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March 4, 2026

Galaxea Privacy Policy

We are well aware of the importance of personal information to you, and we thank you for your trust in us. Through the Galaxea Privacy Policy (hereinafter referred to as "this Policy"), we explain how we collect, store, protect, use, and provide to external parties your personal information when you visit the website of Xinghaitu (Beijing) AI Technology Co., Ltd. and its affiliates (including but not limited to Suzhou Xinghaitu Dynamics Technology Co., Ltd.) (collectively, "we") or otherwise interact with us (collectively, "using the Services"), as well as how you may exercise your rights as a personal information subject.

We have endeavored to express this Policy in plain and concise language, and have used bold type to highlight the provisions concerning your vital rights and interests and the sensitive personal information, in order to draw your attention to them. This Policy is closely related to your use of the Services. We recommend that you read this Policy carefully and fully understand its terms before using the Services. If you choose to continue using the Services, you will be deemed to have read and agreed to this Policy.


How We Collect and Use Personal Information

In the course of your use of the Services, we will collect and use, in the following ways, the personal information that you provide, that you authorize to be provided, or that is generated as a result of your use of the Services:

Inquiring About or Purchasing Our Products and Services, and Obtaining Support

If the company or organization to which you belong wishes to learn about or purchase our products or services, or to obtain other support, we may collect your name, country/region, contact information (mobile phone number), company (optional), email address, address, unit number (optional), room number (optional), postal code, inquiry content, brief description of your needs, and products of interest, which you fill in on our website on your own, or which you or the company or organization to which you belong provide when interacting with us in other ways. We will collect the foregoing personal information from you only for the purpose of responding to your needs, and of concluding and performing the contract with the company or organization to which you belong.

Robot Data Collection

For the purposes of robot product research and development, testing and verification, performance optimization, and other related work, we may use robots or other devices to collect data such as task objects, robot status, and the surrounding environment. If you enter the shooting range of a robot during the data collection process, we may record your appearance in the images/videos, such as your body outline, posture, movements, clothing, and facial images. If you knowingly choose to enter the shooting range despite being aware of the presence of the relevant robot, you will be deemed to have voluntarily made the relevant information public. If you do not wish us to collect and process your personal information, please pay attention to the notices we have set up at the collection site and refrain from entering the shooting range.

If you believe that we have already collected your personal information and that you do not wish us to process your personal information, you may contact us through the contact information provided in the "Contact Us" section of this Policy.

Supplier and Partner Management

If you or the company or organization to which you belong is our supplier or partner, for the purposes of admission assessment of suppliers and partners, qualification verification, business communication, and cooperation management, we may collect and process the relevant information that you or the company or organization to which you belong voluntarily provide or that is generated in the course of the cooperation, including: name, company, position, contact information, and other necessary information related to the aforesaid purposes. If you do not provide the aforesaid information, it may affect the establishment or continuation of our cooperative relationship with you or the company or organization to which you belong, and the handling of related business.

Recruitment

When you apply for a position with us, we will collect the personal information that you voluntarily provide, including your name, mobile phone number, email address, gender, date of birth, native place, city of residence, recruitment channel, remarks, resume attachment, education history, job-seeking intentions (most recent position, expected position, expected work city, expected salary, current status), work history, family information, training history, self-evaluation, and any other personal information related to the recruitment scenario that you submit voluntarily. If you do not provide such information, you will be unable to enter our application process.

In accordance with the relevant provisions of laws and regulations, we are entitled to process (including collect, use, entrust the processing of, share, transfer, and publicly disclose) your personal information without seeking your authorization and consent in the following circumstances:

(a) where it is necessary for the conclusion or performance of a contract to which you are a party;

(b) where it is necessary for us to fulfill our statutory obligations;

(c) where it is necessary for responding to a sudden public health incident, or for protecting the life, health, and property of natural persons in an emergency;

(d) where your personal information is processed within a reasonable scope for acts such as news reporting and public opinion supervision carried out in the public interest;

(e) where personal information that you have made public yourself or that has otherwise been lawfully made public is processed within a reasonable scope in accordance with the applicable provisions; and

(f) other circumstances prescribed by laws or administrative regulations.

Unless you reject our processing by means of deletion, withdrawal of consent, or otherwise, during the period in which you use the Services, we will use your personal information within the scope that complies with laws and regulations and that has a direct or reasonable connection with the purposes declared in this Policy. If the information we collect and use based on the needs of the Services exceeds the scope described above, we will separately explain to you the scope and purposes of the information collection by means of on-page notices or as agreed in the relevant agreements, and will seek your consent as required by laws and regulations.

Third parties may provide services to you through our channels. When you enter a service page operated by a third party or use a third-party service, and the third party collects your personal information from you, you are advised to carefully review the privacy policy of such third party; we are not responsible for the third party's processing of your personal information.

You confirm that, where the personal information you provide to us includes the personal information of other persons, you have notified the relevant persons of this Policy and sought their consent (where applicable).

How We Store and Protect Personal Information

In general, we will store personal information collected within People's Republic of China ("China") in the territory of China in accordance with the provisions of laws and regulations.

In general, we retain your personal information only for the period necessary to achieve the relevant purposes, for example, for the term of our cooperation with you. In the event that our products or services cease operation, we will notify you by means of notices, announcements, or the like, and will delete your personal information or anonymize it within a reasonable period.

We will take reasonable measures to protect your personal information so as to prevent the loss, leakage, damage, unauthorized access, and unauthorized disclosure of the information. For example, we will use storage and transmission encryption technologies, user permission management, and other means to protect your personal information. We have strict information security rules and procedures, and dedicated network engineers within the company strictly implement the aforesaid measures. In the event of a security incident such as the leakage of personal information, we will initiate emergency response measures to prevent the security incident from expanding, and will notify you and report to the competent authorities as required by the relevant laws and regulations.

Please understand that the Internet environment is not one hundred percent secure. Notwithstanding the aforesaid security measures, please note that "perfect security measures" do not exist on the Internet, and we will do our utmost to ensure the security of your personal information. If you discover that the personal information we hold may have been or has been leaked, please contact us immediately, so that we can take corresponding measures in a timely manner to avoid or reduce any possible adverse impact on you.

Cross-Border Transfer of Personal Information

In principle, the personal information that we collect and generate in the course of our operations within the territory of the People's Republic of China is stored within China.

As our business is distributed across the globe, in specific circumstances, we may transfer your personal information outside of China (including to the Hong Kong Special Administrative Region, the Macao Special Administrative Region, and the Taiwan). We take measures to ensure that our processors provide an adequate level of data protection by ensuring that appropriate protection measures are in place and that data transfer arrangements are duly implemented. We will ensure that your personal information is provided outside of China only after we have fulfilled the obligations prescribed by the applicable data protection laws.

How We Entrust the Processing of, Share, Transfer, and Publicly Disclose Personal Information

  • Entrusted processing: To improve the efficiency of information processing, we may entrust a third party to process your personal information on our behalf. With respect to any third party to which we entrust the processing of personal information, we will enter into an agreement with it, requiring it to process personal information in accordance with the agreement, this Policy, and the requirements of the relevant laws and regulations.

  • Sharing: We will not share your personal information with other companies, organizations, or individuals, except in the following circumstances: (1) sharing where your separate consent has been obtained; (2) sharing under circumstances prescribed by law or upon the request of a government department vested with corresponding authority by law; and (3) sharing where the submission of part of your information is necessary for providing the service you have requested.

  • Transfer: As our business continues to develop, we may carry out transactions such as mergers, acquisitions, and asset transfers. We will inform you of the relevant circumstances and, in accordance with laws and regulations and at a standard no lower than that required by this Policy, will continue to protect your personal information, or will require the recipient to process and continue to protect your personal information in accordance with this Policy. If the recipient changes the original purpose and means of processing, it shall obtain your authorization and consent anew in accordance with the law (except as otherwise provided by laws and regulations).

  • Public disclosure: In principle, we will not publicly disclose to external parties the personal information we have collected. If public disclosure is indeed necessary, we will inform you of the purpose of the public disclosure, the types of information to be disclosed, and the personal information that may be involved, and will obtain your separate consent.

Your Rights as a Personal Information Subject

During the period in which you use the Services, if you need to access, copy, correct, supplement, delete (or cancel your account, where applicable), or restrict the processing of your personal information, or if you need to withdraw your consent to the use of your personal information, or to exercise other statutory rights, please contact us through the contact information provided in the "Contact Us" section of this Policy, and we will respond to you within the statutory period.

After you withdraw your consent (where applicable) or delete your personal information (where applicable), we will delete or anonymize your personal information in accordance with the requirements of applicable laws and regulations.

To the extent permitted by laws and regulations, we may be unable to respond to your request to exercise your rights in the following circumstances:

  • where your request is contrary to our fulfillment of the obligations prescribed by laws and regulations;

  • where the requested information is directly related to national security or national defense security;

  • where the requested information is directly related to public safety, public health, or major public interests;

  • where the requested information is directly related to criminal investigation, prosecution, trial, and the enforcement of judgments;

  • where we have sufficient evidence to prove that you have subjective malice or have abused your rights;

  • where it is for the purpose of protecting major lawful rights and interests such as the life or property of you or other individuals, but it is difficult to obtain your authorization and consent;

  • where responding to your request to exercise your rights would cause serious damage to the lawful interests of you or other individuals or organizations; or

  • where the requested information involves trade secrets.

How We Protect the Personal Information of Minors

We provide services only to adults, and we do not provide services to minors under the age of eighteen (18). If you discover that we have collected the personal information of a minor under the age of eighteen (18) without the consent of his or her parent or other guardian, please contact us through the contact information provided in the "Contact Us" section of this Policy. We will, after verification, delete or otherwise process such information in accordance with the law and the requirements of the parent or other guardian.

Application and Updates of This Policy

This Policy applies to the functions of the Services that you use, as well as new functions to be launched from time to time. We will update this Policy in a timely manner upon the occurrence of any of the following major changes: (1) our basic circumstances change, for example, a change of owner resulting from a merger, acquisition, or reorganization; (2) the scope, purposes, or rules for the collection, storage, and use of personal information change; (3) the manner in which you access and manage your personal information, or the channels and mechanisms for inquiries and complaints, change; (4) our data security capabilities or information security risks change; or (5) other changes that may have a material impact on your rights and interests in your personal information.

If this Policy is updated, we will notify you by means such as an announcement on our website. If you continue to use the Services after the updated Policy takes effect, it means that you have fully read and understood the updated Policy and are willing to be bound by the updated Policy. You may view the latest version of this Policy on our official website.

Contact Us

We have designated dedicated personnel to be responsible for personal information protection. If you have complaints, suggestions, or questions regarding this Policy or the processing of your personal information, please contact us through the contact information announced on our website.

We will review and respond to you as soon as possible, and we undertake that the issues involved will be replied to with our handling opinions or the results within the period prescribed by the applicable law.