THE RELEVANT PRODUCT OR SERVICE USE AGREEMENT, OR OTHER REASONS ATTRIBUTABLE TO YOU, OR HACKING, INTRUSION OF COMPUTER VIRUSES, OR OTHER REASONS ATTRIBUTABLE TO THIRD PARTIES, OR FORCE MAJEURE, YOU UNDERSTAND THAT SANGFOR SHALL NOT BEAR ANY DIRECT OR INDIRECT LOSS OR LIABILITY ARISING THEREFROM.

6. How you access and manage your personal information

Under applicable data protection laws, you may have the following data protection rights:

6.1 You have the right to access and manage your personal information processed by Sangfor.

6.2 You have the right to demand the rectification of any incorrect or inaccurate personal data we hold with respect to you.

6.3 You have the right to object to processing of your personal data, or ask us to restrict processing of your personal data..

6.4 You may also request us to delete your relevant personal information under the following circumstances:

6.4.1 Our processing or authorized processing of relevant personal information violates applicable laws and regulations.

6.4.2 We collect and use your personal information without your express consent.

6.4.3 Our processing or authorized processing of relevant personal information seriously breaches the relevant agreement.

6.5 You have the right to withdraw your consent previously made and relating to the processing of your personal data with future effect. However, such withdrawal of consent does not affect the legitimacy of any processing operations previously executed. To exercise any of the above rights, please contact us by following the instructions available in the Section 9 "Contact Us" in this Privacy Policy.

6.6 Response to your request

6.6.1 When you claim the said rights, we may require you to submit a written request and may verify your identity. In principle, we do not charge a fee for your reasonable requests, but we will charge a certain cost for repeated requests that exceed reasonable limits, as appropriate. We may reject requests that are repeated for no reason, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legitimate rights and interests of others, or are highly impractical (for example, involving the backup of information stored on tapes).

6.6.2 To ensure security, you may need to submit a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

6.6.3 Under the following circumstances, we will not be able to respond to your request:

6.6.3.1 It is related to the performance of your obligations specified by laws and regulations.

6.6.3.2 It is directly related to national security and national defense security.

6.6.3.3 It is directly related to public safety, public health, or major public interests.

6.6.3.4 It is directly related to criminal investigation, prosecution, trial, or judgment execution.

6.6.3.5 We have sufficient evidence that you have subjective malice or abuse of rights.

6.6.3.6 It is for the purpose of safeguarding the life, property, or other significant legitimate rights and interests of you or other individuals.

6.6.3.7 Response to your request will cause serious damage to the other legitimate rights and interests of related individuals or organizations.

6.6.3.8 It involves trade secrets.

7. How we use cookies and similar technologies

7.1 Cookies are small data files that are installed on your computer or mobile endpoint device when you visit a website. The content of a cookie can only be retrieved or read by the server that created it. We may record and use information about you through cookies, but the information recorded through cookies is only stored on your local device and only processed when you are using the relevant features/services of the Platform. The specific purposes for which we use cookies include:

7.1.1 To remember your identity for the purposes of logging in and completing authentication, e.g. cookies help us to recognize you as a registered User of Sangfor;

7.1.2 To store your operational settings or preferences so that you can have a more efficient experience.

7.1.3 To count and analyze your use of the Platform in order to provide you with a more thoughtful and personalized service, which may include, but is not limited to, customized pages, content recommendations, etc.

7.2 Other similar technologies

In addition to cookies, we may use other similar technologies to collect information automatically. For example, we may use browser web storage (including through HTML5), also known as local storage objects, for purposes similar to cookies.

7.3 Most web browsers have settings to block cookies and clear the browser’s web local storage, which you can manage or clear according to your preferences. Please note that if you set to block the operation of cookies or other similar technologies, you may not be able to enjoy an optimal experience of the Services and the usability of certain features may be affected.

8. Protection of minors

8.1 Our Products and Services are provided mainly to adults. We attach great importance to the protection of personal information of minors. If you are a minor, you must ask your parent or other guardians to carefully read this Policy and you may use our products or services or provide information to us after obtaining the consent of your parent or other guardians.

8.2 In the case of the collection of personal information of minors who use the Platform with the consent of their parents or other guardians, we will only process the relevant information as permitted by law, with the express consent of the parents or other guardians, or as necessary for the protection of the minors.

8.3 In the event that Sangfor identifies any collections of personal information of minors without obtaining verifiable consent of their parents or other guardians, we will seek to obtain valid consent from their parents or other guardians or delete the relevant personal information as soon as possible.

9. Updates to this Policy

We may revise and update this Policy from time to time according to changes in the management and operation of the Platform or the processing of personal information. If the update of this Policy may result in any material reductions of your rights under this Policy, or involves any changes of important regulation such as expanding the scope of our processing activities, we will notify you to check the updated Policy by posting a notice in a prominent position on the page of this Platform, popping up, or sending an email or other reasonable means. Your continued use of the Platform under the above circumstances constitutes your understanding and acceptance of the updated Policy.

10. Contact us

If you have any questions about this Policy or other matters related to the use of the Platform, or have any comments or suggestions, you may contact Sangfor by sending an email to privacy@sangfor.com We will review the information you submit as soon as possible upon receipt and will provide you with timely feedback after your demand is clarified.

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