YEARLY PLAN Personal Information Processing Rules

Last updated: August 4, 2026

In accordance with the Personal Information Protection Law of the People’s Republic of China and other applicable laws and regulations on the processing of personal information, we, the operating entity of the YEARLY PLAN brand (registered address, contact details and filing information are subject to the information published at the footer of the Website, in the filing information, legal notice or “Contact Us” page; hereinafter “YEARLY PLAN” or “we”), hereby explain through these Personal Information Processing Rules (these “Rules”) how we process your personal information in the context of our official website.

These Rules apply to scenarios such as brand presentation and content browsing on the YEARLY PLAN official website, as well as your proactively contacting us. The Website currently does not offer user registration, does not provide member accounts, and does not provide online ordering, payment, logistics/delivery or after-sales transaction functions. If the YEARLY PLAN mini-program mall, official WeChat account, offline stores or other sales channels have separate personal information processing rules, the rules published through those channels shall prevail.

We will amend and update these Rules from time to time in accordance with applicable legal and regulatory update requirements or business changes. The most recent update date is stated at the top of these Rules; for material changes, we will provide prominent notice.

These Rules will help you understand the following:

1.How we collect and use your personal information
2.How we share, entrust the processing of, transfer and publicly disclose your personal information
3.How we protect your personal information
4.How you manage your personal information
5.How we process minors’ personal information
6.How your personal information is transferred globally
7.Data retention period
8.Cookie policy
9.How these Rules are updated
10.How to contact us

1. How We Collect and Use Your Personal Information

A. When providing you with website access services, safeguarding cybersecurity and performing relevant legal obligations, we collect and process the following necessary information:

(1) Website access and page display: when you visit the Website, in order to ensure proper page loading, display adaptation and troubleshooting, our servers receive and record your IP address, date and time of access, pages visited, referring page, browser type and version, operating system, device type, screen resolution, language preference and network status. If you refuse to provide, or your browser restricts, certain information, you may not obtain the optimal display effect, but basic browsing is usually not affected.

(2) Cybersecurity and system stability: to guard against cyber attacks, intrusions, viruses, abnormal traffic and fraud risks, we process necessary access logs, security logs and strictly necessary cookies or similar technical identifiers for risk identification, recording, auditing, analysis and handling. Such processing is necessary to ensure the operation of the Website and to fulfil cybersecurity protection obligations.

(3) Device and permissions: the Website does not proactively access device permissions such as your camera, microphone, photo album, contacts or precise geographic location. If features requiring device permissions are added in the future, we will separately indicate the purpose of use on the relevant feature page and obtain your authorization in accordance with the law; you may manage the relevant permissions through your browser or device settings.

B. When you proactively contact us, we collect and process the following information:

When you contact, communicate with or send information to us through the email address, telephone number, message entry point (if any) published on the Website or official customer service channels, you may need to provide your title or name, email address, telephone number, WeChat ID, the content of your inquiry or message, and other materials you choose to provide to explain your issue, so that we can verify your identity, understand and respond to your question, and record the progress and outcome of the handling. If you do not provide the necessary contact information, we may be unable to give you feedback on the handling outcome, but this will not affect your continued browsing of the Website.

C. Non-essential scenarios based on your consent:

As of the date of this update, the Website does not enable statistical analysis, personalized recommendations, advertising or cross-site tracking. If website statistics, content preference analysis, event registration, subscription notifications or other non-essential functions are enabled in the future, we will inform you of the purposes, methods and types of information processed through on-page notices, pop-ups, notification letters or authorization forms, and will obtain your consent where required by law; your refusal to provide information or withdrawal of consent will not affect your use of the Website’s basic browsing functions.

D. Sensitive personal information and other lawful circumstances:

The Website browsing scenario does not proactively collect sensitive personal information. Please do not submit to us, through messages, emails or other means, sensitive personal information such as ID document numbers, bank accounts, medical and health information, whereabouts/location tracks, or biometric information; if you send such information by mistake or it is genuinely necessary to provide it, we will process it only to the extent necessary to respond to your request, and will delete it promptly or apply strict protective measures once the purpose has been achieved.

To the extent permitted by applicable law, we may also process your personal information in the following circumstances: where necessary for the performance of statutory duties or legal obligations; where necessary to respond to a public health emergency or to protect the life, health and property of a natural person in an emergency; where processing, within a reasonable scope, personal information that you have disclosed yourself or that has otherwise been lawfully made public; and other circumstances provided for by laws and regulations.

Please ensure that the information you provide to us is true, accurate and lawful, and does not contain content that violates laws or regulations, has an adverse impact or infringes the rights and interests of third parties. Considering that business scenarios and website functions may change, if in the future we need to process other personal information not stated in these Rules, we will separately inform you and obtain your consent in accordance with the law.

Warranty and disclaimer when users submit third-party information: when you submit content containing third-party personal information to the Website, you shall warrant that you have obtained lawful and valid authorization for such submission, and that the information you submit contains no harmful code, malicious programs or illegal content. If a third party asserts rights or a regulatory authority conducts an investigation due to your failure to perform the foregoing warranty obligations, you shall handle the matter yourself and bear all consequences; if this causes us losses, you shall compensate us.

User responsibility and breach handling: you shall ensure that the information you provide to us is true, accurate and lawful, does not violate laws or regulations, does not infringe the lawful rights and interests of any third party, and contains no harmful code or malicious programs. You shall not use the Website to engage in any illegal, non-compliant or otherwise improper conduct. If the information or content you submit violates the foregoing requirements, or contains content that is illegal or non-compliant, infringes third-party rights and interests, or has an adverse impact, we have the right to delete the relevant content immediately and to refuse to respond to your subsequent related requests. If your conduct causes us or a third party to suffer losses, receive complaints, be penalized or become involved in disputes, you shall bear the corresponding liability and compensate us for the reasonable expenses we incur as a result, including but not limited to damages, liquidated damages, property preservation guarantee fees, appraisal fees, notarization fees, attorneys’ fees, settlement payments or administrative fines. If we first assume liability to third parties as a result, we have the right to recover from you.

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

A. Sharing. We will not sell your personal information, nor will we share your personal information with any company, organization or individual, except in the following circumstances and other circumstances to which you have separately given explicit consent:

(1) Provision as required by laws and regulations or by the mandatory requirements of competent government authorities;

(2) Sharing with other parties after obtaining your explicit consent;

(3) Processing necessary for responding to lawful requests from government authorities, regulatory authorities, judicial authorities, public security authorities or financial institutions, or for anti-fraud, anti-money laundering, compliance checks and the like;

(4) If in the future we jointly provide services chosen by you together with partners, we will only share the personal information necessary to complete such services, subject to the purposes stated in these Rules.

B. Entrusted processing. In order to provide and maintain the Website, we may entrust the following categories of service providers with processing necessary access logs, device information or contact details you proactively provide: cloud server and content delivery network providers; website security, operation & maintenance and IT system maintenance providers; email, customer service or messaging tool providers; and website statistics providers enabled with your consent. We will agree in writing with the entrusted parties on protection measures and the rights and obligations of both sides, and require them to maintain confidentiality and not to process beyond the agreed scope.

C. Transfer. In the event of a merger, division, acquisition, asset transfer, liquidation or bankruptcy involving a transfer of personal information, we will inform you of the name and contact details of the recipient and require the new company or organization holding your personal information to continue to be bound by these Rules; if the recipient changes the original processing purposes or methods, we will require it to seek your authorization and consent anew.

D. Public disclosure. We will publicly disclose your personal information only in the following circumstances: after obtaining your explicit consent; or based on law, legal proceedings, litigation or the mandatory requirements of competent government authorities.

3. How We Protect Your Personal Information

(1) We are committed to protecting your personal information. We adopt appropriate technical measures and organizational arrangements, including, where feasible, encrypted transmission, access control, permission tiering, log auditing, de-identification, defined posts and responsibilities, regular inspections and compliance audits, to restrict and manage how personal information is processed, administered and used. We likewise ensure that relevant employees receive appropriate training on personal information protection.

(2) In response to personal information security incidents, we will perform reporting and notification obligations as required by laws and regulations, including the basic circumstances and possible impact of the security incident, the measures taken or to be taken, suggestions on how you can independently guard against and mitigate risks, and remedial measures for you. Where applicable, we will promptly notify you by email, telephone, website announcement or other reasonable means; where individual notification is impracticable, we will publish an announcement by reasonable means and report to the regulatory authorities in accordance with the law as required.

(3) Notwithstanding the foregoing security measures, please understand that no security measures on information networks are perfect. We cannot promise the absolute security of data and information, and we remind you to stay away from telecom and online fraud and illicit online industries, and to properly safeguard the security of your financial accounts and online accounts.

4. How You Manage Your Personal Information

(1) Access, copying, correction, supplementation, deletion and portability. You have the right by law to access, copy, correct, supplement and delete your personal information; as the Website does not provide registered accounts, you cannot perform these operations yourself through an account page — please contact us through the contact channels published in Section 10 of these Rules to exercise the foregoing rights.

(2) Withdrawal of consent and change of consent scope. For personal information processed on the basis of consent, you may withdraw your consent through the contact channels published in Section 10 of these Rules — please specify which consent you wish to withdraw; for authorizations relating to cookies or similar technologies, you may also delete, block or restrict them through your browser settings. After consent is withdrawn, we will no longer process the corresponding personal information on the basis of that consent, but this does not affect processing already carried out on the basis of your authorization prior to withdrawal.

(3) Response time, identity verification and fees. To protect the security of your personal information, we may need to verify your identity when you manage your personal information, and may additionally obtain information used for identity verification to the extent necessary and reasonable. We in principle charge no fees for your reasonable requests; for requests that are repeated many times, exceed reasonable limits, require excessive technical means, may pose risks to the lawful rights and interests of others, violate laws or regulations, or are objectively difficult to fulfil, we have the right to refuse them, but will explain the reasons to you. You shall provide the necessary explanation of the legality and reasonableness of your request; the reasonable costs and liabilities arising from unreasonable requests shall be borne by the requesting user. We will respond to your request within fifteen working days after verifying your identity.

5. How We Process Minors’ Personal Information

The Website is a brand publicity page aimed at the general public and does not target minors; in principle, we do not proactively collect any personal information of minors. However, due to technical limitations, when providing online services we may be unable to accurately identify whether a user is a minor. We therefore remind all users: if you are a minor, please do not provide us with any personal information; minors under the age of fourteen shall use the Website with the consent and under the guidance of a parent or other guardian.

If you find that we have inadvertently collected a minor’s personal information, please notify us. We will immediately cease the relevant processing activities and, within a reasonable period, delete or anonymize the relevant personal information in accordance with the law.

6. How Your Personal Information Is Transferred Globally

In accordance with laws and regulations, we store within the territory of China the personal information collected and generated through the Website. As of the date of this update, we do not provide your personal information overseas on the basis of the Website.

Please understand that if, based on future business needs, it is necessary to ensure that you can obtain a particular service under uniform standards (for example, cross-border after-sales service, cross-border events or overseas technical support), we will transmit the necessary personal information to overseas recipients only when you use that specific service or where expressly provided by laws and regulations, and after we have performed the obligations legally required for cross-border transfers.

7. Data Retention Period

Personal information collected for the purposes of these Rules will be retained by us for whichever of the following periods expires first:

(1) The period necessary to achieve the purposes of website access, secure operation, responding to inquiries or handling complaints;

(2) The period necessary to comply with mandatory legal provisions on data retention, among which network logs retained to safeguard cybersecurity and system operation shall be kept for no less than six months;

(3) The time at which you request deletion or withdraw your consent to our processing of your personal information (except where a retention period required by laws and regulations or necessary to achieve the processing purpose has not yet expired);

(4) The time at which our processing purpose has been achieved.

After the retention period expires, we will delete or anonymize the relevant personal information; where laws and regulations provide otherwise, or deletion is technically difficult to achieve, we will cease all processing other than storage and the taking of necessary security protection measures.

All ownership of and rights and interests in derivative data generated by us through personal information processing that has been anonymized or de-identified such that it can no longer identify a specific natural person belong to us, and we have the right to dispose of and use such data at our own discretion.

8. Cookie Policy

Users of the YEARLY PLAN official website should note that we may store cookies or similar technologies in your browser or device in order to maintain sessions, ensure security and identify abnormal access. Cookies are small text data files sent from a server during browsing, usually stored in the browser or device, and used to simulate a continuous connection with the website or remember necessary states.

As of the date of this update, the Website uses only strictly necessary cookies and does not enable cookies for statistical analysis, personalized recommendations, advertising or cross-site tracking. You may set your browser to refuse cookies, but doing so may prevent you from fully using certain basic functions of the Website. For detailed categories, current status, validity periods and management methods, please refer to the Cookie Policy published on the Website from time to time.

9. How These Rules Are Updated

The most recent update date is stated at the top of these Rules. For material changes to these Rules, we will provide prominent notice. If a change involves a material change to the purposes, methods or types of personal information processing, or adds processing activities for which your consent is legally required, we will obtain your consent anew in accordance with the law. If you do not agree with the changes, you may stop using the Website; your continued use of the Website constitutes your consent to the updated Rules.

If the Website publishes historical versions or version update notes, you may view them through the relevant entry point; where no historical version entry point is provided, you may request them from us through the contact channels in Section 10.

10. How to Contact Us

If you have any questions, comments, suggestions, concerns, complaints or reports regarding the content of these Rules or how we process your personal information, please contact us through the channels published on the Website’s “Contact Us” page, or ask our official customer service to forward your request to the Legal and Compliance Department / Personal Information Protection Officer.

Contact details of the Personal Information Protection Officer: subject to the information published in the Website’s legal notice, “Contact Us” page or filing information. We will respond to your request within an appropriate period in compliance with legal requirements, and will process your request within fifteen working days after verifying your identity in accordance with these Rules and laws and regulations; if timely processing is impossible due to insufficient or untrue identity verification materials submitted by you or unclear request content, the processing period will be extended accordingly, and such circumstances shall not be deemed a delay on our part. Our response to your request shall not be deemed an admission or commitment by us as to the legality or compliance of the relevant processing activities. If you are not satisfied with our handling, you are entitled by law to lodge a complaint or report with the competent regulatory authority, or to file a lawsuit with the people’s court having jurisdiction over our location.