BlueSword (hereinafter referred to as "BlueSword", "We" and "Our") understands the importance of privacy to you and respects your privacy. Please read and understand this Privacy Policy (hereinafter referred to as "Policy") before submitting your personal data to BlueSword. This policy applies to Websites owned and operated by BlueSword. This policy describes the information practices of BlueSword Website, including what information is collected, how it is used, with whom it is shared and how it is protected.

This policy also explains how to process your personal data, but may not cover all possible data processing scenarios. BlueSword Websites may contain links to other Websites. BlueSword is not responsible for the privacy practices or content of these Websites.

We have developed this policy to help you understand the following contents:

1. How does BlueSword collect and use your personal data

2. How does BlueSword use cookies and similar technologies

3. How does BlueSword disclose your personal data

4. How to access or modify your personal data

5. How does BlueSword protect and retain your personal data

6. How does BlueSword process children's personal data

7. Third party providers and their services

8. How your personal data is transferred globally

9. How to update this policy

10. How to contact BlueSword

1. How does BlueSword collect and use your personal data

Personal data is information that identifies an individual when it is used alone or in combination with other information. Such data will be submitted directly to us when you use our website, products or services, and interact with us. For example, these data are obtaining when you create an BlueSword account or contact us for support; or we record how you interact with our Websites, products, or services, such as cookies technology, or receiving usage data from software running on your device. We will also obtain data from public and commercial third-party sources as permitted by law. The data we collect depends on how you interact with BlueSword, including the Websites you visit or the products and services you use, including name, gender, business name, title, address, email address, phone number, login information (account number and password), photos, document information etc. We also collect the information you provide to us and the content of the messages you send us, such as the query information you enter or the questions or device information you provide to receive customer support. You may be required to provide your personal data when using BlueSword products or services. In some cases, you may choose not to provide personal data to BlueSword, but if you choose not to provide it, BlueSword may not be able to provide you with related products or services, or respond to or solve your problems.

We may use your personal data for the following purposes:

(a) Create an account.

(b) Fulfill your transaction or service request, including executing orders; delivering, activating or verifying products or services; providing training and certification and managing and processing training and certification results; participating in online or offline activities; changing or providing information you request (such as marketing materials for products or services, white papers) at your request; and providing technical support.

(c) Contact you with your consent; send you information about products and services that may be of interest to you; invite you to participate in BlueSword events, market research or satisfaction surveys; or send you marketing messages. If you do not expect to receive such information, you can unsubscribe at any time.

(d) Send you important notifications, such as notifications for updating and installing operating system or application.

(e) Provide you with personalized user experience and content.

(f) Authenticate and manage suppliers and business partners to communicate or conduct business with them.

(g) Conduct internal audits, data analysis and research to improve our products and services.

(h) Analyze efficiency of business operations and measure market share.

(i) Troubleshoot the error if you choose to send us the error details.

(j) Synchronize, share and store the data you upload or download and perform uploading and downloading the desired data.

(k) Protect the safety of our products, services and customers or users, implement and protect us from loss and improve anti-fraud programs.

(l) Comply with and enforce applicable legal requirements, relevant industry standards or our policies.

The BlueSword may also collect and use non-identifiable data. Non-identifiable data is data that cannot be used to determine an individual's identity. For example, BlueSword collects summarized statistics, such as Website visits. The purpose of collecting these data is to understand how users use Websites, products and services. In this way, BlueSword can improve its services and better meet customer needs. BlueSword may, at its discretion, collect, use, process, transfer or disclose non-identifiable data for other purposes. We will do our best to isolate your personal from non-identifiable data and use them independently. If your personal data contains non-identifiable data, it will still be treated as personal data.

When BlueSword processes your personal data, we will comply with applicable legal requirements based on appropriate legality, including:

　· Process your personal data for fulfillment of the contract in response to your transaction or service request;

　· Process your personal data based on your consent;

　· We will be based on the legitimate interests of us or third parties when your personal data are processed for the purpose of contacting with you, conducting marketing or market research, improving our products and services, and improving our loss prevention and implementing anti-fraud programs. These legitimate interests include: helping us manage and operate our business more effectively and provide our products and services; protect the security of our businesses, systems, products, services and customers; manage internally and comply with internal policies and processes; other legal interests we describe in this policy, etc.;

　· We may also process your personal data based on compliance and enforcement of legal obligations.

2. How BlueSword uses cookies and similar technologies

2.1 Cookie

To keep our website running, we sometimes store small data files called cookies on your computer or mobile device. A cookie is a plain text file that a web server stores it on a computer or mobile device. The content of a cookie can only be retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile app. Cookies usually contains an identifier, a Website name, and some numbers and characters. With cookies, Websites can store data such as user preferences to better serve users. BlueSword’s purpose of enabling cookies is the same as that of most Websites or Internet service providers, which is to improve the user experience. With cookies, Websites can store user's a single visit (using a session cookie) or multiple visits (using a permanent cookie). With cookies, Websites can save settings such as the language, font size, and other browsing preference of computer or mobile device. This means that users do not have to reconfigure user preferences every time they visit. If a website does not use cookies, the Website treats visitor as new visitors each time he/she opens a web page. For example, if you log in to one Website and go to another page, the Website will not recognize you and you will be logged out again. BlueSword will not use cookies for any purposes other than those stated in this policy. You can manage or delete cookies based on your preferences.

In addition, we may use local storage objects (LSOs) such as Flash cookies and HTML5 to store content information and preferences. Suppliers and partners who provide certain features or display ads on our Website based on your web browsing activity may also use LSOs such as HTML5 to collect and store information. Various browsers may provide their own management tools to remove the HMTM5 LSO.

You can clear all cookies saved on your computer, and most web browsers provide the function of blocking cookies. But if you will do this, you will need to change the user settings yourself each time you visit our Website. For more information on how to change your browser settings, please visit the following links:

Internet Explorer    Google Chrome    Mozilla Firefox    Safari    Opera

3. How does BlueSword disclose your personal data

In the event that certain services are provided by BlueSword's authorized partners, BlueSword will share your personal data with the partner as described in this policy. For example, when you buy BlueSword products online, BlueSword must share your personal data with the logistics service provider to make delivery or arrange a partner to provide the service. In addition, as an international company, we may share personal data in other language Websites of BlueSword.

In the event of applicable legal requirements or in response to legal proceedings, BlueSword may also disclose your personal data to relevant law enforcement agencies or other government agencies. BlueSword will also disclose your data in the presence of reasonable request. For example, execution of the contract and appropriate disclosure that we believe is necessary to prevent physical damage or property damage or to investigate possible or actual illegal conduct.

4. How to access or modify your personal data

You should ensure that all personal data submitted is accurate. BlueSword will endeavor to maintain the accuracy and completeness of personal data and update these data in a timely manner.

When it is required by applicable law, you may have access to specific personal data we hold about you; ask us to update or correct your inaccurate personal data; deny or restrict us from using your personal data; ask us to delete your personal data. If you want to exercise the relevant rights, please   and provide feedback to us online. In order to keep safety, you may need to provide a written request. We will refuse to process a request if we have a reasonable basis to believe that the request is deceptive, unenforceable, or harmful to the privacy of others.

You will also be entitled to cancel your consent at any time when BlueSword processes your personal data based on your consent, as required by applicable law. However, the cancellation of the consent does not affect the legality and effectiveness of our processing of your personal data based on your consent prior to cancellation, nor does it affect our ability to process your personal data based on other appropriate justifications.

If you believe that our processing of your personal information does not comply with applicable data protection laws, you may contact legal data protection agency.

5. How does BlueSword protect and retain your personal data

BlueSword values the security of personal data. We use appropriate physical, administrative, and technical measures to protect your personal data from unauthorized access, disclosure, use, modification, damage or loss. For example, we use encryption technology to ensure data confidentiality; apply protection mechanisms to protect against malicious attacks; deploy access control mechanisms to ensure that only authorized personnel have access to personal data; and hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal data. We will do our best to protect your personal data, but please note that any data transmitted over the Internet is not guaranteed to be 100% safety. Therefore, while we take appropriate steps to protect your personal information, BlueSword cannot confirm or guarantee the security of the information you provide to us or from our Website, so access to our Website is at your own risk. For information on how to report security issues, matters or possible events to the BlueSword and BlueSword information security team, please do not hesitate to contact us at [info@blueswords.com]. In the event of a personal information security incident, we will promptly notify you and report to the regulatory authorities in accordance with the requirements of laws and regulations.

The personal data we collect will be stored and processed in your region, the European Union, the United States, and any other country where BlueSword or its affiliates, subsidiaries, or service partners. BlueSword's main data center is located in China and has strict data security protection and efficient operating mechanisms to avoid the risk of service interruption or data leakage. We take appropriate control to ensure that the data collected under this privacy statement complies with the requirements of this statement and the applicable laws of the location where the data is located. We will retain your personal data in a period of time required to achieve the purposes described in this policy, unless it is required by law or permission to extend the retention period. Because the data storage period may vary based on different scenarios and products and services, the criteria we use to determine the retention period include: the time required to retain personal data for the purpose of completing the business, including the provision of products and services, maintenance of corresponding transaction and business records, control and improvement of the performance and quality of products and services, guarantee of the safety of systems, products and services, response to possible user inquiries or complaints, problem identification etc.; whether users agree to extend the retention period; whether there are special requirements for retaining data required by laws and contracts. We will retain your registration information as long as your account is required to provide services to you. You can also choose to cancel your account. After you cancel your account, we will stop providing products and services based on this account and delete your corresponding personal data without special legal requirements.

Our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.

6. How does BlueSword process children's personal data

Our products, Websites and services are primarily for adults. Children may not create their own user accounts without the consent of their parents or guardians. For the collection of children's personal data with parental consent, we will only use or disclose these data if it is permitted by law, obtains explicit consent of the parent or guardian, or is absolutely necessary to protect the children. If BlueSword finds that it has collected the children's personal data without prior verifiable parental consent, we will try to delete the data as soon as possible.

7. Third party providers and their services

To ensure a smooth browsing experience, you may receive content or web links from BlueSword and our partners (hereinafter referred to as "third parties").

BlueSword has no control over such third parties. You can choose whether to access links, content, products, and services provided by third parties. BlueSword cannot control the privacy and data protection policies of third parties, and such third parties are not bound by this policy. Please refer to the privacy policies of these third parties before submitting personal information to them.

8. How your personal data is transferred globally

Since BlueSword is a global company, we may share your personal information within BlueSword (including subsidiaries, affiliates and parent companies) or with our suppliers and business partners as permitted by law, and may transfer information to other countries where we have business. In such cases, BlueSword will take steps to ensure that the data we collect is processed in accordance with the requirements of the policy and applicable laws. When the personal data of the data subject located in the EU is transferred to a country or region where the same data protection level is not accepted by the European Union, BlueSword will use various legal mechanisms, such as signing the standard contract terms approved by the European Commission or requesting your consent of cross-border transferring of personal data or implementing security measures such as data anonymity before transferring cross-border data.

Where BlueSword stores or transfers personal information, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.

9. How to update this policy

BlueSword reserves the right to update or modify this policy on a regular basis. If our privacy policy changes, we will post the latest version of our privacy policy here. If we make material changes to our privacy policy, we may also send you notifications of changes through different channels, such as posting a notice on our website or sending an email (sent to the email address specified in your account) to inform you. Based on applicable data protection laws, we will also seek your consent for any material changes affecting how we use your personal information. We encourage you to check this page regularly for the latest information on our privacy practices.

10. How to contact the BlueSword

If you have any questions, comments or suggestions, please contact us.

When BlueSword processes your personal data in accordance with this Privacy Policy, the BlueSword Entity that responds to your request, contacts you, provides you with products or services, or concludes or signs contract with you is the controller of the relevant personal data.