SUBLUE RENTAL PRIVACY POLICY

UPDATE AND EFFECTIVE DATE: JUNE 1, 2025OVERVIEWTHIS



policy will help you understand the following:

I. How We Collect and Use Your Personal

InformationII. How We Use Cookie

TechnologiesIII. How We Store and Protect Your Personal

InformationIV. How We Transfer Your Personal Information to Other

EntitiesV. Your Rights: How to Access and Control Your Personal InformationVI

. Data Storage Locations, Cross-Border Transfers of Personal InformationVII

. ResponsibilitiesVIII

. Revisions to this PolicyIX

. Severability

We, Deep Blue (Tianjin) Underwater Intelligent Technology Co., Ltd. (hereinafter referred to as "we" or "us" or "SUBLUE"), respect and protect your privacy and personal information, and when you use the SUBLUE RENTAL application (hereinafter referred to as the "App") provided by us to control and manage the water sports products (hereinafter referred to as "Water Sports Products") connected to the application user account, we will follow the SUBLUE RENTAL Privacy Policy (hereinafter referred to as the "Policy") ) and your rights. Our App may contain links to our affiliates, third parties, or external websites operated by us. If you click on these links, the linked website will be displayed through your mobile phone's web browser, but your personal information will be processed in accordance with the privacy policy of the relevant website. As an application operator, we are the controller of your personal data and we will obtain the data directly from you as the data subject.

IF YOU WOULD LIKE MORE DETAILED INFORMATION, PLEASE READ THE CORRESPONDING SECTION ACCORDING TO THE INDEX ABOVE: THIS

POLICY APPLIES TO ALL USERS OF SUBLUE RENTAL'S PRODUCTS AND SERVICES. SPECIFICALLY, INDIVIDUALS WHO HAVE FULL LEGAL CAPACITY TO REGISTER FOR AN ACCOUNT ON OUR APP AND ENJOY THE RELEVANT SUBLUE RENTAL PRODUCTS AND SERVICES (HEREINAFTER REFERRED TO AS "USERS"). We neither provide services to any minor nor actively collect personal information from any minor, but if the collection of their personal information occurs for reasons beyond our control, we will delete such information upon notice.

Understand that this Policy is necessary for you to use the App and its water sports products-related features and for you to become our user. We recommend that you carefully read and understand the entire content of this Policy so that you can make choices as you see fit. When you use or connect to the App, you click to accept or indicate that you understand this Policy, which is deemed to be your acknowledgment and agreement to abide by this Policy. This Policy does not necessarily apply to the services, activities, or products of third parties you may be involved with, and they may have different privacy policies. However, if the type of personal information of a third party is involved, such as country/region, mobile device identification code, IMEI and other information, we will supervise and require the third party to use your personal data reasonably and legally in accordance with the purpose, scope and time of use specified by us and its privacy policy.

1. This Policy will help you understand the categories of specific personal information we collect for a specific product, service or function, the reasons for use and the method of collection.

2. When you use some functions of the application, we may be triggered to collect some information from you. Such collection and its purposes are clearly stated in this Policy for your review. REFUSAL TO PROVIDE SUCH INFORMATION WILL ONLY PREVENT YOU FROM USING THE RELEVANT SPECIFIC FEATURES, BUT WILL NOT AFFECT YOUR NORMAL USE OF OTHER FEATURES OF SUBLUE RENTAL PRODUCTS AND SERVICES. We will cease to collect relevant personal information and/or de-identify or delete the collected information if the collection or processing of certain personal information is no longer necessary for all applicable purposes specified herein.

3. In general, we will not actively share, disclose or transfer your personal information to any third party, unless otherwise provided in this Policy or as required or permitted by relevant laws. If it is necessary to share, disclose or transfer this information, we will explain to you the reasons/basis for such sharing, disclosure or transfer and obtain your explicit consent to the extent required by law.

4. As long as the processing of your personal information is based on your consent, you can access, modify or delete your personal information or withdraw your consent; You may also cancel your user account registered on the App ("App Account"), make a complaint, report or set up privacy features to control or restrict our further use of your personal information. You also have the right to object to the processing at any time if the processing is in our legitimate interest by contacting us using the contact information listed in this Policy.

5. As long as the processing of your personal information is based on your consent or agreement or through automated processing, it means that you have provided us with your personal information, and we will provide you with personal information in machine-readable form according to your requirements, including but not limited to your email address, password and SUBLUE ID, phone number, account information, mobile device identification number (IMEI), location information, text information, basic application information, application operation logs, Device operation logs, network information, and basic device information, so that you and other service providers can use such information. You can contact us support@sublue.com email address, and we will reply to you within 7 working days after receiving your application.


6. If you have any questions, complaints or explanations about this Policy, our implementation of the Personal Information Protection Law, or the exercise of your rights under the following provisions or laws, you can contact us according to the contact information listed in this Policy.

Contact Information: support@sublue.com

please be aware of our Privacy Policy, which covers how we collect, use, disclose, transfer and store your personal information. We are committed to protecting your privacy and data security by complying with the Personal Information Protection Act applicable to us. We also guarantee that all our employees will fulfill the above obligations. The purpose of processing your personal data is to operate the application and water sports products and to provide you with better services and improve product quality, such as supporting the development of new products and upgrading the functions of existing products, so as to provide you with better and more suitable services.

1. How we collect and use personal information

(a) The type of information, the method of collection and the purpose of

the information The reasons for us to process your personal information: the purposes described in this Policy; your consent; to comply with our legal obligations; the performance of a contract to which you are a party; To protect your vital interests; or an assessment based on the legitimate interests pursued by us deems it necessary or necessary to transfer the information to a third party (see the attachment below for details).

(1) Personal information to be provided when registering an application accountYou

need an application account to use its functions, especially those related to water sports products. WHEN YOU REGISTER AN APPLICATION ACCOUNT, WE WILL COLLECT AND STORE YOUR PERSONAL INFORMATION, INCLUDING YOUR EMAIL ADDRESS AND SUBLUE ID, PHONE NUMBER, ACCOUNT INFORMATION, MOBILE DEVICE IDENTIFIER (IMEI), LOCATION INFORMATION, TEXT INFORMATION, BASIC APPLICATION INFORMATION, APPLICATION OPERATION LOGS, DEVICE OPERATION LOGS, NETWORK INFORMATION, AND BASIC DEVICE INFORMATION. By providing the information you provide, you warrant that the personal information you provide to us is complete and accurate. In order to facilitate our internal processing of data related to your application account, your account will automatically be assigned a SUBLUE ID (a random string) after you complete the application account registration. By linking your application account and SUBLUE ID, your application and we can recognize your instructions and needs, distinguish between you and other users, send the correct instructions to your water sports products, and provide you with services based on long-term understanding and fulfillment of the SUBLUE RENTAL User Agreement.

The above information will be used to verify your identity; Match and aggregate actions under your application account; Match and provide feedback on the status of your water sports products; To facilitate our customer service and after-sales requests that you send to us; To send you the above notices, account verification, important changes and service feature updates, as well as technical and security-related notices.

If you agree that we may contact you at your email address to send you periodic interesting information about us and our products and services, such as marketing. You can unsubscribe from our email marketing campaigns by clicking on the unsubscribe button provided in each marketing email.

In order to better provide you with valuable product consultation information, when sending our products and services, we need to collect your personal information such as: mobile phone number, email address, country/region, mobile phone basic information, and purchased equipment information.

(2) Personal information collected by the water sports product paired with the application accountIn

order to maintain and protect your water sports product, implement your instructions, transmit the status of your water sports product to your application account interface, and facilitate your reference, some information of your water sports product needs to be transmitted or stored through our server. Among the above information, the following information may be considered your personal information: (i) Service Set Identifier (SSID), network layout and IP address of the Wi-Fi network access status to which your water sports product is connected; (ii) the model number and serial number of the water sports product; (iii) operating records and status data of water motion products; (iv) water motion product errors and upgrade history; (v) Clean maps generated by water sports products.

Such processing of personal information is limited to:

(i) for all personal information transmitted and stored through our servers, we process such data to carry out your instructions until we perform the SUBLUE RENTAL User Agreement with you. In exceptional circumstances, we may share information on your water sports product with other users at your request: you may authorize one or more users to jointly use and control your water sports product through the App, in which case you are referred to as the "Manager", and any other person you authorize to allow the control of your Water Sports Product through the App Programming Interface (API) is called the Operations Manager. If you are an Operations Manager, both the management and the Operations Manager who is authorized to manage the people will be able to view your rental reports.

(ii) We also use some of your personal information and your SUBLUE ID to analyze and identify potential market needs and common failures and to support long-term feasibility and technology updates related to information systems, water motion products and mobile applications. The personal information used for this purpose is limited to the model of your water sports product, the record of instructions performed by the water sports product, warnings and suggestions on the water sports product, errors, and fault information uploaded by you.

and (iii) we review the rental records and failure information of your water sports products to supplement your user profile in order to optimize and personalize the content of your application. In order to accommodate this type of data collection, we will also tailor our advertisements or third-party advertisements (through the app, in-app notifications, or content displayed on the homepage of your mobile device), marketing advertisements (sent from the email address provided when registering for an app account). Please note that, for the purposes of data collection, we also consult the assessment of preferences, preferences, consumption habits related to market research and statistical analysis. This data is collected in automated form.

Please note that if you choose to authorize another app account to control your water sports product, the data collected by the authorized account through your water sports product during the control period will also be recorded under his app account.

(3) Personal information collected by the applicationIn

order to match your application account with your water sports products during your account login and continuously transmit instructions to your water sports products, we will collect: (i) the information of the mobile device on which the application is installed, including the device model, operating system and version, IP address, Mac address, country and city where it is located; (ii) the SSID, network layout, status, and errors of access to the Wi-Fi network to which your mobile device is connected; (iii) your application pairing status, history, and errors, if any; and (iv) login times, instructions, and runtime logs generated under the name of the application account. We will collect "Uniform Identifiers" of your mobile devices, such as International Mobile Telephony Equipment Identifiers (IMEIs) and Mobile Device Identifiers (MEIDs); Our use will be limited to reviewing historical data collected or generated on a particular mobile device and identifying whether your application may have been stolen and logged in to an unfamiliar mobile device.

If you use our customer service through the App, we will collect a record of your communication with us, contact information other than your email address (if required), and other information used to process your request. Please refer to the Appendix to this Policy for details of the service providers we engage in the collection of information.

The "Storage" license on your mobile device authorizes any information collected by the App for the operation, updates, or upgrades of the App and for storing it. In order to process the above information, the Application will seek the following permissions from your mobile device: (i) access to "Mobile Data", "Location" and "Wi-Fi" information, and "Bluetooth" in order for the configuration of network pairing connections and network-dependent application functions to function properly; and (ii) access to Device Information in order to protect the use of your Application Account.

The processing of such personal information is limited to:

(i) the correct output of the App content, in particular in order to maintain a continuous connection between your App account, the instructions you give through the App account and your water sports products;

(ii) to process instructions, queries and requests relating to your use of the App and/or your water sports products, including customer service;

(iii) analysis to identify potential market needs and common failures, improve service quality and support long-term feasibility and technology updates related to information systems, water sports products and mobile applications;

(iv) create and supplement your user profile to optimize and personalize your App content, our or third-party advertisements (through the App, in-app notifications, or top-of-the-top advertising content on your mobile device), marketing advertisements (sent from the email address provided when registering for an App account) for such data collection;

(v) to carry out our legitimate interests such as "know your customer", record keeping and cyber security protection, in order to provide law enforcement authorities with the information necessary to prevent, process or monitor data security risks.

To push various advertisements and other types of notifications to your application account interface, the application requires your consent to access the "notifications" function on your mobile device, and some of the tools provided by our service providers will be integrated into the application (please refer to the annex to this policy for details). Please turn off receiving these notifications for specific categories through your user settings. We will emboss the word "Advertisement" on all advertisements for your easy identification.

During the sharing of water sports products, if you, as a sharer, intend to share with other individuals who have not registered for the app, you should obtain their consent before submitting their email address to the app, so that we can send them an email address with an invitation to register for an app account.

II. How We Use Cookies

(a) How we use cookie technology to collect information automatically. In order to facilitate your use of the App or the services we provide, we may use small data files to identify you, which can help you skip the step of repetitive information or determine the security of your App account. This data includes cookies, Local Shared Objects, or locally stored data provided by other mobile device operating systems (collectively, "Cookies"). Cookies are automatically stored for 1 month, dynamically updated, and in certain cases, we use cookies to collect the SSID of the Wi-Fi network you search for within the app.

(b) How to refuse the use of cookies. You can set your web browser to refuse or manage cookies. However, please note that if you refuse to use cookies, you may not be able to enjoy the best service experience and certain services, but this will not affect the core functionality of our products and services. At the same time, when you log out of the app login, the saved cookies are automatically deleted.

III. How We Store and Protect Your Personal Information

(a) Our Data Security Management and Policies. We are legally responsible for maintaining information security and protecting your information from improper disclosure, destruction, misuse, or loss. We undertake to take (or have been) all reasonable steps to do our best to protect your personal data, employing technical security measures such as Secure Sockets Layer (SSL), AES, MD5 encrypted access and appropriate security policies for our employees. We also communicate our policies and safety guidelines to our employees and enforce privacy protections strictly within our team. In addition, we have established internal licensing and approval mechanisms for access to your personal information, and have selected reliable and qualified third-party cloud storage providers to store such data.

(b) Account Verification. In order to protect the security of your application account, we may use different verification measures to identify you in the process of using your application account. For example, if you log in to your account on a new mobile device, we may identify you by using your account plus a verification code sent by, but not limited to, a verification email.

(c) Mechanisms for reporting personal information security incidents. Please understand that due to current technical limitations or potential malicious attacks, personal information security incidents may occur due to uncontrollable factors. In the event of such an incident, if required by law, we will promptly notify you of the approximate facts and potential impact of the security incident, the measures we have taken or will take, recommendations to protect your information and reduce the risk, and remedial measures. We will inform you of the facts of the accident by email, letter, phone or push notification in the manner you have set to receive information from us. If we are unable or difficult to contact each affected customer, we will make a reasonable and effective effort to post the notice. If necessary, we will also report the results of the personal information security incident to the relevant regulatory authorities.

(d) Storing your information for a limited period of time. We will only store your personal information for as long as is necessary to fulfill the purposes set out in this Policy or as required or permitted by law. We will carefully review our needs for the collection of the personal information disclosed herein and, if we establish such requirements, we will only retain the information for the shortest possible period for the purposes for which it was previously collected, unless a longer retention period is required by law, after which your personal information will be destroyed or anonymized in a non-reproducible manner. For any third party disclosed in the attachment, we undertake to delete your personal information during the period of cooperation with them and immediately after the end of the agreement. If we terminate the provision of SUBLUE RENTAL services or business activities, we will immediately cease collecting your personal information and immediately delete or de-identify the personal information collected, and if this is the case, we will notify you or publish the relevant information through our website or app.

IV. Your Rights: How to Access and Control Your Personal Information

(a) How You Can Access and Correct Your Personal Information. You can log in to your App account in the App to view the "User Information" and "Settings" interfaces, view or modify the personal information you have submitted and the third-party accounts associated with it, or make relevant privacy and security settings. However, for security and identification reasons or in accordance with the mandatory provisions of laws and regulations, you may not be able to modify part of the initial registration information you provided during registration. If you are unable to access or correct your personal information through the above methods, please request our assistance through the contact information shown in Article 9 of this Policy. We will continue to develop an interface that is easy for you to operate on your own, so please pay attention to the future update of the app.

(b) how you can opt-out of receiving marketing messages. If you do not wish to receive marketing emails from your email address, you can unsubscribe by clicking "unsubscribe" in those messages. Please note that you cannot unsubscribe or refuse to receive messages related to your App account, such as retrieving a lost App account or App account password, changes or updates to service features, or technical and security notices.

(c) How you can request deletion of your personal information. If you find that our collection and use of your personal information violates applicable laws or violates your agreement, you may request to delete your personal information collected by us in accordance with the illegal breach of contract through the contact information indicated in Article 9 of this Policy.

(d) how you can change the scope of your consent or withdraw your consent. You can change the scope of your authorization for us to continue to collect personal information or withdraw your authorization by asking us to delete your personal information, prohibit the App from calling the permission of your mobile device, or make settings in the App. You can also withdraw all authorization for us to continue to collect your personal information by canceling your App account. After you withdraw your consent or authorization, we may not be able to continue to provide the corresponding services due to lack of necessary information. Your withdrawal of consent or authorization will not affect the legality and validity of our previous processing of personal information based on your consent.

(e) How you cancel your App account. You may request to cancel your App account through the contact information shown in Article 9 of this Policy, or in "App Settings - Account Cancellation". At that time, we will delete or anonymize your personal information. After canceling your App account, you need to contact us to change the rental version of the water sports product to the regular version of the product to continue to use it.

(f) Before responding to your above request, in order to ensure security, we may need to verify your identity and credentials, which will be processed within fifteen (15) working days; In case of special circumstances, we will respond within a maximum of thirty (30) days or within the time limit prescribed by laws and regulations, or provide a reasonable explanation for the failure to respond in a timely manner.

V. Data Storage Location and Cross-border Transfer of Personal Information (a)

(b) The storage location of your personal information. PERSONAL INFORMATION COLLECTED AND GENERATED WHEN YOU USE SUBLUE RENTAL PRODUCTS AND SERVICES WILL BE STORED ON SERVERS IN THIRD-PARTY CLOUD FACILITIES, LOCATED IN THE UNITED STATES (IF YOU USE THEM OUTSIDE OF EUROPE) AND FRANCE.

(b) International Transfers of Your Personal Information. Because we rely on our resources and servers around the world to provide you with products or services, your personal data may be transferred to or accessed from jurisdictions other than where you are located. Such jurisdictions include: (i) the jurisdiction in which your personal data is stored (where you are located in the same place as you, cross-border transfers do not apply); (ii) China, where we are registered, where we are located, where we provide SUBLUE products and services, and where most of our service providers are located, and when our employees need access to your personal data processing issues or to conduct extensive analysis; (iii) the storage of some of the other service providers who provide services to you on our behalf by integrating APIs/SDKs (Application Programming Interfaces/Software Development Kits) into our Applications, primarily in your jurisdiction or in the jurisdiction where the relevant affiliates that specialize in serving you are located; and (iv) the jurisdiction in which you have logged into your Application account, provided that the data is stored in a different location than your country of residence. In particular, when you send an e-mail to support@sublue.com, the personal information contained in your e-mail and its delivery will be sent directly into China, where our email servers are located. All such international transfers are generated and conducted by third-party cloud facilities and related servers physically located in such jurisdictions, and we will procure that third-party cloud service providers take appropriate measures to protect your personal information in accordance with the law.

6.

LiabilityNeither our employees, agents nor we shall be liable for claims for damages for negligence and tort and claims for costs in vain.

The scope of liability does not apply to: damage caused by intent or gross negligence, or breach of a substantive contractual obligation, i.e. the contract is properly executed and a party to the contract can regularly perform the contractual obligation on which it is based, as well as damage caused by a breach that may jeopardize the achievement of the purpose of the contract. If we are liable for negligence, the scope of liability does not apply to damage caused by injury to life, limb or health. In addition, the scope of liability shall not apply to damages arising from lack of quality assurance or liability provided for by law.

7. Revision of this

PolicyWe may revise this Policy from time to time. In this case, for example, we will ask for your consent after notifying you in one or more of the following ways: (i) sending you push notifications when you log in to your App account or update your products or services to present you with the revised Privacy Policy; or (ii) contact you via stored contact information, such as by email, pop-ups, or other similar methods. If you choose to accept, the updated version will supersede this Policy and continue to be binding on you.

YOU CAN FIND THE MOST CURRENT VERSION OF THE SUBLUE RENTAL PRIVACY POLICY THROUGH YOUR IN-APP ACCOUNT SETTINGS. We encourage you to read our Privacy Policy whenever you access our Services.

8. SeverabilityIf

any provision of this Policy is deemed illegal or unenforceable, we will amend the provision to the extent necessary to make it legal or enforceable, but retain the original meaning of the provision as much as possible.

If possible, the terms of this Policy shall be construed in a manner that is legally valid and enforceable. However, if one or more provisions of this Policy are found to be invalid, illegal, or unenforceable, in whole or in part, that provision or the remainder of this Policy shall remain in full force and effect.

IX. Special Agreement on Minors' Personal InformationWe

attach great importance to the protection of minors' personal information. We do not actively collect personal information from minors directly. For the collection of minors' personal information with the consent of their guardians, we will only use, share, transfer or disclose them as permitted by law, with the consent of their guardians, or as necessary to protect minors. We expect parents or guardians to instruct minors in using our services. If you are under the age of 14, or are under the age of few in accordance with the laws and regulations of your location, it is recommended that you ask your parents or guardians to read this Policy and use our services with the consent of your parents or guardians, but please refrain from providing us with any personal information that can identify you. If your guardian does not agree to your use of our services in accordance with this Policy, or if you have actually provided us with information that can identify you, please immediately terminate your use of our services and notify us in a timely manner, so that we can take corresponding measures in accordance with the provisions of applicable laws.

10. How to contact us1

. If you have any questions, comments or suggestions about this Policy or matters related to your personal information, please contact us through the following methods. SUBLUE Company Address: No. 45 Muning Road, Binhai New Area, Tianjin, ChinaEmail

: support@sublue.com You

can also contact us by submitting feedback information in the Help & Feedback page in the app.

2. In general, we will reply within fifteen (15) working days. Attachment: List of Third-party Service Providers
*The table below presents some third-party privacy policies (you need to access third-party network environment for reading). We advise you to read the part on “personal information of end-user/terminal user” to understand their specific way to possibly use your personal information. The content below may be applicable only to the cleaning robot products of specific models of brands under SUBLUE.

Third-party product/service(s)	Information processing scenario/purpose	Type of information acquired (not all personal information)	Access to your mobile device invoked	Information processing	Name	Link
Alibaba Cloud	Storage and transmission of various data of our products and services, including the distribution network between the App and your home robot	All information we gather	None	Data is transmitted and processed merely based on our command or the automatic command of our products and services	Alibaba Cloud Computing Co. Ltd.	http://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/ suit_bu1_ali_cloud201902141711_54837.html
Alibaba Cloud text message	Send verification code to your mobile phone to confirm your identity; send notification to you on the embedded user care activity and marketing information of the App	Mobile phone number	The storage permission of text messages for verification
Alibaba Cloud OSS	Analyze and classify your home robot based on the cleaning log	The cleaning log and personal portrait of your home robot	None
okhttp	HTTP is a modern way of network application. This is the way we exchange data and media. Effective use of HTTP can quicken your content loading speed and save bandwidth. Intercommunication with server.	Network status	None		2022 Block, Inc.	https://square.github.io/okhttp/
YYImage	For gif and image processing and loading		None	For image processing and loading	github	https://github.com/ibireme/YYImage
SnapKit	For automatic layout of control			Realize automatic layout of control through constraint	github	https://github.com/SnapKit/SnapKit