Privacy Policy

Last Updated: June 9, 2026

Effective Date: June 9, 2026

This Privacy Policy (hereinafter referred to as the “Policy”) applies to the earnfunvip website (www.earnfunvip.com), associated software and services (collectively “earnfunvip”) operated by Digital Trade Fuyue Technology (Shenzhen) Co., Ltd. / 数贸富越科技（深圳）有限公司 and its affiliates (hereinafter “we”, “us” or the “Company”). We strive to present this Policy in a concise, clear and easy-to-understand manner. We fully recognize the importance of your personal information and will make every reasonable effort to safeguard the security and integrity of your personal data. We are committed to maintaining your trust in us and abide by the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choosing consent, the principle of least sufficiency, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. Meanwhile, we undertake to adopt corresponding security protection measures in accordance with mature security standards in the industry to protect your personal information.

Special Note: Before using any of the services we provide, please carefully read and fully understand this Privacy Policy and make your corresponding choices. Once you opt to use or continue using our Service, you shall be deemed to consent to our processing of your relevant information in compliance with this Privacy Policy. Where you provide us with personal information belonging to any third party, you must warrant that you have obtained the third party’s full authorization. If you provide us with third-party personal information, or if you collect, use, or disclose third-party personal information while using the Service, you shall ensure that you have obtained the necessary authorizations, consents, or other legal bases as required by applicable laws. Otherwise, any risks and liabilities arising therefrom shall be borne solely by you. You must fully respect the personal information of all persons (including without limitation other users) which you obtain, receive or access via earnfunvip and its associated services. You shall not collect, duplicate, store, disseminate or otherwise use the personal information of other users without their prior authorization or otherwise permitted by law. Otherwise, any consequences arising therefrom shall be borne solely by you.

In addition, this Policy does not apply to products or services provided to you by other third parties. When you use third-party products or services through the Service, your personal privacy information shall be governed by the privacy terms of such third-party products or services. If you need to use products or services provided by third parties while using earnfunvip services, we will clearly indicate on the relevant page that such services are provided by specific third parties, and strongly recommend that you carefully read and confirm your understanding of the third party's agreements and policies regarding personal information protection prior to confirming acceptance of their products or services.

If you have any questions, comments or suggestions, you may contact us via the contact details set out in “8. How to Contact Us”. We will respond to your request within 15 business days upon receipt of your request and verification of your identity, or within the period required under applicable laws and regulations, and will provide you with external dispute resolution methods at your request.

1. How We Collect and Use Your Personal Information

1.1 We collect and process your personal information complying with the principles of lawfulness, fairness and necessity, solely for the purpose of achieving relevant functions. We strive to disclose the collection and use of your personal information to you in a comprehensive, complete and timely manner. Except for the business scenarios specified below, any personal information you submit to us while using the earnfunvip services will be deemed as your authorization and consent for us to collect and use such information in accordance with the disclosures set forth in this Policy.

1.1.1To complete account registration, login, and identity verification, we will collect your name, job title, email address, phone number, country/region, account password, and similar information. If you refuse to provide the aforementioned necessary information, you may be unable to complete registration, log-in, or use the Service properly.

1.1.2To complete the distributor profile, cooperation application and merchant review, we may collect information such as your sales categories, distribution methods, social media platforms and account details, follower count, website URL, offline store name, company registration information, offline store address, and estimated annual sales volume, depending on the online or offline distribution channel you select. If you refuse to provide the relevant necessary information, you may be unable to complete your distributor profile, submit a cooperation application, or such refusal may affect the merchant's review of your application.

1.1.3To support the establishment, management, and performance of distribution cooperation—in cases where relevant merchant rules, page features, or bilateral cooperation arrangements involve order tracking, promotion effect confirmation, commission/rebate calculation, settlement reconciliation, or dispute resolution—we may process information related to your distribution cooperation, including application records, review status, partnered merchants, store information, promotion channels, promotion effect, order or lead-related information, commission/rebate calculation, and settlement reconciliation details. If you refuse to provide or authorize the processing of the relevant necessary information, such refusal may affect the relevant distribution cooperation, commission/rebate calculation, settlement reconciliation, or dispute resolution.

1.1.4If you use the Service on behalf of a company, store or other organization, we may, based on the page functionalities, collect the organization name, store name, company registration information, and relevant contact information you submit, for the purposes of identity verification, cooperation application, merchant review and cooperation management.

1.1.5If the Service subsequently supports your authorization of third-party platforms to provide relevant information to us, we will inform you on the specific authorization page of the third-party platform name, scope of information collected, purpose of use, and authorization method, and will process such information only after obtaining your authorization.

1.1.6If the Service offers paid features in the future, we will separately inform you on the relevant page of the fee items, payment methods, information required to be collected, and the third-party payment institutions involved.

1.1.7Operating and providing the Service to you is a core part of our business activities. As necessary for normal business operations, we need to internally utilize your personal information, including conducting internal audits, data analysis, and research; we will also use the information collected for big data analysis. For example, we may use the information collected to generate statistical products that do not contain any personal information, to present an overall picture of the Service, to analyze behavioral patterns of different user groups, etc.; we may also process and analyze your usage behavior, and conduct data analysis and research, including but not limited to improving the products or services, optimizing business arrangements, assisting business decision-making, etc. We may publicly share and share with our partners big data analytics information that has been statistically processed and no longer contains personally identifiable content. As necessary for ensuring business security, network security, and service optimization, we need to collect your device information, network information, user information, user options (e.g., privacy settings), or technical or diagnostic information relating to your use of the Service. If you refuse to provide such information, we will not be able to ensure the normal operation of the Service.

1.2 Entrusted Processing: To provide and maintain the Service, we may engage third-party service providers such as cloud service providers, system operation and maintenance providers, data storage providers, data analytics providers, and customer service providers to process necessary personal information. We will enter into agreements with such entrusted parties, requiring them to process personal information solely in accordance with our purposes, methods, and scope, and to implement necessary confidentiality and security measures.

1.3 Provision to Third Parties: Unless permitted by laws, regulations, normative documents, or regulatory requirements, or with your prior separate consent, we will not provide your personal information to third parties, except in the following circumstances:

1.3.1We may provide your personal information to third parties as necessary to fulfill statutory duties or comply with mandatory requirements of government authorities.

1.3.2Based on your separate consent or other legal grounds for processing: In order to perform the agreement entered into with you or for other reasonable purposes, we may provide certain personal information about you to third-party personal information controllers, including our affiliates, service providers, and business partners. Such purposes include, but are not limited to, data storage, database management, network analytics, and payment processing. The third-party personal information controller that receives your personal information has the right to process such information within the scope of the processing purposes, methods and categories of personal information that have been disclosed to you. If the recipient intends to change the original processing purposes or methods, it must obtain your consent anew. We will ensure that such affiliates, service providers and business partners comply with this Privacy Policy and implement appropriate confidentiality and security measures.

1.3.3As necessary for contract performance: When you submit a distribution cooperation application to a specific merchant, we will display your basic application information to that merchant for the purpose of the merchant's review. Such information includes your country/region, sales channels, product categories, distribution methods, follower count, and estimated annual sales volume. If your application is approved by the merchant following its review, we will provide the merchant with the necessary contact and business information you submitted during registration, application, or profile completion, for the purposes of establishing, managing, and performing the distribution cooperation between you and the merchant. Such information includes your name, email address, phone number, social media platforms and account details, website URL, offline store name, offline store address, and other information necessary for the cooperation. The relevant merchant will process the above information for purposes including, but not limited to, distributor review, cooperation communication, business management, order and commission/rebate settlement, compliance management, and dispute resolution. The relevant merchant will act as an independent personal information controller and will process the above information within the scope of its own business and legal responsibilities. If the merchant changes the purposes or methods of processing, or processes your personal information beyond the scope described above, the merchant shall independently fulfill the corresponding legal obligations of notification, consent, or other compliance requirements in accordance with applicable laws.

For the avoidance of doubt, you should be aware and understand that the relevant products may contain links to websites, applications, products, and services operated by other independent third parties. We make no express or implied warranties regarding such third-party websites, applications, products, or services, and such links are provided solely for the convenience of users to browse the relevant pages. When you access links to such third-party websites, applications, products or services, you shall separately agree to the privacy policies or personal information protection terms they provide. We and the providers of such third-party websites, applications, products, and services each assume independent responsibility for personal information protection toward you, within the scope of applicable laws and the terms agreed between us.

1.4 Transfer: We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

1.4.1Transfer with explicit consent: With your explicit consent, we may transfer your personal information to other parties.

1.4.2Transfer in the context of mergers, acquisitions or bankruptcy liquidation: If a transfer of personal information is involved, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy; otherwise, we will require that company or organization to obtain your authorization and consent anew. In this process, we may, as reasonably required for commercial arrangements such as due diligence at the request of potential buyers or other parties, need to disclose your personal information to third parties, including auditors, law firms, advisors, etc.

1.5 Public Disclosure

We will publicly disclose your personal information only in the following circumstances:

1.5.1After obtaining your separate consent;

1.5.2Disclosure required by law: We may publicly disclose your personal information when required by law, legal process, litigation or mandatory requirements of government authorities.

Please note that information you voluntarily post or even publicly share while using our Service may involve your own or others' personal information, or even sensitive personal information. Such information includes, for example, your identity information, contact information, and any text, images, videos, or other forms of information you choose to upload that contain personal information. Please exercise greater caution when deciding whether to post or publicly share such information while using our Service.

1.6 Exceptions to Authorization and Consent for Provision, Transfer and Public Disclosure of Personal Information

Pursuant to applicable laws, regulations and national standards, we may share, transfer, or publicly disclose your personal information without obtaining your authorization or consent in the following circumstances: where it relates to our compliance with obligations under laws and regulations; where it relates to national security or national defense; where it relates to public safety, public health, or major public interests; where it relates to criminal investigation, prosecution, trial, or enforcement of judgments; where it is necessary to protect your or another individual’s vital legitimate interests such as life or property, yet it is difficult to obtain that individual's consent; where you have already made the personal information publicly available to the general public; where the personal information is collected from lawfully and publicly disclosed sources, such as lawful news reports, government information disclosures, or similar channels; other circumstances as provided by laws and regulations.

Furthermore, pursuant to applicable laws, regulations, and national standards, where we provide or transfer de-identified personal information to third parties and ensure that the data recipient cannot restore or re-identify the personal information subject, your authorization or consent is not required.

2. How We Protect Your Personal Information

2.1 We use security measures that comply with industry standards to protect your personal information from unauthorized access, public disclosure, use, modification, damage, or loss. We take all reasonable and feasible measures to protect your personal information. For example, we use encryption technology to ensure data confidentiality, employ trusted protection mechanisms to prevent malicious attacks, and deploy access control mechanisms to ensure that only authorized personnel can access your personal information. We conduct background checks on personnel who process sensitive personal information and require them to sign confidentiality agreements. We encrypt the transmission and storage of your sensitive personal information. We take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We retain your personal information only for as long as necessary to fulfill the purposes described in the specific privacy guidelines, unless a longer retention period is required or permitted by law.

2.2 The Internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or administrative security safeguards are compromised, resulting in unauthorized access, public disclosure, tampering, or destruction of information and causing damage to your legitimate rights and interests, we will bear corresponding legal liability. In the unfortunate event of a personal information security incident, we will promptly inform you in accordance with applicable laws and regulations of the following: a description of the security incident and its possible impact, the remedial measures we have taken or will take, recommendations for you to protect yourself and mitigate risks, and remedies available to you. We will promptly notify you of the relevant circumstances of the incident via email, letter, phone, push notification, or other means. Where it is difficult to notify each individual data subject individually, we will issue a notice through reasonable and effective means. Additionally, we will proactively report the handling of the personal information security incident as required by regulatory authorities. If you discover that your personal information has been compromised, please contact us immediately through the contact methods set forth in this Policy so that we can take timely measures.

3. Your Rights

In accordance with relevant Chinese laws, regulations, and standard industry practices, we endeavor to safeguard the rights you hold in connection with our personal information processing activities, including but not limited to:

3.1 Access, Rectification, Supplementation, Duplication, and Transfer of Your Personal Information

3.1.1You may access, rectify, and supplement your personal information through the relevant functional settings of earnfunvip.

3.1.2If we have reasonable grounds to suspect that the information you have provided is erroneous, incomplete, or inaccurate, we have the right to inquire with you or notify you to make corrections, and may even suspend or discontinue part of our services to you. You shall act in good faith, with honesty and lawful intent, when submitting relevant registration information to us, and shall not submit any unlawful or objectionable information. If any relevant information changes, you shall update it promptly. If any legal liability or adverse consequences arise from your failure to provide lawful, truthful, or accurate registration information, or from your failure to update such information in a timely manner, you shall bear such liability or consequences alone.

3.1.3If you are unable to access, rectify, or supplement your personal information through the above means, or if you need to duplicate or transfer such personal information, you may contact us at any time through the contact methods set forth in “8. How to Contact Us”. We will respond to your request within fifteen business days and, if the conditions for data transfer satisfy the requirements prescribed by the cyberspace administration authorities, provide appropriate transfer methods.

3.2 Deleting Your Personal Information

3.2.1In the following circumstances, if we have not proactively deleted your personal information, you may submit a request to delete your personal information through the contact methods provided in “8. How to Contact Us”: when the purpose of processing has been achieved, cannot be achieved, or is no longer necessary for achieving the purpose of processing; when we cease providing products or services, or the retention period has expired; when you withdraw your consent; when we process your personal information in violation of laws, administrative regulations, or agreements; or under other circumstances stipulated by laws or administrative regulations.

3.2.2We will respond within fifteen working days after receiving your personal information deletion request. If we decide to comply with your deletion request, we will also notify all entities that have obtained your personal information from us, requesting them to delete it promptly, unless otherwise provided by laws or regulations, or unless such entities have obtained your separate authorization.

3.2.3After you delete information from our services, we may not immediately delete the corresponding information from our backup systems, but we will delete such information when the backups are updated. If the retention period prescribed by laws or administrative regulations has not expired, or if deletion of personal information is technically infeasible, we will cease processing activities other than storage and the implementation of necessary security measures.

3.3 Changing the Scope of Your Authorization or Consent

3.3.1Each business function requires certain basic personal information to operate. You may withdraw or revoke your authorization or consent at any time. Once your consent is withdrawn, we will stop using your personal information for the corresponding processing purposes, and the relevant business functions may no longer be available to you. You may change the scope of your authorization or consent by updating your device settings, amending the settings of our product or service, or contacting customer service. If you have other requests to withdraw consent that cannot be fulfilled through the above methods, you may notify us via the contact information provided in “8. How to Contact Us” to change the scope of your authorization or consent. Once you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw consent will not affect the processing of personal information carried out based on your prior authorization.

3.3.2In particular, if you do not wish to receive commercial promotional information from us, you may cancel the subscription by replying via the opt-out method clearly stated in the promotional email or text message, or by contacting us.

3.4 Account Cancellation

3.4.1You may apply to cancel your earnfunvip account through the contact information provided in this policy. Once we accept your cancellation application, we will verify your identity and proceed with the cancellation after confirming that there are no pending cooperation applications, ongoing disputes, unresolved matters, or any retention requirements stipulated by laws or regulations. After your account is canceled, we will stop providing you with related services and delete or anonymize your personal information in accordance with applicable legal requirements. However, information necessary for fulfilling legal obligations, ensuring security, resolving disputes, or conducting audit trails may be retained for the necessary period.

3.4.2Please note that we have the right to retain your personal information for a reasonable period after your cancellation, as permitted by laws and regulations. In the event of any dispute, you agree that our system data shall prevail, and we will guarantee the authenticity of such data. Once you confirm that your cancellation is successful, your account information, personal identity authentication information, membership benefits, etc., may not be recoverable or retrievable. Nevertheless, you shall remain liable for any conduct carried out by you before the cancellation and during your use of the Service.

3.5 Binding Automated Decision-Making: For certain business functions, we may rely solely on non-human automated decision-making mechanisms, including information systems and algorithms, to make decisions. If such decisions significantly affect your lawful rights and interests, you have the right to contact us through the methods disclosed in this Privacy Policy and request an explanation, and we will provide appropriate remedies.

3.6 Protection of Personal Information of Deceased Users: After a user (natural person only) passes away, their close relatives may, for their own legitimate and lawful interests, exercise rights such as accessing, correcting, and deleting the deceased user’s personal information through the contact methods provided in this Policy, unless otherwise arranged by the deceased user before death. You understand and confirm that, to fully protect the personal information rights and interests of the deceased user, close relatives applying to exercise the rights under this provision must follow our designated process or customer service instructions and submit the deceased user’s identity certificate, death certificate, the applicant’s identity certificate, proof of kinship between the applicant and the deceased user, along with the type and purpose of the rights to be exercised. You may obtain further information regarding the process, conditions, and other matters related to the protection of deceased users’ personal information through the contact methods provided in this Policy.

3.7 Responding to Your Aforementioned Requests

3.7.1To ensure security, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. We will respond within fifteen working days or within the timeframe prescribed in applicable laws and regulations. If you are not satisfied with our response, you may also file a complaint through the contact methods provided in “8. How to Contact Us”.

3.7.2In principle, we do not charge fees for your reasonable requests. However, for requests that are repeatedly made or exceed reasonable limits, we may charge a certain cost fee depending on the circumstances. We may reject requests that are manifestly unfounded, require disproportionate technical effort (for example, developing a new system or fundamentally changing current practices), pose a risk to the legitimate rights and interests of others, or are highly impractical (for example, involving information stored on backup tapes).

3.7.3In the following circumstances, we will be unable to respond to your request as required by laws and regulations:

a)Where the request is related to the fulfillment of obligations prescribed by laws and regulations by the personal information controller;

b)Where the request is directly related to national security or national defense;

c)Where the request is directly related to public security, public health, or major public interests;

d)Where the request is directly related to criminal investigations, prosecutions, trials, or the enforcement of judgments;

e)Where the personal information controller has sufficient evidence showing that the personal information subject has acted with malicious intent or abused their rights;

f)Where responding to the request would protect the life, property, or other significant lawful rights and interests of the personal information subject or other individuals, but obtaining the individual’s consent is highly difficult;

g)Where responding to your request would cause serious harm to the lawful rights and interests of the personal information subject or other individuals or organizations;

h)Where the request involves trade secrets.

4. How We Protect the Personal Information of Minors

4.1 Our products, websites, and services are intended only for adults aged 18 or above who have full legal capacity. We do not proactively or directly collect personal information from minors. If it is established that a minor has registered for or used our products or services without obtaining parental or guardian consent, we will take steps to delete the relevant personal information as soon as possible.

4.2 If you are a parent or guardian of a minor and have any questions regarding the processing of the personal information of the minor under your care, please contact us through the methods provided in this Policy.

5. How We Use Cookies and Similar Technologies

5.1 Use of Cookies and Similar Technologies

5.1.1To provide you with a smoother browsing experience, we will send one or more small data files called Cookies or use similar technologies on your computer or mobile device. The Cookies assigned to you are unique and can only be read by a web server in the domain that issued the Cookies to you. We send Cookies to you in order to streamline the login process, help determine your login status, and ensure the security of your account or data.

5.1.2We will not use Cookies for any purposes other than those stated in this Privacy Policy. You can manage or delete Cookies according to your preferences. You can clear all Cookies stored on your computer. Most web browsers automatically accept Cookies, but you can usually modify your browser settings to reject Cookies based on your needs. Also, you can delete all Cookies stored within the software. However, if you choose to do so, you may need to manually adjust your user settings each time you access the product. Additionally, any information previously stored will be deleted, which may have a certain impact on the security of the services you use. For detailed information on how to change your browser settings, please visit the relevant settings page of the browser you are using.

5.2 Do Not Track

5.2.1Many web browsers are equipped with a Do Not Track feature, which can send Do Not Track requests to websites. Currently, major internet standards organizations have not established policies to regulate how websites should respond to such requests. However, if your browser has enabled Do Not Track, we will respect your choice.

6. How Your Personal Information Is Stored and Transferred Globally

6.1 We will store your personal information for the minimum period necessary to fulfill the services or as required by laws and regulations. When the retention period expires, we will delete or anonymize your personal information in accordance with the law. If deletion is technically infeasible, we will cease processing activities other than storage and the implementation of necessary security measures. As required for normal business operations, we will retain the personal information necessary for our products within the retention periods required by different legal bases for processing:

6.1.1Personal information processed based on your authorization and consent will be retained from the date of collection until the purpose of processing has been achieved, your account is canceled or all information is deleted, your consent is withdrawn, and any agreed revocation period has expired.

6.1.2Personal information necessary for the conclusion or performance of a contract to which you are a party will be retained from the date of collection until the contract has been fully performed and the statute of limitations has expired.

6.1.3Personal information necessary for fulfilling legal obligations will be retained from the date of collection until the legal obligations have been fulfilled and the statute of limitations has expired.

6.1.4If laws, regulations, normative documents, or regulatory requirements impose different requirements for the retention periods above, such requirements shall prevail.

For personal information that exceeds the reasonable and necessary retention period, we will delete or anonymize it, making reasonable efforts to ensure that the information can no longer identify you personally.

6.3 In addition, the personal information we collect about you through the Service will be stored on servers located within the People's Republic of China. You understand and agree that the merchants you apply to cooperate with may be located in jurisdictions different from your country/region. To complete distribution cooperation applications, reviews, and cooperation management, we may provide necessary information to the relevant merchants in accordance with this Policy. If, for the purposes of providing the Service, merchant review, cooperation establishment, customer support, system operation and maintenance, or other necessary purposes, we need to transfer, access, or store your personal information across different countries or regions, we will take necessary protective measures as required by applicable data protection laws. Where legally required, we will inform you of the relevant circumstances, obtain your authorization, or adopt contractual, technical, and organizational management measures to safeguard your personal information.

7. How This Policy Is Updated and Applicable Law

7.1 We may update this Policy in response to changes in our business, legal requirements, or technology. For material changes, we will notify you through website announcements, page prompts, email, or other appropriate means, and will indicate the effective date of the updated policy at the top of this page. Without your explicit consent, we will not reduce any of your rights under this Policy. Regardless of whether we have provided you with specific notice of the changes, if you continue to use our products or services, the updated privacy policy will bind both you and us. Please check our website periodically, or contact us using the methods listed in the “Contact Us” section below, to stay informed of updates to this privacy policy.

7.2 The establishment, implementation, interpretation and dispute resolution of this policy shall be governed by the laws of the People's Republic of China (excluding Hong Kong, Macao and Taiwan), and conflict of laws rules shall be excluded.

7.3 If any provision of this Policy is held wholly or partially invalid or unenforceable for any reason, or violates any applicable law, that provision shall be deemed deleted. However, the remaining provisions of this Policy shall remain valid and binding.

8. How to Contact Us

If you have any questions regarding the content of this Policy, or if you have any inquiries, complaints, or suggestions regarding its implementation or our personal information protection practices, or if you discover that your personal information may have been leaked or you feel the need to withdraw, correct, or delete your personal information authorization, you may contact us through the following methods. We will respond to your request within 15 working days after receiving your request and verifying your identity, or within the timeframe required by applicable laws and regulations.

(1) Company Name: Digital Trade Fuyue Technology (Shenzhen) Co., Ltd. / 数贸富越科技（深圳）有限公司

(2) Contact Email: support@earnfunvip.com

If you are dissatisfied with our response, especially where our processing of your personal information has infringed upon your lawful rights and interests and no settlement can be reached through negotiation, you may institute legal proceedings before a court of competent jurisdiction located at the defendant’s domicile to seek a resolution.