Privacy Policy

This Privacy Policy applies to the Innovation Dream Platform ("Innovation Dream " or "Platform") , namely the Innovation Dream official website and Innovation Dream 's products.

We recognize that your privacy is very important and we are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share and otherwise process your personal information in connection with our Services. This Privacy Policy applies globally and jurisdiction-specific terms are detailed in the Supplementary Terms -Jurisdiction-Specific. If you do not agree to this Privacy Policy, please do not use Innovation Dream s and Innovation Dream s products.

This Privacy Policy is very important and we hope you take the time to read it carefully before using Innovation Dream s.

This Privacy Policy covers the following topics:

What information we collect

How we use your information

How do we share your information?

How do we store and protect your information?

What are your rights and choices?

How We Handle Juvenile Information

International transfer

Privacy Policy Updates

Other important information

How to contact us

Language

Applicable law and dispute resolution

Additional terms -Jurisdiction-Specific

1. What information we collect

We may collect the following information about you:

1.1 The information you provide

Information you provide when you contact us. To access the User Services on Innovation Dream s, you can provide us with your [contact person (email address), and text/picture/video information related to your request]. Your User Identification and related problem description is to better address your issue. We may also collect information in communications you send to us, including when you contact us for complaints, support or feedback.

Create a Innovation Dream s account. We will collect certain information about you during the registration/registration process for the Service. This may include information such as your name, region, phone number or email address.

Your Content. Our Services may allow you to create, upload or share content, such as text, images, your profile information (such as your profile picture name and appearance).

1.2 Automatically collected information

When you visit and use Innovation Dream s, we will automatically collect your information:

Usage information. We will collect information about your interaction with Innovation Dream s, including [records of your clicks, follows, searches, browsing, transactions]. We collect this information to analyze your appetite, infer your interests, and for personalized content recommendations.

Cookies. Cookies are text files placed on your device to collect standard internet log information and visitor behavior information. We may automatically collect information about you through cookies or similar technologies, including (e.g., web beacons, Flash cookies, etc.) ("Cookies") , to automatically collect information, measure and analyze how you use the Platform, including which pages you most frequently view and how you interact with content, enhance your experience using the Platform, improve the Platform, serve you ads, and measure the effectiveness of advertising and other content. We and our partners also use cookies to promote the Platform on other platforms and websites. Cookies enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as "pixel tags" or "transparent GIFs", that can identify cookies, the time and date the page was viewed, the page description where the pixel tag was placed, and similar information from your computer or device. To learn how to disable certain cookies, see the "What are your rights and choices" section below.

2. How we use your information

We will use the information we collect for the following purposes:

2.1 Service Provision

Sign and execute an agreement with you.

Introduce and showcase products under Innovation Dream to you.

Create and manage your Innovation Dream s account and profile.

2.2 Communication

Communicate with you about your use of Innovation Dream s, product announcements and updates, and respond to your requests for assistance.

2.3 Marketing

We will send you marketing information about our products and services through the email address you entered when you registered. If you do not want to receive any of the above messages, please contact us through the contact information provided when you created your account or at any time thereafter.

2.4 Safety, security and integrity

Detect and combat abuse, harmful activities, fraud, abuse, junk email, and illegal activities on Innovation Dream s.

Monitor and prevent security risks or technical issues that disrupt the Innovation Dream , and protect the security of your Innovation Dream account.

2.5 Legal compliance

Comply with legal or regulatory obligations, including but not limited to responding to lawsuits, damages or investigations within or outside your jurisdiction, or in the event of any merger, acquisition, sale and transfer of assets, bankruptcy proceedings, corporate restructuring, winding up or liquidation.

3. How do we share your information?

Except as expressly provided in this Privacy Policy, we do not share your personal information. We share your personal information in one or more of the following circumstances:

3.1 Sharing with your consent

We may share information with third parties with your consent or instructions.

3.2 Innovation Dream 's products use your information

When Innovation Dream 's products are data users of your information, in addition to being responsible for your information, they may use your information within the scope of this policy.

For their own use (i.e. data users). In order to comply with relevant laws and your available choices and controls, we may use the information collected from you to:

Provide you with the experiences, products, and services you request, watch, participate in, or purchase

To communicate with you about your account or transactions with us, and to send you information or request your opinion on features of our website and applications or changes to our policies.

Send offers and promotions for our products and services

Personalize content and experience.

Detect, investigate, and prevent activities that may violate our policies, cause security issues, fraud, or illegal activities

3.3 Sharing with business partners

You understand and agree that some of our services will be provided by or in conjunction with our business partners, and you agree that we may share your necessary personal information with the following partners for the purposes of this Privacy Policy:

Service Providers. We engage other companies to provide services for the purposes described in this Privacy Policy. Examples of these services include [data analysis, information technology and related services, sending emails and providing customer support, and security fraud detection services]. These service providers may access your personal information in connection with providing services to us.

3.4 Sharing in mergers, sales, or other business transactions

In transactions including mergers, financing, acquisitions, reorganizations, spin-offs, bankruptcies, asset transfers or similar transactions, we may transfer your personal information to another entity. We will notify you of this and require the new holder of the information to comply with and enforce any and all of this Privacy Policy.

3.5 Legal reasons sharing

We may share your personal information with law enforcement agencies, government regulators, courts and other public bodies as required by law or regulatory authorities to fulfill our legal obligations.

We may also share your personal information with such organizations where reasonably necessary:

Comply with legal obligations, procedures, or requirements.

Enforce our Terms of Service and other agreements, policies, and standards, including investigating any potential violations.

Exercise, establish or defend legal rights;

Detect, prevent, or otherwise resolve security, fraud, or technical issues.

To protect the rights, property, or safety of us, our users, third parties, or the public, as required or permitted by law.

4. How do we store and protect your information?

4.1 How do we store your information?

4.1.1 Location

Currently, the server we use to store your personal information related to Innovation Dream s is located in Hong Kong . You understand and agree that, subject to the terms and conditions of this Privacy Policy, we may transfer and store your personal information to/on that server in compliance with applicable laws and regulations. Although the location of our server and the jurisdiction in your area may vary, we will use our best efforts to protect your personal information with stricter standards and use our best efforts to prevent your information from being disclosed.

As described in this Privacy Policy, we may share your personal information with third parties who may be located outside Hong Kong. We will not transfer your personal information until we comply with applicable laws and regulations regarding cross-border transfers.

4.1.2 Retention period

We will retain your personal information until your account is terminated and as necessary to achieve the above purposes. We will also retain personal information to comply with legal obligations, enforce our agreements and resolve disputes.

Retention periods vary depending on different criteria, such as [type of information, purpose for which we use the information, and mandatory retention periods under applicable law].

After the retention period, we will delete or anonymization your personal information, unless otherwise required by applicable laws and regulations.

4.2 How do we protect your information?

We will take appropriate technical and management measures to help protect and secure your personal information, such as [encryption and desensitization]. We maintain these technical and organizational measures and will periodically revise them to improve the overall security of our systems. Although we are committed to protecting your personal information, no electronic data transfer or information storage can be completely secure. Therefore, we cannot guarantee, and you should not expect your personal information to remain secure at all times. If you do not agree to these risks and conditions, you must stop using Innovation Dream s.

4.2.1 Technical measures

We use encryption technologies such as security protocols at the transport layer to prevent transmission from being sniffed, eavesdropped on, or intercepted; adopt secure storage measures such as data classification and layered disposal; adopt strict data access control systems and multi-identity authentication technologies to monitor data processing and avoid illegal access and unauthorized use of data; monitor and audit the entire lifecycle of data to prevent unauthorized access, disclosure, use, alternation, human or accidental damage or loss of personal information.

4.2.2 Management measures

Set up a special department for personal information protection, and formulate relevant internal control management systems such as the "Business Data Security Use Standards" and the "Data Collaboration Standardized Management System" to minimize employee authorization; regularly organize employees to participate in relevant security protection training, and take practical security organizational management measures such as locking personal information storage areas and restricting employees from entering storage areas.

5. What are your rights and choices?

Subject to applicable laws and regulations, you have all rights regarding your personal information, including but not limited to the following:

Access Profile Information. You can access your personal information, including [your User Identification, nickname, avatar], by clicking "Profile" in the application.

Usage information. You can access some of your usage information at any time through the relevant product page.

The right to copy your personal information. On the profile page, you can also copy your [User Identification].

Right to delete your personal information.

Delete usage information. You can delete some of your usage information at any time through the relevant product page.

Delete account. You have the right to delete your account. You should understand that after deleting your account, you will lose the right to access or use all or part of the platform content. You understand and agree that the account system of Innovation Dream and all its products is universal. Therefore, once your account is deleted, you will lose access to and use of all Innovation Dream services and its products. Deleting an account will cause consequences including but not limited to permanent loss of your personal data and irreversible access restrictions to the services.

Clear cache. You can clear cache through your browser.

Manage your cookie preferences. Innovation Dream s and its products use cookies to improve your browsing experience and for analysis and research. You can change your preferences or disable all cookies. However, please note that some cookies are necessary for the operation of the website to enable you to move on it and use its services and features. Disabling these cookies will affect the performance of the website and may make these services and features unavailable.

6. How We Handle Juvenile Information

Innovation Dream 's products are mainly aimed at clients aged 18 and above. We encourage parents or guardians to monitor the online activities of minors and recommend that Juvenile use our services under adult guidance. Innovation Dream is committed to protecting the privacy and safety of all users, especially minors. We do not collect or otherwise process personal information of minors.

7. International transfer

In order to provide you with services, we will comply with the applicable protection laws and regulations in your jurisdiction to process your personal information. The information sharing described in this Privacy Policy may involve transferring your personal information to our affiliated entities or other third parties outside your jurisdiction for the purposes described above. These jurisdictions may have privacy and data protection laws that are different from (and in some cases less protective than) your laws. We will take appropriate protective measures to protect your personal information in accordance with this Privacy Policy and applicable laws and regulations.

8. Privacy Policy Updates

We may update or revise this Privacy Policy from time to time in response to changing legal, technological or business developments. When we update this Privacy Policy, we will post an updated version and change the "Last Updated" date at the top of this Privacy Policy. We will also take appropriate steps to notify you in advance of material changes that we believe affect your privacy rights in one or more ways, [such as announcements, push notifications, pop-ups and emails]. Applicable privacy laws require your consent, and we will obtain your consent before the revised Privacy Policy applies to you. We recommend that you review this Privacy Policy each time you use our services to ensure that you are aware of the updated version.

9. Other important information

Policy changes

We may update this policy from time to time to reflect changes in our information practices. If we make any material changes, we will notify you by email (to the email address specified in your account) or by service notice before the change takes effect. If applicable data protection law requires us to provide you with an enhanced notice or to seek your consent for any such change, we will do so. You can check when this policy was last updated by checking the "Last Updated" date displayed at the top of this policy. We encourage you to periodically check this page for the latest information about our privacy practices.

Security

Innovation Dream s takes reasonable and appropriate measures to protect your information from unauthorized access or loss, misuse or alteration by third parties.

Although we make good faith efforts to store the information collected by the service in a secure operating environment that is not open to the public, we cannot guarantee the absolute security of that information during transmission or storage in our systems. Additionally, while we attempt to ensure the integrity and security of our networks and systems, we cannot guarantee that our security measures will prevent third parties from illegally obtaining this information. We do not guarantee or represent that your information will be protected, lost, misused, or tampered with by third parties. However, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

Data retention

We will retain your information for as long as your account is active or as needed to provide you with our services. If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us at [email protected]. Notwithstanding the above, we will retain and use your information to comply with our legal obligations, resolve disputes, and enforce our agreements.

Our children's policy

We do not knowingly collect or solicit personal information from children under the age of 18 (or the age of majority in the jurisdiction in which you reside), nor do we knowingly allow children to use our services. If you are a child under the age of 18 (or the age of majority in the jurisdiction in which you reside), please do not send us any information about yourself, including your name, address, telephone number or email address. No personal information may be provided by anyone under the age of 18. If you believe we have collected personal information from a child, please contact us using the contact details listed below. If we become aware that we have collected personal information from a child, we will delete that information as soon as commercially feasible.

International transfer

We may transfer the information we collect about you across borders to affiliated entities or other third parties, and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction. We take measures to ensure that there are sufficient safeguards in place to transfer information to Hong Kong and elsewhere, and to use and disclose information about you, including personal information, as described in this policy.

10. How to contact us

If you have any questions, comments, complaints, requests or suggestions regarding this Privacy Policy or any other privacy-related matters, you may:

Submit online feedback through the "Personal Information" - "Help and Feedback" section in the application.

Email Address: [email protected] or Address: Room 1307, 13/F, Kunbao Commercial Building, 335-339 Queen's Road West, Hong Kong.

Upon receipt of your inquiry or request, we will respond to you within the period specified by applicable law after verifying your identity. We will strive to process your request as soon as possible. This does not affect your right to file a complaint with the relevant data protection authority (applicable).

11. Language

This Privacy Policy is written in English and may be translated into other languages. In the event of any inconsistency, conflict or ambiguity between the English version of this Privacy Policy and the translated version, the English version shall prevail.

12. Applicable law and dispute resolution

This Privacy Policy is formulated, effective, enforced and interpreted in accordance with the laws of Hong Kong, without regard to its conflict of laws provisions. Any disputes arising therefrom will also be resolved in accordance with the Terms of Use.

13. Additional terms -Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplementary Terms -Jurisdiction-Specific of the jurisdiction applicable to your access or use of the Services and the remaining provisions of the Privacy Policy, the Supplementary Terms -Jurisdiction-Specific of the relevant jurisdiction shall prevail.

13.1 Additional Notice for California Residents

This section applies to California residents covered by the California Consumer Protection Act of 2018 ("CCPA") .

13.1.1 How we collect and disclose your personal information

In the past 12 months, we have collected and disclosed your personal information for the purposes described in the "What information do we collect" and "How do we share your information" sections. Please refer to these sections for more information.

To reiterate the categories of the above information, the terms specified by the CCPA are as follows:

We do not intentionally collect information from anyone under the age of 16.

13.1.2 Whether we sell or share your personal information

In the past 12 months, we have not sold or shared personal information of California residents in the sense of "selling" and "sharing" under the CCPA. We will not sell or share your personal information without providing you with notice and an opportunity to opt out of such sales and sharing.

13.1.3 Your California rights

Depending on where you live, you have the following rights with respect to your personal information:

Right to be informed. You have the right to request to know what personal information we collect about you, including the categories of personal information, the categories of sources from which we collect personal information, the commercial or commercial purposes for which we collect, sell or share personal information, to which third parties we disclose personal information, and the specific pieces of personal information we collect.

Right to deletion. You have the right to request that we delete your personal information, subject to certain exceptions.

Right to Correction. You have the right to request that we correct inaccurate personal information we maintain about you. Please note that requests for correction are subject to certain restrictions and in some cases we may choose to delete rather than correct your personal information.

The Right to Opt Out. Under CCPA, you have the right to opt out of the sale or sharing of your information. [However, as previously stated, we do not sell or share your personal information under CCPA. Therefore, we do not have the right to opt out. We will not sell or share your personal information without providing you with notice and an opportunity to opt out of such sale and sharing.]

Right to restrictions. You have the right to request that we restrict the use and disclosure of sensitive data under the CCPA, subject to certain restrictions.

The right to non-discrimination. We will not discriminate against you for exercising your privacy rights under the CCPA.

13.1.4 How to exercise your rights

Method. You can exercise your rights using the methods described in the "What are your rights and choices" section. You can only make verifiable consumer requests for your "Right to be informed" twice within 12 months.

Verify your request. We will only respond to your request if we are able to verify it. We may need additional information in order to verify your request and we will let you know if we are unable to verify your identity.

Scope of our response. Any disclosures we provide only cover the 12 months prior to receipt of a verifiable consumer request. If we are unable to comply with any part of the request, the response we provide will also explain why (if applicable).

Authorized Agent. If you choose to use an authorized agent to submit your request, we may ask your agent to provide proof that you have given signed permission to submit the request. We may also ask you to: (1) provide written permission from the authorized agent to do so; and (2) verify your own identity directly with us. We will not require these steps if we receive proof that you have provided the authorized agent with power of attorney under sections 4121 through 4130 of the California Probate Code. We may deny requests from agents who have not submitted proof that they have been authorized by you to act on your behalf or who do not meet the requirements for authorized agents under the CCPA.

Fees and Charges. We generally do not charge a fee for our response to your request. However, if the request is excessive, repetitive or manifestly unfounded, we may decide to charge a reasonable fee to fulfill your request.

Response time. We will respond to your request in good faith within 45 days of receiving your request. If an extension is required (up to 90 days), we will notify you in writing of the reason and the required extension period. We will comply with your request for restrictions within 15 working days from the date of receipt of your request.

13.2 Additional Notice for Residents of the European Economic Area ("EEA")

This section applies to residents of the EEA covered by the GDPR ("GDPR") .

13.2.1 Data controllers and representatives

Identity and contact details of the controller. The controller of the processing in this Privacy Policy is Innovation Dream s Technology Co., Ltd. The contact details of the controller are: [email protected] , Room 1307, 13th Floor, Kunbao Commercial Building, 335-339 Queen's Road West.

13.2.2 Legal basis for processing

We will only use your personal information if we have a legal basis, and in accordance with the GDPR, we process your personal information on the following legal grounds:

Your consent. We ask for your consent to access or use your personal information for specific purposes. With your consent, we will use your personal information.

Contractual necessity. We may process your personal information to fulfill a contract we are about to enter into or have entered into with you.

Legitimate interests. We may process your personal information to pursue our or a third party's legitimate interests, provided that your interests and fundamental rights and freedoms do not override those interests. The legitimate interests on which we rely include (1) improving your experience, (2) sending you marketing information, advertising and promotions about our products and services, (3) developing, testing and improving our products and services, (4) ensuring the safety, security and integrity of promoting Innovation Dream s, and (5) complying with non-EEA laws, regulations, codes of conduct, guidelines or rules applicable to us, and responding to requests and other communications from competent non-EEA enforcement agencies, government regulators, courts and other public bodies, and fulfilling our corporate and social responsibility commitments, protecting our and our customers' rights and property, resolving disputes and enforcing agreements.

Legal compliance. We may process your personal information as necessary to comply with legal obligations. This includes situations where we are required to do so by law, or where we are obligated to comply with valid legal requests, such as orders or disclosure requests from law enforcement agencies, government regulators, courts and other public bodies.

Public interest. We may process your personal information when necessary to perform tasks in the public interest, including conducting research, preventing and detecting crime, protecting children, and promoting public safety, security, and integrity as required by applicable laws and regulations.

Important interests. We may process your personal information to protect your life, physical integrity or safety or that of others. This may include providing information to law enforcement agencies or emergency services in an emergency to protect health or life.

13.2.3 GDPR

Under the GDPR, your rights with respect to personal information specifically include the following:

Right of access. You have the right to request access to your personal information, which enables you to receive a copy of the information being processed.

Right to correction. You may request correction of inaccurate personal information without undue delay. You may also supplement any incomplete personal information, taking into account the purpose of the processing.

Right to withdraw consent. Based on consent to the processing of your personal information, you have the right to withdraw your consent at any time. Withdrawing your consent does not affect the legality of the processing based on your consent prior to the withdrawal.

Right to erasure (right to be forgotten). You have the right to request the erasure of your personal information in the following cases: (1) your personal information is no longer needed for the purposes of the processing; (2) you withdraw your consent if the processing is based solely on consent; (3) you object to the processing and we have no overriding legitimate grounds or you object to the processing for direct marketing purposes; (4) your personal information has been unlawfully processed or (5) we have a legal obligation to erase your personal information. However, the right to erasure (right to be forgotten) does not apply if your personal information is necessary for a specific purpose as set out in Article 17 (3) GDPR.

You can exercise the above rights using the methods described in the "What are your rights and choices" section.

Right to restriction. You have the right to restrict the processing of your personal information in the following circumstances: (1) you dispute the accuracy of your personal information during the period when we must verify the accuracy of your personal information, (2) the processing is illegal and you object to the deletion of your personal information and request restriction, (3) we no longer need your personal information for processing but you need your personal information for legal claims, (4) you object to processing during the period when we must verify overriding legitimate reasons.

The right to portability. You have the right to portability, that is, (1) the processing of your personal information is based on contractual necessity or consent, and (2) the processing is carried out by automated means. This means that you have the right to receive the personal information you provide to us in a structured, commonly used and machine-readable format, and the right to transfer that information to another controller without our hindrance.

Right to object. You have the right to object to the processing of your personal information at any time. We will comply with your request unless we have overriding legitimate reasons or we need to continue processing your personal information to establish, exercise or defend a legal claim. If you object to the processing of your personal information for direct marketing purposes, including profiling within the context of such direct marketing, we will no longer process your personal information for those purposes.

Right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with your national data protection authority about our handling of your personal information.

If you wish to exercise all of the above rights or encounter any issues related to these rights, you can contact us using the contact information provided. You generally do not have to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your rights. If a third party submits a request on your behalf, we may need to take reasonable steps to verify the authenticity of the request. In order to expedite our response, we may request further information about your request.

13.2.4 International transfers

We may transfer your personal information outside the EEA for the purposes described in this Privacy Policy. When transferring personal information from the EEA to a non-EEA jurisdiction, we rely on one or more of the following mechanisms:

Appropriateness decisions. These are decisions taken by the European Union Commission under Article 45 GDPR (or equivalent decisions under other law), where they recognize that a jurisdiction provides an adequate level of data protection.

Other measures. If we transfer your personal information to a jurisdiction without making an adequate decision, we will rely on standard contractual terms or other cross-border transfer solutions to provide adequate protection in accordance with the GDPR.

14. Contact us

14.1 If you have any complaints, suggestions or questions about the protection of personal information, you can send your inquiry to the [email protected], and we will verify your user identity and promptly feedback your complaints and reports.

14.2 If you have any questions, comments or suggestions about this policy, or wish to exercise your rights, you can contact us through the following methods:

Send your enquiry to our Data Protection Officer [email protected], or

B. Send your questions to the following address: Room 1307, 13/F, Kenbo Commercial Building , 335-339 Queen's Road West, Hong Kong.