SHAREit Group Terms and Policies

These SHAREit Terms of Service (these "Terms") serve as a binding agreement between a user ("you"/"your") of the Services (as defined below) and us (and our successors and assigns), and these Terms set forth the terms and conditions subject to which you may access and use SHAREit applications, websites, products, services and other content offered by us (collectively, the "Services").

You agree that, by accessing or using the Services, you have read, understood and agreed to be bound by these Terms. If you do not agree to these Terms, please do not access or otherwise use any of the Services.

Your access to and use of the Services is also subject to our Privacy Notice as well as any other additional guidelines or rules that are made available to you from time to time, the terms of which will be posted via our Services or otherwise notified to you and are incorporated herein by reference.

By accessing or using the Services, you represent that you have the full legal capacity, and you are competent to enter into a binding agreement with us.

If you are accessing or using the Services on behalf of a company, partnership, association, government or other organization ("Organization"), you represent and warrant that (i) you are duly authorized to do so; (ii) you are authorized to bind your Organization to these Terms; and (iii) your Organization is legally and financially responsible for your access to or use of the Services.

Please take the time to read these Terms carefully.

These Terms may be provided in more than one language. In the event of any conflict, where permitted under local law, this English language version of these Terms shall prevail.

2. Changes of these Terms

We may revise these Terms from time to time. We will use commercially reasonable efforts to notify you of any material changes to these Terms. However, you should look at these Terms regularly to check for such changes. We will also update the "Last Updated" date at the top of these Terms, which reflect the effective date of such Terms.

By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Terms. If you do not agree to the revised Terms, you must stop accessing or using the Services.

3. Who May Use the Services

You must be at least 13 years old (with additional limit on the minimum age for applicable jurisdictions set forth in our Privacy Notice) ("Minimum Age") to use the Services.

If you are above the Minimum Age but below the age of majority under the law applicable to you, you must have your parent or legal guardian's consent to use the Services. Please have your parent or legal guardian read these Terms with you.

Without limiting the generality of the age limit set forth above, you must be at least 18 years old (or the legal age of majority in your jurisdiction) to use certain features of the Services. In such case, we may require you to provide necessary information or document to prove your age before accessing or using such features.

By granting your child permission to use the Services, you hereby agree to be bound by these Terms. You are responsible for monitoring and supervising your child's use of the Services. If your child is using the Services and is either under the Minimum Age or does not have your permission, please contact us at feedback_android@ushareit.com immediately, so that we can disable your child's access.

4. Your Privacy

We respect and value your privacy. Please see our Privacy Notice regarding how we collect, use and process your personal information, and your rights and choices regarding your privacy.

5. Account

Account and SHAREit ID

You may be required to register an account ("Account") with us to use or access certain features of the Services. You must provide true, accurate and complete information to us relating to your Account and ensure that such information remains up-to-date.

You are also solely responsible for your user name of your Account, provided that your user name shall comply with applicable laws or our guidelines (if any) (e.g., your user name must not contain obscene words). We may request you to change your user name, if your user name violates applicable laws or guidelines or is otherwise deemed as inappropriate by us.

You are also responsible for the confidentiality and security of your Account, including any passwords and credential information. If you are aware of or suspect that any unauthorized party knows your password or has accessed your Account, you must notify us immediately at feedback_android@ushareit.com.

You must not sell, lend, share or transfer your Account or otherwise permit any other person to access or use your Account. You agree that you are solely responsible for any and all activities that occur under your Account, including any use of our Services and transactions occurred under your Account. To the fullest extent permitted by laws, any acts under your Account will be deemed as acts made by yourself.

Once your Account is terminated, regardless by us or upon your request, you will not be able to reactivate your Account or retrieve any information or content in connection with the terminated Account.

Third Party Account

You may access our Services by using your account with a third party (e.g., your Facebook account) ("Third-Party Account"). If you have any question or encounter any problem with your Third-Party Account, you should contact the relevant third party and resolve the issue directly with such third party. We are not responsible for your Third-Party Account, including without limitation loss or stealing of your password or misuse or retrieval of your Third-Party Account.

6. Your Use of the Services

Not all Services or features may be available in your jurisdiction. Different features may be available in different versions of the Services. Certain features are not available for users under a certain age.

In order to use our Services, you are responsible for your own device and any charges incurred in connection therewith (e.g., Internet connection and data charges). If you are unsure what those charges may be, please consult your service provider.

We may from time to time update or modify our Services. You may be asked to update the Services manually. You understand that our Services may not operate properly or not be fully available to you if you opt out of automatic updates or if you reject to make such updates.

We reserve the right to discontinue or terminate our Services, in full or in part, permanently or otherwise, with or without notice to you. The Services are owned and operated by us, and we reserve all rights in and to the Services not expressly granted to you in these Terms.

7. SHAREit Content

As between you and us, all audios, videos, images, text, graphics, software, music, trademarks, marks, designs, Coins (as defined below) and other content, information and materials on our Services and the selection and arrangement thereof and all intellectual property rights in connection therewith ("SHAREit Content") are either owned by or licensed to us.

We hereby grant you a limited, personal, non-exclusive, non-transferable, non-sublicensable and revocable license to access and use SHAREit Content solely for your personal and non-commercial use in accordance with these Terms. Unless expressly permitted by us, you shall not download, copy, reproduce, distribute, transmit, display, broadcast, license, sell, offer for sell or otherwise exploit SHAREit Content for any other purposes. We reserve all rights in and to SHAREit Content unless expressly licensed to you hereunder.

You shall not use SHAREit Content, Third Party Content/Services (as defined below) or other materials made available as part of the Services for any purpose not expressly permitted by these Terms. Any such use will be deemed a breach of these Terms.

8. User Files

The Services provide you with a few features to manage photos, documents, audios, videos, files, apps, materials, content, data and other information, materials or files ("User Files"), including without limitation to access, view, delete or organize your User Files, to transmit or share your User Files with other users of the Services or between your devices (e.g., between your mobile phone and your computer), to download or receive User Files, to convert certain User Files from one format to another format (subject to the format available for conversion on SHAREit) and/or to store your User Files.

By using User Files management feature(s) of the Services, you grant us a non-exclusive, sublicensable, transferable, royalty-free and fully paid up and universal license and right to access, delete, transmit, convert, store, monitor, screen, moderate or otherwise use your User Files for (a) providing the Services to you (e.g., if you select to use our cloud storage services, we will store your content uploaded for providing the storage services to you), (b) operating and improving the Services (e.g., we may analyze your content to avoid spam or illegal content), (c) assessing your compliance with these Terms (e.g., we may access your content to assess whether you violate any code of conduct for using the Services or to resolve an infringement claim); and (d) complying with applicable laws (e.g., if we are obligated under applicable laws to screen any user content, we will do so to comply with our legal obligations).

You represent that you are the owner or have obtained necessary rights, permissions or authorization to use the User Files and you have all necessary rights, permissions or authorization to grant us the rights in and to the User Files as set out under these Terms. You agree to pay for all royalties, fees, and any other monies owing to any person arising from or in connection with the exploitation of the User Files you make available on or through the Services. Subject to the limited license above, we do not claim ownership to the User Files. We are not responsible for any User Files in any way and are not liable to you or any third party for any losses, damages or liabilities arising out of or in connection with the User Files or the use of the User Files. You shall back up your User Files.

You understand that no transmission of data over the Internet or any network can be guaranteed to be completely secure, and thus you agree and acknowledge that we cannot guarantee the confidentiality or security of such User Files or any information. Any downloading, transmission, receipt or other use of User Files through the Services is at your own risk.

If you use the SHAREit Space feature, you acknowledge that the storage space available to you for free will be limited and your free access (if any) to such feature may be limited as well. Subject to our limited right to your User Files, your User Files stored in SHAREit Space is private, but you have the option to share your User Files with others. Your use of the SHAREit Space may be subject to additional terms and conditions displayed on SHAREit or otherwise notified or made available to you.

9. User Content

The Services may include comments or other interactive features by which you can upload, publish, submit, send or otherwise make available images, photos, comments and other information or content ("User Content") on the Services. User Content expressly excludes User Files. For the avoidance of doubt, if any User Content is used as a User File, the terms and conditions under Section 8 (User Files) will additional apply to such use.

You acknowledge that User Content will be made publicly available and is not confidential. You shall not post, publish or otherwise make available confidential information via the Services.

Between you and us, you own your User Content. By uploading, publishing, submitting, sending or otherwise making available your User Content via the Services, you hereby grant us and our affiliates an irrevocable, unconditional, non-exclusive, royalty-free and fully paid-up, sublicensable, transferable, universal and perpetual license to (a) copy, reproduce, publish, transmit, distribute, display, use, adapt, make derivative work of, and otherwise exploit your User Content in any media and by all means, either now existing or hereafter devised; (b) use the identity, name and likeness and other biographical information you uploaded, published, submitted, sent or otherwise made available in connection with such User Content; (c) use the foregoing for promotional purposes deemed appropriate by us; and (d) for necessary archiving purposes.

You must at all times ensure that: (a) you are the owner or have obtained necessary rights, permissions or authorization of your User Content; (b) you have all necessary rights, permissions or authorization to grant us the rights as set out under these Terms; and (c) your User Content (and use of your User Content in accordance with these Terms) does not infringe on or violate any right, title or interest, including intellectual property rights, of any person or otherwise contravene any applicable laws. You agree to pay for all royalties, fees, and any other monies owing to any person by reason of exploitation of the User Content you make available on or through the Services in accordance with these Terms.

We reserve the right to refuse to publish, cut, edit, crop, block, disallow, take down, delete or remove any User Content for any reason at our sole discretion (e.g., if such User Content is deemed inappropriate according to applicable laws or guidelines, or in response to third party complaints) with or without notice and without liability to you.

You are solely responsible for your User Content, and we recommend that you keep a back-up copy of it at all times. We do not guarantee the accuracy, integrity, appropriateness or quality of any User Content, and under no circumstances will we be liable in any way for any User Content.

We make no guarantee that your User Content will not be copied, reproduced, distributed or otherwise used without your authorization. You agree that, to the fullest extent permitted by applicable laws, we shall not be liable to you for any such unauthorized use of your User Content, and you hereby waive and agree not to assert any claim against us arising out of or in connection therewith. You understand that even if you seek to delete User Content from the Services, it may as a technical and administrative matter take some time or not be possible to achieve – e.g., we may not be able to prevent any third party from storing or using any of your User Content that you have made public via the Services.

You acknowledge that we have the right to disclose your identity to a third party who claims that any User Content posted or uploaded by you on our Services infringes on such third party's intellectual property rights, privacy or other proprietary rights or if we are required to disclose your identity under applicable laws.

10. Virtual Coins

If you have an Account with us, you may be able to obtain certain virtual coins, tokens or otherwise ("Coins") by participating in certain in-app campaigns, completing certain in-app tasks or participating in certain promotional activities hosted by or for us (collectively, "Campaigns"). If you do not have an Account with us, you will not be able to participate in any Campaign or obtain any Coins. The Coins you obtain will be displayed to you in your Account. You are not required to make any purchase in order to participate in any Campaign. Coins are not for sale and you may only obtain Coins by participating in the Campaigns.

You acknowledge that you may be subject to additional terms and conditions in connection with your participation in certain Campaigns and your access to or use of the Coins. The availability and applicable terms and conditions for any specific Campaign and/or the Coins feature will be determined by us. If there is any inconsistency between the terms and conditions under these Terms and such additional terms and conditions for specific Campaign and/or the Coins feature, such additional terms and conditions will prevail with respect to the inconsistency and with respect to such specific Campaign and/or Coins feature.

You acknowledge that:

Coins that you obtain is for your self-use only;
Coins cannot be transferred, assigned, sold, traded, given away or otherwise exchanged among SHAREit users;
Coins cannot be redeemed to cash or legal tender;
you do not own the Coins or have any proprietary rights in and to the Coins, but you are only granted with a limited license to use such Coins in accordance with these Terms;
any balance of Coins displayed in your Account does not constitute any stored value; and
Coins cannot be used outside the Services.

You acknowledge that Coins can only be used in the manner(s) expressly permitted by us (e.g., topping up your mobile charge). The rules for using the Coins will be displayed to you on the Services. Any of your use of the Coins cannot be reverted or cancelled. When you use the Coins with different validity periods, the Coins with the validity period that will expire the earliest will be automatically consumed first. We may modify the permitted manner(s) and the rules for using the Coins from time to time at our sole discretion.

Any Coin you rightfully obtain is not subject to a limited validity period, unless otherwise specified (e.g., in the applicable rules for a specific Campaign), provided, that, all Coins you obtain will automatically and immediately expire (a) if you fail to log in your Account for 30 consecutive calendar days, on the date immediately following such 30-day period; (b) on the date you terminate your Account; (c) when we terminate your Account in accordance with these Terms; (d) when we terminate the Services permanently; or (e) when we terminate the Coins feature.

11. Third Party Services

By accessing or using the Services, you may access or use content, materials, products or services ("Third Party Content/Services") provided by third parties.

Third Party Content/Services may include, without limitation and subject to the availability on SHAREit, mobile game top-up services, game virtual item purchase services, system protection and virus scan service, cloud storage services (rather than SHAREit Space feature, which is provided by us) or payment services provided by third parties.

In case that you access or use any Third Party Content/Services through the Services, you acknowledge and agree that:

the Third Party Content/Services (including without limitation payment services in connection with the use of such Third Party Content/Services) are provided to you by third parties, not us;
you are solely responsible for your access to or use of such Third Party Content/Services;
you shall be solely responsible for your reliance and other activities arising from or in connection with your access to or reliance on such Third Party Content/Services;
we have no control over the Third Party Content/Services, and we do not warrant, approve or endorse any Third Party Content/Services in any manner;
we are not responsible for the accuracy of Third Party Content/Services;
we do not guarantee the quality, reliability or suitability of any Third Party Content/Services;
we have no liability to you for any damages or losses suffered as a result of or in connection with your access to or use of Third Party Content/Services; and
any disputes arising from or in connection with your access to or use of such Third Party Content/Services shall be between you and the applicable third party.

Your access or use of Third Party Content/Services is subject to the agreements or understandings between you and the third party directly, and certain third parties may require you to agree to additional terms and conditions for accessing or using such Third Party Content/Services. Such agreements, understandings, additional terms and conditions are solely between you and the applicable third party. We are not a party to your relationship with such third party, neither do we act as the agent of you or the third party.

You acknowledge that we may, at our sole discretion, disable, suspend or remove the Third Party Content/Services from the Services in full or in part at any time without any liability to you.

Games

You acknowledge that the games (web games or App games) available on our Services and any and all content and elements embodied therein are Third Party Content/Services provided by the respective third party game distributors or developers or other third party providers, not by us.

Advertising Content

We may display or otherwise make available advertising, promotional or commercial content or activities ("Advertising Content") on our Services. You understand that Advertising Content is Third Party Content/Services and is provided for your information only. You agree that such Advertising Content may be displayed or made available on the Services in conjunction with your User Content.

Anti-virus Service

You may be able to use anti-virus services provided by third parties. The relevant third party may use software development kits (SDK) or other similar technologies to provide you with such system protection and virus scan services.

12. Code of Conduct for Using the Services

Your access to and use of the Services is subject to these Terms, all applicable laws and regulations and guidelines.

You agree and acknowledge that you will not:

access or use the Services if you are under the Minimum Age set forth in Section 3 (Who May Use the Services) above, or if you are otherwise not fully competent to enter into a binding agreement;
use the Services for any illegal or noncompliant purposes or violate applicable laws, regulations, rules, or guidelines;
modify, alter, reverse engineer, duplicate, resell, disassemble, decompile, transfer, copy, exchange or translate the Services or any elements therein or thereof without our prior written permission;
use the Services to make profits or for any commercial or unauthorized purposes, such as sending advertising content or messages without our prior written permission;
use any automated system, software, robot, spider, crawler, scraper or interface, or any other automatic device, software or process, whether operated by a third party or otherwise, to extract, monitor, copy or collect any data or information from the Services, or engage in any manual process to do the same;
attempt to circumvent any technical measures we employ or bypass our policies, or attempt to access parts or features of the Services that you are not authorized to access;
make available the Services or any elements thereof as a part of any other product or service;
probe, scan, or test the vulnerability of our Services or any system or network;
intimidate or harass other users, promote sexually explicit material, violence or discrimination based on race, sex, religion, nationality, disability, sexual orientation or age;
use or develop any third-party applications that interact with the Services or other users' content or information without our prior written consent;
use the Services in a way that could interfere with, disrupt, negatively affect, or inhibit other users from fully enjoying the Services, or take any acts that could affect, cause damage to or impair the provision of the Services;
use or attempt to use another user's account, username, or password without their permission;
solicit login credentials from another user;
use the Services to host, display, upload, modify, publish, transmit, distribute, broadcast, store or otherwise make available any content, materials or information that:
- belong to another person and to which you do not have any right;
- may violate applicable laws or infringe upon a third party's rights, including without limitation copyright, trade mark or other intellectual property, privacy or proprietary rights;
- may encourage or provide direction for a violation of law, dangerous activities or self-harm;
- are harmful, harassing, blasphemous, defamatory, obscene, pornographic, pedophilic, libelous, invasive of another's privacy, hateful, or racially, ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner whatsoever;
- harm minors in any way;
- deceive or mislead the addressee about the origin of such messages or communicate any information which is grossly offensive or menacing in nature;
- impersonate another person;
- would be considered, perceived or interpreted as obscene, indecent, pornographic, sexually explicit, libelous, maliciously false, inaccurate, misleading, offensive, deceptive, bullying, threatening, or abusive;
- would be considered, perceived or interpreted as threats, attacks, incitement to violence, hate speech, hateful behavior, discrimination, slurs, encouragement or facilitation of illegal and criminal activities, promotion or trade of regulated goods, frauds, scams, gambling, dangerous acts, harassment, sexual exploitation, impersonation, misinformation or fake engagement;
- contain viruses, Trojan horses, malicious code, worms, logic bombs software or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource; or
- at our sole discretion, is objectionable or may restrict or inhibit others from using the Services, or which may create a risk of loss, harm or damage to any person or property.

We may with or without notice to you (a) disable, suspend or terminate your Account or block or ban your access to the Services; (b) remove or disable any of your content; and/or (c) report to the applicable authorities and take other actions we deem appropriate in response to your violation or breach of these Terms or applicable laws, at any time without any liability to you. Some of the reasons may include where we consider that you fail to comply with any of the provisions of these Terms or applicable laws and regulations, or activities occur under your Account which, at our sole discretion, would or might cause damage to or impair the Services or infringe on or violate any third-party rights.

13. Protection of Intellectual Property Rights

We respect intellectual property rights and comply with applicable laws on protection of intellectual property. We sincerely ask you to do the same. You agree not to infringe upon intellectual property rights of any person while using the Services.

If you find anything on the Services infringing upon intellectual property rights which you own or control, you may notify us of such infringement at feedback_android@ushareit.com.

14. Subscriptions for Premium Services

Premium Service and Subscription Fees

We offer most of the features of the Services to you for free. But you may also subscribe certain features of the Services ("Premium Services") and pay subscription fees ("Subscription Fees") before you can use them.

The Premium Services are only available to users of Apple iOS version of the Services and who has a valid Apple ID account.

The price for Subscription Fees is are solely determined by us and will be displayed on the Services at the point of purchase. We reserve the right to change the price for the Premium Services from time to time and/or the features and functions available with the Premium Services in any manner and at any time as we may determine in our sole and absolute discretion, and we will use commercially reasonable efforts to communicate any such changes to you in advance. Price changes will be effective at the time of renewal of your subscription. As such, please make sure you read any notification of price changes carefully.

The currency applicable to your payment may depend on various factors (e.g., the jurisdiction where you make the purchase and the app store through which you make the purchase).

Payment Methods

You can pay for Subscription Fees via your valid Apple ID account. All payment will be processed in accordance with the applicable terms and conditions of Apple App Store. You agree that when you pay the Subscription Fees, (a) you authorize Apple to save your information of your chosen payment methods and continue billing your chosen payment method (e.g., credit card) to avoid interruption of the Premium Services, and (b) the taxes payable by you may be calculated based on the billing information that you provide at the time of purchase.

If there is any failure of payment via your chosen payment method (e.g., such payment is rejected, denied, not received by us), we may not be able to provide you with the Premium Services or may terminate to provide your access and use of with the Premium Services until payment is properly processed, and you are liable for any fees, costs, expenses or other amounts arising from such failure of payment. Your failure of the payment may result in a change to the start commencement date of your next Premium Service subscription period and may change the date on which you are will be billed for each subscription period.

Subscription Renewals and Cancellations

You agree that your subscription of the Premium Services will automatically renew for additional periods equal in duration to your preceding subscription term, and you authorize Apple to charge the Subscription Fees and applicable taxes automatically through your chosen payment method at the start of each new subscription period. If you do not want to use the Premium Services after the then-current subscription term or if you do not want to be charged automatically on a recurring basis, you must cancel or adjust your subscription at least 24 hours before the subscription period renewal date. You can cancel or adjust your subscription of the Premium Services via Settings - iTunes Account & App Store - Apple ID - View Apple ID - Subscriptions. You will still have access to the Premium Services after your cancellation until the end of the then-current subscription term, after which you will not be able to use the Premium Services you have unsubscribed.

Free Trials

You may be able to sign up for a free trial ("Free Trial") of the Premium Services for a limited period and may be required to provide your payment information to start the Free Trial. By providing your payment details to sign up for the Free Trial, you agree to such charge and authorize Apple to charge the applicable Subscription Fees upon the termination of the Free Trial period.

You may cancel your Free Trial at any time but at least 24 hours before the end of the Free Trial period. If you do not timely cancel your Free Trial at least 24 hours before the end of the Free Trial period, to the extent permitted under applicable laws, you will be automatically charged the Subscription Fees applicable to the Premium Services following the end of the Free Trial period, and unless you have otherwise chosen a subscription period, your subscription of the Premium Services will be renewed according to the renewal period applicable for the subscription model selected by you when you sign up for the Free Trial.

To the extent permitted under applicable laws, we reserve the right to modify or terminate your Free Trial for any reason or no reason, with or without prior notice to you.

Refunds

You must follow the applicable refund policy of Apple App Store.

15. Tax

If you are subject to any taxes imposed by any jurisdiction on the payment for your use of the Services, you will be responsible for the payment of such taxes (including any related penalties or interest). We reserve the right to charge any applicable taxes if we determine that we are required to do so by applicable laws. We also reserve the right to request certifications from you in relation to taxes and to report to tax authorities amounts paid and/or withheld from payments to you.

16. Your Feedback

By sending, submitting or otherwise making available any feedback, ideas, suggestions, documents, proposals or other materials ("Feedback") to us or our personnel, you irrevocably grant us a sublicensable, transferable, perpetual, universal and unlimited license to use, exploit or disclose such Feedback for any purpose in any manner without restriction and without any compensation or credit to you or any third parties, whether in whole or in part, and whether as provided or as modified. You also agree that we have no obligation to review, consider, use or implement your Feedback, and nor will we be required to treat your Feedback as confidential.

17. Indemnity

YOU AGREE TO INDEMNIFY, DEFEND AND HOLD HARMLESS US, OUR SUBSIDIARIES, AFFILIATES, LICENSORS, LICENSEES, ASSIGNS AND SUCCESSORS AND EACH OF OUR AND THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, SUPPLIERS, AGENTS, PARTNERS, ADVISORS ("SHAREIT PARTIES") FROM AND AGAINST ANY CLAIM, PROCEEDING, LOSS, DAMAGE, LIABILITY, COST, DEMAND OR EXPENSE (INCLUDING WITHOUT LIMITATION ATTORNEY'S FEES) OF ANY KIND ARISING OUT OF OR RELATED TO: (A) ANY OF YOUR ACT OR OMISSION; (B) YOUR BREACH OF THESE TERMS; (C) YOUR OR YOUR USER FILES OR YOUR USER CONTENT'S VIOLATION OF THE RIGHTS OF ANY THIRD PARTY, INCLUDING WITHOUT LIMITATION INFRINGEMENT ON ANY INTELLECTUAL PROPERTY, PROPRIETARY RIGHT OR TRADE SECRET, OR PRIVACY OF ANY PERSON OR ENTITY, OR APPLICABLE LAWS; (D) YOUR VIOLATION OF LAW OR CONTRACTUAL OBLIGATION AND ANY CLAIMS, DEMANDS, NOTICES IN CONNECTION THEREWITH; AND/OR (E) YOUR USE OF THE SERVICES.

18. Disclaimer

NOTHING IN THESE TERMS SHALL AFFECT ANY STATUTORY RIGHTS THAT YOU CANNOT CONTRACTUALLY AGREE TO ALTER OR WAIVE AND ARE LEGALLY ENTITLED TO AS A CONSUMER.

YOU EXPRESSLY UNDERSTAND AND AGREE THAT, UNLESS OTHERWISE REQUIRED OR CONTEMPLATED UNDER APPLICABLE LAW, THE SERVICES AND THE INFORMATION PROVIDED VIA THE SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT ANY CONDITIONS, WARRANTIES OR REPRESENTATIONS OF ANY KIND, EITHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAWS, SHAREIT PARTIES DISCLAIM ALL CONDITIONS, WARRANTIES OR REPRESENTATIONS OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING WITHOUT LIMITATION, CONDITIONS, WARRANTIES OF MERCHANTABILITY, QUALITY, FITNESS FOR A PARTICULAR PURPOSE, PERFORMANCE OR SUITABILITY FOR THE INTENDED USE, TITLE AND NON-INFRINGEMENT, OF THE SERVICES (INCLUDING ALL INFORMATION, CONTENT AND MATERIALS CONTAINED THEREIN). IN PARTICULAR, WE DO NOT REPRESENT OR WARRANT TO YOU THAT (I) THE SERVICES WILL MEET YOUR REQUIREMENTS; (II) THE SERVICES WILL OPERATE WITHOUT INTERRUPTION OR WILL BE SECURE, COMPLETE, RELIABLE, AVAILABLE OR ERROR-FREE; (III) ANY ERRORS OR DEFECTS IN THE SERVICES WILL BE CORRECTED OR THAT SUCH CORRECTIONS TAKEN WILL MEET YOUR EXPECTATIONS; OR (IV) THE SERVICES WILL BE COMPATIBLE WITH YOUR NETWORK, COMPUTER OR DEVICE.

WHILE WE ATTEMPT TO MAKE YOUR ACCESS TO AND USE OF THE SERVICES SAFE, WE CANNOT AND DO NOT REPRESENT OR WARRANT THAT THE SERVICES ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS OR WILL TRANSMIT DATA IN A SECURE MANNER. ANY DOCUMENTS OR MATERIALS TRANSMITTED, DOWNLOADED OR OTHERWISE OBTAINED THROUGH THE USE OF THE SERVICES ARE ACCESSED OR USED AT YOUR SOLE DISCRETION AND YOUR OWN RISK, AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR DEVICE OR LOSSES OF DATA OR CONTENT RESULTING THEREFROM.

WE MAY CHANGE, SUSPEND, WITHDRAW, RESTRICT OR TERMINATE THE AVAILABILITY OF ALL OR ANY PART OF OUR SERVICES FOR BUSINESS OR OPERATIONAL REASONS AT ANY TIME WITH OR WITHOUT NOTICE TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW.

19. Limitation of liability

NOTWITHSTANDING ANYTHING TO THE CONTRARY, NOTHING IN THESE TERMS SHALL EXCLUDE OR LIMIT ANY LIABILITY TO THE EXTENT THAT SUCH LIABILITY CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAWS.

SHAREIT PARTIES WILL NOT BE LIABLE TO YOU FOR ANY INDIRECT, SPECIAL, EXEMPLARY, CONSEQUENTIAL OR PUNITIVE DAMAGES, INCLUDING WITHOUT LIMITATION, ANY LOSS OF BUSINESS, REVENUES, PROFITS, OPPORTUNITIES, CONTRACTS, GOODWILL OR BUSINESS REPUTATION, OR ANY LOSS OF DATA OR CONTENT, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF THE FOREGOING DAMAGES.

SHAREIT PARTIES WILL NOT BE LIABLE FOR ANY LOSSES OR DAMAGES ARISING IN CONNECTION WITH (A) YOUR ACCESS TO OR USE OF THE SERVICES IN BREACH OF THESE TERMS; (B) ANY UNAUTHORIZED USE, CHANGES, MODIFICATION, ALTERATION OR DESTRUCTION OF THE SERVICES; (C) THE FAILURE, SUSPENSION, DISCONTINUATION OR TERMINATION OF ALL OR PART OF THE SERVICES AT ANY TIME; (D) ANY THIRD PARTY CONTENT, SOFTWARE OR FUNCTIONS (INCLUDING Third Party Content/Services) USED IN CONNECTION WITH THE SERVICES; AND (E) ANY RELIANCE OF YOU ON THE TRUTHFULNESS, RELIABILITY, COMPLETENESS OR ACCURACY OF ANY ADVERTISING CONTENT, OR ARISING FROM ANY RELATIONSHIP OR TRANSACTION BETWEEN YOU AND ANY ADVERTISER OR SPONSOR WHOSE ADVERTISING CONTENT APPEARS ON THE SERVICES.

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL THE TOTAL AGGREGATE LIABILITY OF SHAREIT PARTIES FOR ALL CLAIMS IN CONNECTION WITH THESE TERMS ARISING OUT OF ANY AND ALL CIRCUMSTANCES, EXCEED THE GREATER OF: (A) THE AGGREGATE FEE PAID OR PAYABLE BY YOU TO US, IF ANY, IN THE PAST TWELVE MONTHS FOR THE SPECIFIC SERVICES GIVING RISE TO THE CLAIM; AND (B) ONE HUNDRED U.S. DOLLARS (U.S. $100.00).

20. Governing Law

These Terms shall in all respects be governed by and construed in accordance with the laws of Singapore, without regard to conflict of law rules or principles.

21. Termination

Termination by You

You may delete your Account or stop using the Services at any time. If you want to terminate or disable your Account, you may submit your Account deletion request on SHAREit or contact us at feedback_android@ushareit.com.

Termination by Us

We may suspend or termination your Account and/or access to the Services in full or in part, with or without notice to you, if (a) your user name violates applicable laws or guidelines or is otherwise deemed as inappropriate by us; (b) you infringe the intellectual property rights or other right of a third party; (c) you or any of your User Files or User Content violates these Terms, documents referred herein or additional terms and conditions applicable to you for your access or use of the Services; (d) your use of the Services, your User File or your User Content is illegal or otherwise violate applicable laws; (e) you fail to pay fees due and payable; (f) we are requested to do so upon a request or order from a governmental, judicial or other authorities; (g) we terminate your Account or access to the Services upon your request; (h) we discontinue or terminate our Services, in full or in part, permanently or otherwise; (i) if we reasonably believe that your access or use of the Services is or suspended to cause harm or damages to us or a third party.

22. Dispute Resolution

Your Dispute with Us

You agree to contact us first for any claim, dispute or controversy ("Dispute") arising from or in connection with these Terms, including any question regarding existence, validity or termination of these Terms. Both parties agree to attempt to resolve such Dispute in good faith.

For any unresolved Dispute, the parties agree that such Dispute shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre in accordance with the Arbitration Rules of the Singapore International Arbitration Centre for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be Singapore. The tribunal shall consist of three (3) arbitrators. The language of the arbitration shall be English.

Your Dispute with Third Parties

To the fullest extent permitted by law, any dispute between you and third parties (e.g., service provider, copyright owner) relating to your use of the Services, shall be resolved between you and such third party directly. SHAREit Parties will not be held liable to any extent for any and all claims, demands and damages (actual and consequential) of every kind and nature arising out of or in any way related to your dispute with third parties. You hereby irrevocably release SHAREit Parties from, defend and hold SHAREit Parties harmless against any and all claims and liabilities arising out of or in connection with your disputes with third parties of any nature.

23. Other Terms

Force Majeure. We will not be responsible for any failure to perform our obligation hereunder caused by reasons beyond our reasonable control.

Entire Agreement. These Terms, together with any other terms or policies incorporated herein by reference, constitute the entire agreement between you and us governing your use of the Services, and replace all prior agreements and communications between you and us in relation to your use of Services.

Severability. If any provision of these Terms is found to be invalid or unenforceable, then, without affecting the validity or enforceability of the remaining of these Terms, such provision shall be deemed to be severed from these Terms, and if possible, replaced with a similar provision to the extent valid and enforceable under applicable laws and regulations so as to effect the original intent of the parties as closely as possible so that the agreements and transactions contemplated hereunder are consummated as originally contemplated to the fullest extent possible. The remaining provisions of these Terms will continue to be valid in full force and effect.

No Waiver. Our failure or delay to enforce any provision of these Terms shall not be deemed as waiver of any rights hereunder and will not prevent further exercise of our rights later.

Assignment. We may freely assign, transfer or sub-contract these Terms or any of our rights or obligations hereunder, in whole or in part, to any third party without notice to you. You shall not assign these Terms without our prior written consent.

Survival. Upon termination of these Terms, any provision which, by its nature or express terms should survive, will survive such termination, including without limitation Sections 7 (SHAREit Content), 9 (User Content), 16 (Your Feedback), 17 (Indemnity), 18 (Disclaimer), 19 (Limitation of Liability), 20 (Governing Law), 21 (Dispute Resolution) and 23 (Other Terms).

Independent Contractor. These Terms do not and shall not be constructed to create any joint venture, partnership, employment, agency or franchise relationship between you and us.

No Third Party Rights. No third party other than you and us shall have rights to rely on or enforce these Terms, unless otherwise provided under these Terms.

Headings. Headings are included for reference purpose only and will not affect the meaning or interpretation of any provisions in these Terms.

24. Contact Us

If you have any questions or want to learn more about the Services, please contact us at feedback_android@ushareit.com.

25. Apple App Store Specific Terms

Your use of the Services made available as an application via the Apple App Store ("iOS Apps") is subject to any policies promulgated by Apple Inc. or its affiliates or subsidiaries (collectively, "Apple") that apply to the use of such Services, including the Apple Media Services Terms and Conditions available at https://www.apple.com/legal/internet-services/itunes/.

If there is any inconsistency between the provision of this Section 25 and the remaining provisions of these Terms, the provision of this Section 25 shall prevail.

You acknowledge that:

to the extent any third party content is made available or accessible via the iOS Apps, the third party providing such content shall be solely responsible for such content;
we may from time to time adjust your visibility, status or rank on iOS Apps in accordance with these Terms;
we, not Apple, license or make available the iOS Apps to you in accordance with these Terms and these Terms are between we and you, not Apple;
the license granted to you in the iOS Apps is limited to a non-transferable license to use the iOS Apps on any Apple-branded products that you own or control and as permitted by the Usage Rules set forth in the App Store Terms of Service, except that such iOS Apps may be accessed and used by other accounts associated with the purchaser via iOS Family Sharing or volume purchasing;
you and we acknowledge and agree that Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the iOS Apps;
you shall be solely responsible for ensuring your use of any account that you use to log into the Services is in accordance with the policies applicable to such account;
Apple Inc. and its affiliates are not responsible or liable to you for content made available through the Services, and as between you and Apple, you, not Apple, are solely responsible for your use of the Services and the content thereof;
in the event of any failure of the iOS Apps to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price for the iOS App(s) to you; and, to the maximum extent permitted by applicable laws, Apple will have no other warranty obligation whatsoever with respect to the iOS Apps, and as between Apple and us, any other claims, losses, liabilities, damages, costs or expenses attributable to any failure to conform to any warranty will be our responsibility;
as between Apple and us, (a) we, not Apple, are responsible for addressing any of your claims or claims of any third party relating to the iOS App or your possession and/or use of that iOS App, including, but not limited to: (i) product liability claims; (ii) any claim that the iOS App fails to conform to any applicable legal or regulatory requirement; and (iii) claims arising under consumer protection, privacy, or similar legislation, (b) in the event of any third party claim that the iOS App or your possession and use of that iOS App infringes that third party's intellectual property rights, we, not Apple, will be solely responsible for the investigation, defense, settlement and discharge of any such intellectual property infringement claim;
we do not grant you a right to use any intellectual property rights, including trademarks, of Apple Inc. or its affiliates. Your use of such intellectual property rights is granted (if applicable) in accordance with the Apple Media Services Terms and Conditions and any other policies made available by Apple Inc. or its affiliates from time to time in relation to use of the platform;
we may be required to change the Services, or these Terms, in order to comply with instructions of Apple. You agree that we are permitted to make such changes immediately and without notice and shall have no liability to you or others with respect to such changes; and
Apple, and Apple's subsidiaries, are third party beneficiaries of these Terms, and that, upon your acceptance of these Terms, Apple will have the right (and will be deemed to have accepted the right) to enforce these Terms against you as a third-party beneficiary thereof.

26. Indonesia-Specific Terms

If you are using our Services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of these Terms, the following terms shall prevail.

Minimum Age. The Services are only intended for people of more than 14 years old (including) in Indonesia.
Agreement to these Terms. By using the Services, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married, or under guardianship, you represent and warrant that you have obtained consent from your parent or legal guardian to use the Services. If you do not obtain consent from your parent or legal guardian, or your parent or guardian is not willing to give their consent, you must cease using the Services.

Effective Date: September 12th 2022

At SHAREit, we recognise that privacy is important. This Privacy Notice ("Notice") describes how Smart Media4U Technology Pte. Ltd., with its registered address at 6A Shenton Way, #05-02 Downtown Gallery, Singapore （068815） ("Smart Media4U", "we", "our" or "us") collects, processes, and protects personal data about you through the SHAREit App (the "App"), www.ushareit.com, and all other Smart Media4U websites and applications (collectively, the "Services") that link to this Notice. This Notice also describes your rights in relation to your personal data.

Smart Media4U is the controller of your personal data. If you have any questions about this Notice or how we use your data, our details are provided in the "Contact Us" section below.

This Notice may be provided in more than one language. In the event of any conflict, where permitted under local law, this English language version of the Notice shall prevail.

1. PERSONAL DATA THAT WE COLLECT

Personal data is information, or a combination of pieces of information, that could reasonably allow you to be identified. We collect personal data from a variety of sources, including from you directly (e.g., when you contact us), information we generate about you in the course of our relationship with you, and information we collect about you from other sources.

We may also collect certain personal data about you as required by law, or as a consequence of our contractual relationship. Failure to provide this information may prevent or delay the fulfilment of these obligations. We will inform you at the time when your information is collected whether certain data is compulsory and the consequences of the failure to provide such data.

Information you provide to us

We collect the following categories of personal data about you that you provide to us:

Personal details, which includes your age range, gender, nickname.;
Contact details, which includes your phone number, email address;
Authentication and identification information, which includes your user identification number, SHAREit ID, image;
Transactional information, which includes your information relating to any of your requests, queries, or complaints;
Content uploaded by you, which includes videos, audio content, music, pictures;
Actions taken by you in our App and your activity in our App, which include the following actions: like, not interested, share, report, following, follower, download, log-in history, sharing history, game score, game reviews, browsing history, search history, feedback; and
Any information you include in your publicly visible app profile or which you or others make available to us or the public, which includes your social media profile data if you use your social media account to log in to SHAREit, comments on the videos publicly circulated on the App or feedback you leave.

Information we collect automatically

We collect the following categories of personal data about you automatically, including:

internet or other electronic network activity information, such as the data we receive when you interact with our app (e.g., your search history, log data, or actions you take within the App) or information about your device (e.g., your device version, operating system, system language and regions, and identification number Device ID, Android ID, Google Advertising ID, Hardware Serial Number, Device Model, Operating system, System language and region, Mac address), and the information about the other apps you have installed;
subject to requirements under applicable law, coarse geolocation data, such as location information (including your GPS and latitude and longitude information) we receive about you (e.g., based on your Internet Protocol (IP) address, Wi-Fi SSID, etc.); We will only collect your GPS information with your express consent, you can withdraw your consent at any time by turning off location permissions;
Your network carrier and network type; and
Director information on your SD card.

Information we receive from other sources

We may receive and process personal data about you from other sources, including from publicly available sources. For example, we may receive personal data about you from commercially available sources, such as public databases (where permitted by law), and third-party services (such as third-party social media companies, advertising partners, and analytics providers).

2. HOW WE USE YOUR PERSONAL DATA AND THE BASIS ON WHICH WE USE IT

We use your personal data for the purposes described in the below table. In addition, we must have a legal basis to process your personal data, as specified under applicable laws. In most cases, the legal basis will be one of the following:

as consented by you in respect of this Notice;
to fulfil our contractual obligations to you, for example to provide the services you request;
to comply with our legal obligations, for example to obtain proof of your identity to enable us to meet our fraud prevention and anti-money laundering obligations;
to improve our services and user experience;
where permitted under applicable laws, to meet our legitimate interests, for example, to carry out data analysis to ensure the stability and security of our Services and prevent crime, fraud and misuse of our Services;
we may obtain your separate consent to collect and use certain types of personal data when we are required to do so by law (for example, in relation to our direct marketing activities). If we ask for your consent to process your personal data, you may withdraw your consent at any time by contacting us using the details at the end of this Notice; and
as otherwise may be permitted under applicable laws.

The provision of your personal data may be necessary for the purposes of entering into a contract with us or to receive the services you request, or may otherwise be voluntary. If you do not wish to provide your personal data to us, we may not be able to (a) provide the services you request, or (b) tell you about the services we offer.

If you are located in the EU or UK, you may refer to the legal basis for processing purposes under EU and UK data protection laws as outlined in the third column in the following table.

Purpose	How do we use personal data for this purpose?	Legal Basis under EU/UK data protection laws
Identification and authentication	We use your personal data to verify your identity and create a profile for you when you register with us, identify your device, access and use our Services, or otherwise engage with us, and to ensure the security of your personal data.	Using your personal data in this way is necessary for us to perform our contractual obligations to you and to provide you with the requested Service.
Contractual obligations	We use your personal data to meet our contractual obligations to you under our terms and conditions of use or to take steps at your request prior to entering into such contract.	Using your personal data in this way is necessary for us to perform our contractual obligations to you and to provide you with the requested Service.
Service operations	We process your personal data to provide the Services that you request, such as to connect you with other users; We use the information about the other apps you have installed to provide you with the App’s core functionality, which are peer-to-peer transmission service (with possible installation initiated by you thereafter) and file management.	Using your personal data in this way is necessary for us to perform our contractual obligations to you and to provide you with the requested Service.
Service improvements	We analyse usage information, including site analytics, to continually improve the user experience.	It is necessary for our legitimate interests to analyse usage information in order to improve our Services and your user experience.
Communications and customer service	Communications may include providing information to you about changes to the terms and conditions, updates regarding our Services, or responses to questions you pose. We also process your personal data to provide customer service support to you in connection with our Services.	It is necessary for our legitimate interests to inform you about changes to our terms and conditions, updates to our Services and respond to questions or communications that you send to us. It is necessary for our legitimate interests to provide customer support to you in connection with our Services, and also necessary for performance of our contract with you.
Advertising and marketing	We may use your personal data to build a profile about you, to understand your preferences, and to help determine which marketing materials (for example, region- or sector-focused) would be of interest to you. Where required by law, we will obtain your consent before sending such marketing materials; You can also reject it through our App.	Where necessary under applicable laws, we will process your personal data on the basis of your consent. For example, we will obtain your consent prior to sending you marketing messages. It is also necessary for our legitimate interests to understand your preferences and to provide you with information that we believe would be of interest to you.
Security	We may use your personal data for purposes such as security maintenance; in particular, we need to scan your App list information for this purpose when you use antivirus features.	It is necessary for our legitimate interests to protect the security of our App and Services.
Exercising our Rights	We may use your personal data to exercise our legal rights where it is necessary to do so, for example to detect, prevent, and respond to intellectual property infringement claims or violations of law.	It is necessary for our legitimate interests to process personal data for the purposes of exercising and defending legal claims and exercising our rights. Processing personal data may also be necessary to ensure compliance with our legal obligations.
Complying with our obligations	We may process your personal data to carry out fraud prevention checks or comply with other legal or regulatory requirements, when required by law.	It is necessary for our legitimate interests to process personal data for the purposes of protecting the security of our Service and protecting against fraud. Processing personal data may also be necessary to ensure compliance with our legal obligations.
Customising your experience	We may use your personal data to improve your experience of the Services, such as by providing interactive or personalised elements on the Services and providing you with content based on your interests. You can also reject it through our App.	It is necessary for our legitimate interests to provide you with information and personalised features that we believe would be of interest to you.

3. HOW AND WHEN WE SHARE YOUR PERSONAL DATA

We may share your personal data as follows:

With our service providers and other third parties that perform services on our behalf and support our business operations in connection with our Services. For example, we may partner with companies to send marketing messages, support email and messaging services, and analyse information. These third parties which may receive and process your personal data may include: (i) cloud service providers for the purposes of storing and operating data, as necessary for delivering our Services; (ii) providers of SMS services for the purposes of email support and messaging, for example in order to send verification codes to you where necessary as part of our Services; (iii) fraud prevention agencies in order to detect, prevent or resolve fraud, security or technical issues in connection with our Services; and (iv) other third parties that provide services to us, such as payment service providers or logistics providers when we hold in-app activities from time to time. The third parties that process your personal data on our behalf will use your personal data in accordance with the agreement we have in place with them and for the purposes described in this Notice.
With advertisers and marketing partners in order to display advertisements on our App and support our business, to show how many users of the App have clicked or viewed an advertisement, and third-party measurement companies for the purposes of measurement, analytics, engagement technologies and optimisation of our Services.
With members of our group of companies, including our affiliate companies as well as joint venture partners, for the purposes of processing, analysing, or storing your information or otherwise as needed to provide the Services to you or for the purposes set out in this Notice.
In certain circumstances, we may be required to disclose or share your personal data with law enforcement agencies, courts, other government authorities (whether in your jurisdiction or abroad) or other third parties where we or any of our affiliates believe it is necessary for us to do so to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
With potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to require the entity to which we transfer your personal data to use it in a manner consistent with this Notice.

4. INTERNATIONAL DATA PROCESSING & TRANSFER

The information we collect from you is stored on a server located in Singapore or the United States. Where permitted under applicable laws, your personal data may be transferred to, stored, and processed outside of your jurisdiction. If you are a user of the Services located in the EU or UK, your personal data may be transferred to a country that is not regarded as ensuring an adequate level of protection for personal data under European Union law / by the European Commission or under UK law / by the UK Government. This includes jurisdictions such as the United States and Singapore.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protection for your personal data. For more information on the appropriate safeguards in place, and to obtain a copy of such safeguards, please contact us at the contact information below.

5. DATA SECURITY AND RETENTION

We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data. We evaluate these measures on a regular basis to ensure the security of the processing.

Our Services may contain links to and from third party websites or services. Please note that if you follow a link to any of these third party websites or services, they will have their own terms of use and privacy policies, and we do not accept any responsibility or liability for these policies. Please read these policies before you submit any personal data to or otherwise use such third party website or services.

We retain your personal data for as long as we have a relationship with you. After our relationship ends, we only retain your information as long as required or permitted by law. We may also retain records to investigate or defend against potential legal claims, deal with complaints or official enquiries or investigations regarding the Services, or maintain business records for analysis and/or audit purposes. We will delete, destroy or anonymise users' personal data when: (i) the relevant service/feature/function for which the personal data was collected or used, is no longer available or removed; (ii) it is no longer necessary to retain the personal data for the purpose for which that personal data was collected; (iii) it is no longer necessary to retain the personal data for legal or business purposes; and (iv) it is not necessary to retain the personal data for other legitimate interests.

6. YOUR RIGHTS OVER YOUR PERSONAL DATA

You have certain rights regarding the personal data we hold about you, subject to local law. These may include the following rights:

access – confirm whether your personal data is processed by us, and if it is, to request a copy of your personal data and information relating to how it is processed;
rectify – request any inaccuracies in the personal data we hold about you be corrected or any incomplete personal data we hold about you to be completed;
erase – in certain circumstances, request that we erase your personal data from our records;
restrict – in certain circumstances, request that your personal data is no longer processed by us;
object – where we process your personal data on the basis of our legitimate interests, you have the right to object to this. However, we may continue to process your personal data if you have objected where we have compelling legitimate grounds to continue such processing or for the establishment, exercise or defence of legal claims;
direct marketing – you have the right to ask us to stop processing your personal data for direct marketing purposes;
portability / transfer – in certain circumstances, request to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to you or another third party you have chosen;
withdraw your consent – where we are relying on your consent to process your data, then you can withdraw your consent at any time;
automated decision making – in certain circumstances you have the right to request that you are not subject to automated processing of personal data, which produces a legal effect or similarly significantly affects you; and
lodge a complaint – you have the right to lodge a complaint with your local data protection authority. If you are in the United Kingdom, this is the Information Commissioner's Office (https://ico.org.uk/). If you are located in the European Economic Area (EEA), the contact details for data protection authorities in your jurisdiction are available here (https://edpb.europa.eu/about-edpb/about-edpb/members_en). We also encourage you to contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate. Please note that we may require additional information from you in order to honour your requests.

If you would like to discuss or exercise any rights you may have under law, please contact us at the contact details below.

7. CHILDREN'S INFORMATION

The Services are not directed to children, and we do not knowingly collect any personal data from children under the age of 13 (or such legally required age of consent as defined under applicable laws) or knowingly allow such person to register on our Services. In the event that we are notified that we have collected personal data from a child of or under the age of 13 (or such legally required age of consent as defined under applicable laws) without parental consent, we will suspend the account and delete relevant information as quickly as possible. If you believe that we might have any information from a child of or under 13 (or such legally required age of consent as defined under applicable laws), please contact us at the contact details provided below.

8. CONTACT US

Smart Media4U is the controller responsible for the personal data SHAREit collects and processes. If you have questions or concerns regarding the way in which your personal data has been used or would like to exercise any right, please contact us at: feedback_android@ushareit.com.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country of residence.

9.CHANGES TO THE NOTICE

You may request a copy of this Notice from us using the contact details set out above. We may modify or update this Notice from time to time.

If we change this Notice, we will notify you of the changes. Where changes to this Notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing) or to terminate your use of the Services.

10. INDONESIA-SPECIFIC TERMS

If you are using our Services in Indonesia, the following additional terms shall apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Notice, the following terms shall prevail.

Minimum age. The Services are only intended for users of more than 14 years old (including) in Indonesia.
Age, Parental and Guardian Consent. By using the Services, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married or under guardianship, you represent and warrant that you have obtained consent from your parent or legal guardian to use the Services. If you do not obtain consent from your parent or legal guardian, or your parent or guardian is not willing to give their consent, you must cease using the Services.

11. SINGAPORE-SPECIFIC TERMS

Where we rely on personal data provided by you (or your authorised representative), in order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided above.

Effective: February 28, 2019

1. Compliance with the Policy and Legal Requirements 2. Disclosures 3. Third-Party Services 4. Prohibited Advertisements and Practices 5. Restricted Advertisements 6. Editorial Requirements 7. Content Display 8. Consequences for Violations

The SHAREit Advertising Platform (the 'Platform', 'Platform' means any applicationand website of SHAREit that may display advertising contents on it.) is intended not only to provide a means for organizations of all sizes and budgets to promote their products and services, but also to enhance a user's experience by providing engaging, relevant, accurate, and fair advertisements. To ensure the furtherance of these objectives, SHAREit Advertising Policy (the 'Policy') is formulated. SHAREit reserves the right to amend this Policy at any time without notice and to modify, reject, or remove any advertisements, including advertisements not explicitly prohibited by the Policy, in its sole discretion, so please check in and review them regularly.

I) Compliance with the Policy and Legal Requirements

Our Advertising Policy provide guidance on what types of ad content are allowed. When advertisers place an order, each ad is reviewed against these policies. While the guidelines below may reflect certain legal requirements that are applicable to advertisers within particular industries, these guidelines are not legal advice. It is the responsibility of the advertiser to ensure that its advertisements and materials comply with all applicable laws and regulations, the Policy, and any instructions provided by SHAREit. If the contents of this policy is inconsistent with the laws and regulations of the targeting countries, the local laws and regulations shall govern. Indeed, adherence to these guidelines may not be sufficient to fulfill the legal requirements and regulations applicable to your industry. SHAREit urges advertisers to consult with their legal counsel regarding appropriate advertising practices for their industries, locations, and any additional locations targeted for advertising.

II) Disclosures

All required disclosures and mandatory warnings in ads must be clear and conspicuous.

Advertiser(s) must be accurately and clearly identified in the ad.

III) Third-Party Services

If you use a service, feature, or functionality that is operated by a third party and made available through our Services (including Services we jointly offer with the third party), each party's terms will govern the respective party's relationship with you. SHAREit is not responsible or liable for a third party's terms or actions.

IV) Prohibited Advertisements and Practices

SHAREit maintains a general prohibition on advertiser conduct that is designed to circumvent the Policy or to abuse the capabilities of the Platform. While this prohibition includes conduct that results in advertising-platform arbitrage, that disseminates malware, that exploits data from users in an irresponsible manner, that redirects users to unknown destinations, or that endeavours to circumvent SHAREit's review systems, whether specific conduct falls within this general prohibition is determined in the sole discretion of SHAREit. In addition to this general prohibition, SHAREit prohibits advertisements related to the following categories of products and services on its Platform:

1. Products or Services that Facilitate Illegal, Fraudulent, or Misleading Behavior

Products or services may not be advertised on the Platform that facilitate illegal, fraudulent, or misleading behavior. Examples of such products or services include those used for hacking or obtaining unauthorized access to wire, electronic, or other networks, those designed to circumvent copyright limitations, those designed to cause inflation of website metrics, such as clicks, impressions, likes, or followers, those designed to produce inauthentic documents, work product, or credentials, those which obscure the transparency of the blockchain, those designed to assist in evasion of law-enforcement activities, and those related to unlawful, improbable, or unsubstantiated financial products and services, investment, or contribution strategies and schemes.

2. Counterfeit Goods

Advertisements may not promote or offer for sale counterfeit goods, including inauthentic collectibles or memorabilia and goods with a mark or logo that is likely to be confused with the trademark of another.

3. Hazardous Products or Services

Advertisers may not use the Platform to promote the use or sale of hazardous, dangerous, or injurious products or services, including products subject to consumer recalls, explosive materials or fireworks, recreational drugs or substances, weapons, guns, ammunition, explosives, tobacco products, and related products or services.

4. Obscene, Offensive, or Inappropriate Content

Advertisers may not use the Platform to disseminate obscene, offensive, or inappropriate content. Such prohibited content includes content that depicts intolerant or overly contentious political or cultural topics or views, that uses vulgar or sexually explicit words or images, that is designed to evoke visceral reactions, or that is improperly targeted toward minors.

5. Inappropriate Targeting

SHAREit strives to offer useful and relevant ads to its users. As such, all targeting must be relevant, appropriate, and in compliance with relevant legal obligations of the advertiser. Examples of inappropriate targeting may include (but are not limited to):

Goods or services targeted to regions where they are illegal;
Age-restricted products or services targeted to minors;
Ads whose targeting illegally discriminates;
Ads whose targeting is likely to provoke or cause outrage.

Ads disapproved for inappropriate targeting may be resubmitted with targeting revisions.

6. Deceptive, Untrue, or Misleading Advertising

Advertisers using the Platform must ensure their advertisements are truthful, non-deceptive, and defensible. Thus, advertisers may not employ techniques that are deceptive, untrue, or misleading, including failing to disclose material terms of an offer or service, irresponsible use of the term 'free', offering software that includes undisclosed collection of personal data or malicious applications, promoting products that facilitate spam, making factual claims unsupported by a reasonable basis, or using sensational, exaggerated, or overly provocative content.

Ads must not mislead users into interacting with their creative content; this includes ads that simulate system or site warnings/error messages or appear to offer a functionality that is not present within the ad.

7. Prohibited Financial Products and Services

Ads must not promote financial products and services that are frequently associated with misleading or deceptive promotional practices.

The following types are not allowed:

Initial Coin Offerings
Binary Options

8. Sale of Body Parts

Ads must not promote the sale of human body parts or fluids.

9. Spyware or Malware

Ads must not contain spyware, malware, or any software that results in an unexpected or deceptive experience. This includes links to sites containing these products.

10. Automatic Animation

Ads must not contain audio or flash animation that plays automatically without a person's interaction or expands within Facebook after someone clicks on the ad.

11. Unauthorized Streaming Devices

Ads must not promote products or items that facilitate or encourage unauthorized access to digital media.

12. Payday Loans, Paycheck Advances, and Bail Bonds

Ads may not promote payday loans, paycheck advances, bail bonds, or any short-term loans intended to cover someone's expenses until their next payday.

13. Surveillance Equipment

Ads may not promote the sale of spy cams, mobile phone trackers or other hidden surveillance equipment.

V) Restricted Advertisements

In addition to the prohibitions on certain categories of advertisements, SHAREit also enforces limitations how certain products and services may be advertised on the Platform. These restrictions are designed to ensure that controversial or age-restricted products or services appear only to the appropriate users. These restricted categories of advertisements are discussed in more detail below:

1. Adult-Oriented Products or Services

Only certain categories of products or services that are intended for adult audiences may be advertised on SHAREit. If promotion of the product or service is permitted, SHAREit restricts the method of promotion.

The following categories of adult-oriented products and services are strictly prohibited:

products or supplements claiming to provide sexual enhancement; and promotion of permissible adult-oriented products and services must not:
violate applicable laws and regulations, which may include those applicable to the location of your business or of your target audience;
target minors;
include sexually explicit images or text; or
promote products or services with unlawful themes or content.
utilize the video ad format.

2. Alcohol

Advertisements related to alcoholic beverages or products must:

comply with applicable laws and regulations, which may include those applicable to the location of your business and of your target audience;
comply with industry standards, as may be reflected in the Distilled Spirits Council Code of Responsible Practices, the Beer Institute Advertising and Marketing Code and Guidelines, or the Wine Institute Code of Advertising Standards; and
target individuals above the legal-drinking age.

3. Third-Party Rights

Advertiser shall not infringe upon or misappropriate any copyrights, patents, trademarks, design rights or registrations, trade secrets, confidential information, or similar intellectual property rights (collectively 'IP Rights') of any third party. If a proposed advertisement includes third-party content that has been authorized for such use, advertisers may be required to submit documentation to SHAREit evidencing such authorization.

4. Dating Services

SHAREit allows dating sites, apps, and associated services to advertise, with restrictions. All advertisers within this vertical must be pre-approved and working directly with a SHAREit sales representative.

The following types of sites, apps, and services are prohibited:

Those centered on infidelity
Those that provide for casual sex, international matchmaking, escorts, prostitution, intimate massages or other, similar services
Those focused on fetish communities
Those that exclude persons of specific races, sexualities, religions, political affiliations, etc.

5. Political Advertisements

SHAREit permits responsible political advertising, and expect all political ads and destinations to comply with local legal requirements, including campaign and election laws and mandated election 'silence periods', for any geographic areas they target. The content of political ads shall be neutral and unbiased, focusing on factual situation and statics, and no any form of slandering, hate speech, etc. This policy applies to political content which consist of political campaigning and issue advocacy advertising. Advertisers can run political, election related and issue ads, provided the advertiser complies with all applicable laws and have a written agreement with SHAREit.

Note that election ads don't include ads run by non-political entities promoting political merchandise like t-shirts, or ads run by news organizations to promote their coverage of political parties, election campaigns, candidates, or current elected political members.

For example, In India, election ads are ads for Lok Sabha Elections that feature a political party, a political candidate, GOVERNMENTAL OR MINISTRY BODY or current member of the Lok Sabha, or any ads that are run by a political party, GOVERNMENTAL OR MINISTRY BODY political candidate, or current member of the Lok Sabha. In India, election ads don't include ads run by non-political entities promoting political merchandise like t-shirts, or ads run by news organizations to promote their coverage of political parties, Lok Sabha election campaigns, candidates, or current Lok Sabha members.

6. Gambling and Gambling-Related Services

All gambling advertisements must be manually approved and certified by SHAREit. All approved gambling advertisers must comply with applicable laws, regulations, and licensing requirements, which may include those applicable to the location of your business, those applicable to the location of your target audience, and those related to responsible gambling. They must also comply with industry standards, as may be reflected in the American Gaming Association's Code of Conduct for Responsible Gaming (or country equivalent) and ensure minors are not the target of such advertisements.

The following products and services will be affected by this policy:

Online casinos and gambling where real money is exchanged
Sports betting
Fantasy sports games where real money (or other items of value) is exchanged
Lotteries
Brick and mortar casinos
Games/apps played for money or other items of value, such as gift cards

The following products and services will not be affected by this policy:

Gaming where nothing of value is exchanged
Gambling-related merchandise
Hotel-casinos that primarily promote the casino

7. Health and Pharmaceutical

SHAREit restricts the promotion of certain health and wellness products and services. In addition to our own policies, all advertisements must comply with applicable laws, rules, regulations, licensing requirements, and industry standards. Advertisers are responsible for geo-targeting in compliance with country-specific laws and regulations.

Further, advertisements may not make false, misleading, or exaggerated health claims; promote products that are subject to any regulatory action or warning; or promote a non-government-approved product in a manner that implies safety or efficacy in diagnosing, mitigating, treating, curing, or preventing a particular disease or ailment.

Subject to the preceding requirements and pre-approval by SHAREit, the following products or services may be advertised, except as noted:

(i) Pharmacies, including online pharmacies, that are certified by a third-party licensing organization such as the NABP or LegitScript. Proof of licensing may be necessary for approval.

(ii) Pharmaceutical and medical products that are approved by the FDA (or foreign equivalent, depending on the advertisement's geographic targeting) including but not limited to:

Prescription drugs
Over-the-counter medicines
Medical devices
Pharmaceutical manufacturers

(iii) Approved supplements with a demonstrated record of safety, subject to SHAREit's sole discretion. All ads for supplements must include appropriate, clearly legible disclaimers in the advertisement creative. Additionally, supplement advertisements may not do the following:

Make unsubstantiated claims
Promise unexpected results
Imply that the product can diagnose, cure, mitigate, treat, or prevent a disease
Imply that a product is as effective or more effective than an FDA (or equivalent) approved prescription drug or medical treatment

(iv) Clinical trials with proof of approval by the relevant regulatory authority.

(v) Appropriately licensed (including FDA or foreign equivalent approval where necessary) medical services, procedures, and tests including but not limited to:

Licensed medical professionals
Telemedicine providers with proper medical licensing and registration
Family planning tests and services
HIV and other infectious disease tests
Genetic testing services
Medical and cosmetic surgery

(vi) The advertisement of addiction treatment centers and services is prohibited.

8. Financial Services Including Cryptocurrencies

Ads related to the exchange, management or investment of funds (fiat or virtual) must comply with known applicable laws, regulations, licensing obligations, and industry requirements.

For all ads within this category, at minimum we require the following disclosures to be easily accessible in the ad or from the landing page:

Proper disclosure of all fees;
Evidence of appropriate regulator and/or third-party accreditations or certifications.

Subject to the preceding requirements and approval by SHAREit, the following non-exhaustive list of products or services may be advertised:

FDIC (or foreign equivalent) registered banks and their associated products and services;
Tax filing services;
Apps that track/monitor stocks or financial trends, including cryptocurrency trackers so long as they do not require wallet integration;
Budgeting apps;
Brokerage or trading platforms and associated apps for traditional stocks/bonds as well as for cryptocurrency exchanges with a demonstrated record of legitimate business practices;
Apps or services that facilitate payment or transfer of funds;
Events related to business, finance, cryptocurrencies, and related subjects, so long as there is easily accessible disclosure in the ad copy or landing page clarifying that the information presented is not investment advice.

The following non-exhaustive list of products or services are prohibited from being advertised on the site:

Single securities or other tradable financial assets
Bail bonds
Payday loans
Debt assistance programs
Get rich quick schemes
Pyramid schemes and multi-level marketing
Penny auctions
Binary options
Cryptocurrency wallets
Unaccredited digital banks that perform any traditional bank-like functions
Cryptocurrency credit or debit cards
Initial coin offerings, token sales, or other means of promotion or advertisement of individual digital currencies or tokens.

9. Live Animals

Advertisements promoting the sale of live animals are generally prohibited; however, SHAREit permits advertisements related to pet adoption from bona fide animal-welfare organizations.

VI) Editorial Requirements

The size and format of the Ads Content provided by Advertiser shall meet the requirements of SHAREit. Should Advertiser fail to meet the requirements, SHAREit may request Advertiser to make amendments accordingly.

1. Style Policies

Advertisements on the Platform that appear clearly and concisely both add to a user's experience and are more likely to produce the advertiser's desired results. Below are general guidelines for effective communication using the Platform:

Use correct spelling, grammar, and punctuation.
Use punctuation, capitalization, or symbols reasonably.
Unless required by law or by a regulatory authority, do not include personal information in the headline title, such as a telephone number.

2. Quality

SHAREit requires that all ads on the platform meet high professional and editorial standards. To ensure users are presented with high quality and useful ads, we require the following:

The ad should not purposely withhold information as a way to persuade users into interacting with it (eg 'clickbait')
The ad should be free of any 'worm', 'virus' or other device that could impair or injure any person or entity

3. URL and Landing Page Policies

Advertisers must ensure that the destination URL and the landing page corresponding to the advertised product or service maintain the same level of quality expected for content on the Platform. In addition, the landing-page URL must match that of the advertisement, must not be solely designed to send a user elsewhere, and must not contain or refer to any content that would be otherwise prohibited by the Policy.

VII) Content Display

The ads pages shall be safe, stable, and normally browsing.
No major changes may be made to the content displayed on the Ads pages, such as changing the original product to a product that requires special business license to operate. Should any modification is required, Advertiser shall be notified in advance and resubmitted to SHAREit for re-reviewing.
No automatic page forwarding may be made based on region, time, ip, etc., to result in the links between Ads pages and Ads submitted for reviewing are inconsistent.
No violation of Laws, Regulations or the provisions of this Policy by setting malicious code, viruses, etc. on Ads pages.

VIII) Consequences for Violations

In its sole discretion, SHAREit will determine the consequences for a violation of the Policy or of the rejection of any submitted content. Consequences may include the following:

Disapproval: Advertising content in conflict with this Policy or determined to be inappropriate for the Platform in SHAREit's sole discretion may be disapproved by SHAREit.
Restriction: SHAREit, in its sole discretion, may restrict or entirely prevent certain domains, websites, or services from using the Platform.
Suspension: SHAREit, in its sole discretion, may suspend an advertiser's account from contributing content to the Platform. If an account is suspended, any related accounts and content from such accounts will be suspended as well.

1. Information about this Document 2. General Provisions 3. Basic Principles of the Company's Anti-Corruption Compliance 4. Specific Issues Related to Anti-Corruption Compliance 5. Liability 6. Appendix

1. Information about this Document

This Global Anti-Corruption Compliance Policy (the 'Policy') represents a part of commitment of group of companies SHAREit to conducting our business ethically and in compliance with all applicable laws wherever we operate.

This Policy focuses on anti-corruption laws, including the U.K. Bribery Act 2010 as amended (the 'UKBA'), the U.S. Foreign Corrupt Practices Act of 1977 as amended (the 'FCPA'), and other laws to which the Company (as defined in clause 1.4 below) is subject.

1.1 Purpose

This Policy establishes the basic principles and requirements for compliance with the provisions of Applicable Anti-Corruption Laws by the Company, the Employees of the Company, and any Agents of the Company.

This Policy pursues the following goals:

Describing the Company's prohibitions against bribery and corruption in all of its business operations.
Preventing any manifestations of corruption, both on behalf of and in regard to the Company and/or its Employees; compliance with the requirements of applicable Anti-Corruption Laws when the Company engages in its business activities.
Reinforcing the Company's commitment to conduct business globally with the highest standards of honesty and integrity.
Perfecting and developing the Company's corporate culture, implementing the best practices and standards of responsible business conduct, including in the area of Anti-Corruption Compliance.

1.2 Scope and Application

The Policy applies to all of the Company's Employees (as defined in clause 1.4 below), including the Company's directors, officers and contractors hired through third-party staffing arrangements.

Every Employee is required to become familiar with, and abide by, this Policy.

All Employees have a personal responsibility and obligation to conduct the Company's business activities ethically and in compliance with the law. Failure to do so may result in disciplinary action, up to and including dismissal. Employees may also be subject to regulatory and criminal action, which may lead to fines, debarment from certain positions, reputational harm and other sanctions up to and including imprisonment.

1.3 Definitions and Abbreviations

Term	Definition
Agents (Company Agents)	Agents, distributors, consultants, representatives, independent contractors, joint venture partners, intermediaries, and other third parties engaged by the Company that have the authority to represent the Company before other parties, including but not limited to government entities.
Anti-Corruption Compliance	A system of measures, procedures and controls operating in the Company for purposes of compliance with Applicable Anti-Corruption Laws.
Anything of Value	The term "Anything of Value" is broad and can include any item of monetary value, including, but not limited to, the following: Cash or the equivalent (including gift cards); Benefits and favors (such as special access to a government agency); Performing services that would otherwise have to be paid for or purchased; Gifts; Contracts or other business opportunities awarded to a company in which a Government Official has an ownership or other beneficial interest; Favorable or steered contracts; Employment opportunities, including those given to a family member or friend of a Government Official or representative of a commercial organization, such as positions in joint ventures or consultancy opportunities; Charitable donations; Political contributions; Medical, educational, or living expenses; Travel, meals, lodging, shopping, or entertainment expenses; or Investment opportunities or stock options.
Applicable Anti-Corruption Laws	Any laws and regulations applicable to the Company dealing with combatting against bribery (whether public or private), including the UKBA and other UK anti-corruption laws, the FCPA and other US anti-corruption laws, the laws of the corresponding countries where the Company conducts its activities.
Company	The group of companies, SHAREit as a whole, as well as all legal entities belonging to this group individually (depending on the context).
Employees (Company Employees)	Individuals engaged in long-term or temporary labor relationships with the Company who have concluded a contract of a civil law character with the Company and contractors hired by the Company with the engagement of outside organizations dealing with the supply of personnel.
Improper Advantage	The term "Improper Advantage" covers any improper payment made in a business context, such as (but not limited to) paying or giving Anything of Value to a Government Official or private individual or entity, directly or indirectly, in order to: Influence or prevent a governmental action, or any other action, such as the awarding of a contract, imposition of a tax or fine, or the cancellation of an existing contract or contractual obligation; Obtain a license, permit, or other authorization from a government entity or Government Official that the Company is not otherwise entitled to; Obtain confidential information about business opportunities, bids, or the activities of competitors; Influence the award of a contract; Influence the termination of a contract that is disadvantageous to the Company; or Secure any other Improper Advantage.
Governmental Entity	Any bodies of any national, regional, local or other government, including but not limited to state ministries and offices, services, agencies and their structural subdivisions, as well as all legal entities directly or indirectly controlled by the state as well as the judiciary. For purposes of this Policy, the term comprises also political parties and international organizations.
Government Official	Any employee or officer of a Governmental Entity, as well as any other individual or legal entity acting at the proposal, request, or instruction, or in the interests of a Governmental Entity.

2. General Provisions

2.1 The Company is committed to maintaining the highest level of ethical standards in the conduct of its business.

2.2 The Company does not accept any forms of corruption on the part of private individuals or Government Officials. The Company does not participate in any forms of unethical incentivizing or payments.

The Company does not engage in, nor does it accept any activity which does not comply with this Policy or with Applicable Anti-Corruption Laws.

2.3 The Company, Company Employees, and Company Agents are forbidden to offer, promise, approve, engage or authorize, directly or through an intermediary, in the transfer of Anything of Value to any Government Official or an agent or employee of a commercial organization with the purpose of influencing his or her actions (or ensuring inaction) and/or obtaining improper commercial advantage.

2.4 The Company, Company Employees, and Company Agents are forbidden to give consent to the obtainment or to obtain, solicit or otherwise receive, directly or through an intermediary, any payments in the form of money, securities, other property, render services of a property-related nature, grant other property-related rights or any other valuables, as well as any financial or other benefit or advantage or Anything of Value, if a condition for the obtainment of such payments, benefits or advantages is the commission of actions, the fulfillment of official duties in the interests of the giving party, as well as if these payments, benefits or advantages constitute remuneration, direct or indirect, for the fulfillment of such duties.

2.5 The Company, Company Employees, and Company Agents are forbidden to act as intermediaries in public or private bribery, i.e., to directly hand over bribes at the instruction of a bribe giver or bribe taker, or in some other way to assist in the achievement or realization of agreement between them to receive and give a bribe.

2.6 This Policy constitutes the Company's basic document in the area of Anti-Corruption Compliance; however, it is not invoked to implement exhaustive rules of conduct for Employees and Agents of the Company. In the event of a conflict between this Policy and other Company policies, Employees must apply the more restrictive policy or procedure.

2.7 The Company's management must through its conduct set a standard of ethical behavior and, by their personal example, form an uncompromising attitude among the Employees and Agents of the Company to any forms and manifestations of corruption, which must become an inalienable part of the corporate culture and everyday business practices of the Company.

3. Basic Principles of the Company's Anti-Corruption Compliance

3.1 Consistency in Application of the Policy

The Company consistently implements the rules and principles specified by this Policy and other policies of the Company in the area of Anti-Corruption Compliance. The Company propagates the principles of ethical business conduct and motivates the Company Employees and Agents to comply with this Policy. In the event of a breach of the rules of Anti-Corruption Compliance by Company Employees and Agents, the Company shall apply the relevant liability measures to them.

3.2 Monitoring of Legislation and Best Practices in the Area of Compliance

The Company persistently follows all amendments to the normative requirements of Applicable Anti-Corruption Laws and to the practice of applying it. Taking into consideration the results of that monitoring, and based on the best practices of Anti-Corruption Compliance, the Company takes measures to introduce the amendments into its current policies.

3.3 Periodic Risk Assessment

On a regular basis, the Company undertakes measures to bring to light and reduce corruption-related risks, and also measures to assess the efficiency of the current system of Anti-Corruption Compliance.

Taking into account the results of carrying out these measures, and in case of appropriate necessity, the Company will amend existing policies or develop and introduce additional policies. The measures undertaken must match the character of the risks discovered in a reasonable and proportional way.

3.4 Informing and Training

A copy of this Policy will be given to every director, officer, and employee of the Company and to contract workers engaged directly or through third-party staffing arrangements. All updates to the Policy will be circulated internally. The Policy will also be made available via the Company web-site and will be made available to all Company Agents.

3.5 Problem feedback

In the event that any Employee, or any agent, of the Company has questions concerning the content of this Policy, including questions of interpretation of any of its provisions, as well as doubts as to the legality or ethical character of his or her actions, the application and realization of the principles of compliance indicated in this Policy, including questions related to the applicability of such principles in this or that situation or business process of the Company, the Employee or the agent shall be obligated to send email to legalsupport@ushareit.com.

3.6 Forming and Upholding the Company's Reputation

The Company shall apply reasonable efforts to ensure that persons about whom it is known that they are involved or have been involved in illegal activities will not be admitted to managerial positions or allowed to join the Company's management bodies.

The Company's management bears liability for the maintenance and efficiency of the corporate system of Anti-Corruption Compliance as a whole, and also for ensuring the implementation and execution of controls and procedures of the Anti-Corruption Compliance system in the areas of its functional competence.

Company Employees, irrespective of the position they hold, are personally liable for observance of the principles and requirements of this Policy and the Applicable Anti-Corruption Laws, as well as for the actions (inactions) of the persons subordinate to them who violate these principles and requirements.

4. Specific Issues Related to Anti-Corruption Compliance

4.1 Contractual Compliance Controls

In the cases designated by the Company's policies, contracts entered into by the Company with third parties must envisage the obligations of those parties to observe the Applicable Anti-Corruption Laws (the anti-corruption clause), according to the wordings approved by the Company. Furthermore, the contracts must specify the right of the Company to effect immediate unilateral termination in the event of a breach of the obligations specified by the anti- corruption clause.

In the cases designated by the Company's policies, contracts which the Company enters into with third parties likewise can envisage the right of the Company to carry out an audit of financial and other documentation pertaining to the implementation of the relevant contract.

4.2 Due Diligence of Business Partners and Employees

The Company shall apply reasonable efforts to minimize risks associated with interaction with any third parties, including business, labor and any other relationships with individuals or legal entities.

For this purpose, the Company has developed and maintains procedures for inspection in relation to Employees and business partners (legal entities and individuals), and with whom the Company plans to enter into a contract.

In addition, the Company carries out periodical due diligence of business partners with which it has entered into long-term contracts (lasting longer than one year).

The due diligence procedure in respect of the business partners and Employees has the following goals:

assessment of the necessity of hiring a business partner, Employee;
assessment of the overall reputation of the Employee or a business partner, its owners and key persons for compliance with the Applicable Anti- Corruption Laws;
finding out whether any violations of Applicable Anti-Corruption Laws have been committed in the past;
establishing whether the potential Employee or a business partner has any connections to Government Officials and Government Entities, which might influence obtainment by the business partner or the Company of improper commercial advantages;
assessment of the impact of these connections on the legality of entering into the contract with the business partner from the point of view of Applicable Anti-Corruption Laws;
assessment of commercial reasonableness and arm's-length basis for a proposed transaction.

Any Anti-Corruption Compliance red flags raised during the course of the due diligence review must be addressed to the satisfaction of the local compliance manager before formally entering into, or continuing, the relationship.

The statements in this clause 4.2 of the Policy extend also to contractors under transactions for merger, acquisition, or creation of joint ventures, and so forth. Moreover, also subject to due diligence are legal entities, ownership stakes or rights of control (direct or indirect) of which the Company acquires as a result of the transaction.

4.3 Gifts and Hospitality Expenses

The Company's business decisions and those of its partners must be made objectively, without influence by gifts or favors. A small, reasonably priced gift or gesture of gratitude may sometimes be an appropriate way for business people to display respect for each other. Nevertheless, regardless of value, the giving or receipt of a gift, meal, entertainment, or other hospitality benefit must not be done with the intent to improperly influence a Government Official or any other party doing business with the Company.

Any gifts and hospitality expenses of the Company (gifts which Employees and Agents of the Company may give on behalf of and/or at the expense of the Company to other individuals or legal entities, or which Employees, in connection with their work at the Company, may receive from other parties, as well as the corresponding hospitality expenses) must be in conformity with the following criteria:

is not made with the intent to influence the recipient in order to obtain or retain any improper business advantage for the Company or any other individual or entity, or as an explicit or implicit exchange for favors or benefits, or for any other corrupt purpose;
must not be prohibited by Anti-Corruption Laws applicable to the Company and recipient;
must not affect the capability of the recipient to make impartial and fair decisions in connection with the official powers he or she has been entrusted with, nor must it impose any moral obligation on the recipient;
must not constitute hidden remuneration for the obtainment of improper commercial advantage, including any service, action, omission or decision, and likewise must not represent an attempt to exert influence on the recipient with another illegal or unethical goal;
must be reasonably justified and not be a luxury item separately or jointly, if gifts or payments are made to a person more than once;
must not create for the Company risks to its reputation in the event of disclosure of information on such gifts or hospitality expenses;
must not contravene the principles and requirements of this Policy and other policies of the Company in the area of Anti-Corruption Compliance;
must be offered and accepted in a transparent manner and not be solicited;
must undergo the approval procedures established within the Company.

The indicated criteria shall also be applied to expenses on organization on behalf and/or at the expense of the Company of events aimed at attraction, retention or development of clients, as well as events related to communicating with the public, the mass media, and professional society.

Before the completion of any payment or donation of any gift in an amount exceeding (jointly during one-year period or separately) 100 USD to any third party, including to a Government Official, on behalf and/or at the expense of the Company, the Employee must contact the local compliance manager and provide detailed information about the proposed gift or other paid expenses in order to receive confirmation about the legality and admissibility of such payment or gift. Symbolic gifts, such as pens or calendars bearing the Company's logo, do not require the prior approval of the compliance manager.

The compliance managers shall be entitled to block transfer of the gift or payment of expenses if he or she establishes that such actions do not comply with the criteria set forth above, or create risks of violation of Applicable Anti- Corruption Laws for the Company.

It is not permitted to give gifts on behalf of the Company, Employees and Agents of the Company to any third parties in the form of monetary funds, whether cash or not, as well as any of their equivalents (for example, checks, gift cards, securities and so forth). Also, as a general rule, it is never permissible to pay for air fare and travel for spouses, other family members or other guests of Government Officials or any other third party.

Employees are entitled to accept small gifts and payment of hospitality expenses of modest value from third parties with which the Employees interact in the course of work for the Company, subject to the following conditions:

the acceptance of the gift or payment of hospitality expenses will not create for the Employee a conflict of interests in regard to his or her official duties in the Company and will not affect the performance thereof;
the Employee believes in good faith that the giver has no intention of affecting in some way the performance by the Employee of his or her official duties.

Employees must not solicit or request gifts. Employees are obligated to inform the compliance manager if they receive any gifts or payment of expenses by third parties for an amount greater than 100 USD (or the quality of that sum in local currency).

4.4 Retaining Government Officials

It may be justified to retain a current or former Government Official as an Employee or a business partner of the Company. However, doing so must be handled with caution. Such relationships must be structured so that they meet the requirements of the Applicable Anti-Corruption Laws and other applicable laws of relevant jurisdictions, and must not create a conflict of interest for the Government Official. No such relationship may be negotiated or agreed to without the prior approval of the compliance manager.

4.5 Sponsorship and Corporate Social Responsibility

In accordance with this Policy and other implemented procedures, the Company does not finance and does not participate in any other form in charitable and/or sponsorship activities for the purpose of receiving any illegal privileges or preferences in connection with business activity.

All of the Company's financial operations associated with sponsorship or charitable activity are recorded in detail and in a trustworthy manner in the accounting records; the project being realized undergo coordination in advance; the monitoring procedures for charitable contributions allow one to be convinced with a reasonable degree of certainty that the contributions made do not constitute a concealed form of bribery.

Before the Company or an Employee of the Company makes on behalf and/ or at the expense of the Company any donation for an amount greater than 100 USD, it is necessary to consult with the compliance manager, who is entitled to block payment after performing the appropriate due diligence for compliance with Applicable Anti-Corruption Laws.

4.6 Financing of Political Activity

The Company does not finance and does not support or encourage in any other way political parties or members thereof, including candidates for political positions, their election campaigns or political events, nor any political organizations or movements.

4.7 Payments through Intermediaries in Favor of Third Parties

The Company, its Employees and Agents are forbidden to engage any third parties for the commission of any actions that contravene the principles and requirements of this Policy or the standards of Applicable Anti-Corruption Laws. Such actions by third parties may expose the Company even if they have no actual knowledge or awareness.

The Company, its Employees and Agents are forbidden to make payments in favor of third parties, if there exists suspicion that all or part of this payment will be used to bribe a Government Official or an agent or employee of a commercial organization.

The Company ensures inspection of the reasonability and justification of payments or any other provisions to third parties for the prevention and/or discovery of the violations described above for purposes of minimizing the risks of involving the Company in corrupt activities. All commercial relationships with third-party intermediaries must be approved by the compliance manager, and all relationships must be put in the form of a written agreement.

4.8 Facilitating Payments

The Policy prohibits 'facilitating payments', i.e., unofficial payments provided in order to receive or expedite (speed up) a routine government action, i.e., actions which are ordinarily and commonly performed by Government Officials (e.g., processing governmental papers, such as permits, visas, etc.).

4.9 Books and Records

Employees or Agents are not allowed to conclude on behalf of the Company any transactions with fraudulent intent or with knowledge of the fact that the transaction or payment differs from the description in the documents confirming or justifying the transaction or payment.

For implementation of this prohibition, all financial operations, accounting postings and entries must be credibly recorded with a sufficient level of detail in the Company's books and records, and be documented and accessible for inspection.

Any payments to the third-party Agents should be made to bank accounts held by such Agent in the country in which the relevant goods or services were provided or the country where the Agent is registered. Any expenses for which reimbursement is requested by an Employee or Agent of the Company, as well as any expenses of the Company performed using cash resources, must be confirmed in documentary form using proper primary documentation, including original receipts, invoices or other relevant documents. Any requests for expense reimbursements must be approved by the supervisor of the Employee requesting payment.

4.10 Audit and Control

On a regular basis, the Company carries out internal and external audits of its financial and business activities, and also carries out ongoing control over the completeness and accuracy of the recording of all business operations in the books and records and observance of the requirements of applicable legislation and the Company's internal normative documents, including the principles and requirements established by this Policy.

As part of the internal control procedures at the Company, inspections are carried out into the discipline of implementing the established procedure for performance of business processes, including inspection into the legality of the operations undertaken involving the Company's assets and their economic justification, the advisability of expenses, including for confirmation by primary accounting documents and conformity with the requirements of this Policy.

4.11 Informing about Violations

Every Employee and Agent of the Company who has become aware of facts (or of signs pointing to them) regarding a violation or inclination to violate the provisions of this Policy and/or Applicable Anti-Corruption Laws by Employees or Agents of the Company, as well as by third parties, must inform about it by sending email to legalsupport@ushareit.com.

Within the limits of its powers, the Company shall undertake to ensure the protection of Employees who have conscientiously reported a violation or suspicion of a violation of the provisions of this Policy and/or Applicable Anti- Corruption Laws from persecution or any other form of discrimination on the part of the party in relation to whom the report was made.

In addition, the Company guarantees that none of its Employees will be held responsible (by being dismissed, demoted, deprived of a bonus, and so forth) by the Company if the Employee reported the presumed corruption in good faith, or if the Employee refused to give or take a bribe or render mediation in acts of bribery, including if such refusal results in foregone profit for the Company, or no commercial or competitive advantages were gained. Retaliation may result in disciplinary action up to and including termination.

The Company's guarantees to refuse to hold Employees accountable do not extend to guilty Employees, nor to cases when an internal investigation proves that the report in question was deliberately false, or constituted perjury or libel.

5. Liability

Inasmuch as the Company may be held liable for the participation of Employees and Agents of the Company and other parties associated with it in corrupt activities, for each justified suspicion or established instance of corruption, internal investigations will be undertaken in accordance with the Company's rules establishing the procedure for carrying out such an investigation in a context permitted by applicable legislation.

Parties guilty of breaching this Policy and of Applicable Anti-Corruption Laws may face disciplinary, administrative, civil law or criminal liability at the initiative of the Company, the law enforcement authorities, or other entities in the procedure and on the grounds specified by the Company's Charter, internal procedures, and also in the appropriate cases and given sufficient grounds, in accordance with Applicable Anti-Corruption Laws and other applicable laws and regulations.

6. Appendix

May indicate a violation of anti-bribery matters

1. Suspicious invoices, receipts and payments.

Payment to government, government officials, political parties or state-owned enterprises
Abnormal payment to the customer or supplier (for example, additional or separate fees)
License fee
Abnormal name or proxy (for example, 'old friend', 'Mr.Paris', etc.)
Unusually complex transaction structure or payment process

2. Suspicious payment to an individual

3. Suspicious travel and entertainment expenses, gifts, charitable donations or other similar expenses.

The lack of transparency in the accounting records
Unusually high cost
Travel unrelated to the business (eg Las Vegas, Paris, Dubai, Monaco, Disney World, Swiss Alps)
Luxury hotel or tour, expensive tournament tickets, or sightseeing fees

4. Suspiciously use distributors or sales agents to sell goods, or use service providers such as consultants, agents, intermediaries, intermediaries, or professional companies or individuals (including public relations, lobbying, law, and accounting)

a. Abnormal payment terms or financial arrangements, such as:

Advance payment
Payment to a bank account with a different name
Payment to the account of the country where the business is located or outside the place where the service is performed
Agreement to pay 'success fee'
Payment by a person or place (one consultant, but paying two separate payments to different names or locations)
Any large cash payment

b. Unusually high or suspicious commissions, consulting fees, expense reimbursement or other payments

c. Countries with a history of corruption

d. Invoices including other personnel expenses, inflated invoices, additional commissions or bonuses, or unusual rebates

e. Employees express concerns and request excessive confidentiality (for example, our employees are told 'Don't ask')

f. The third party does not appear to be a legitimate company (for example, there are not enough employees to perform the agreed work or no actual office location)

5. Suddenly obtain a license or other government approval after a long delay

6. Off-book accounts or 'bribery funds'

7. Recently hired government or state-owned enterprise officials or relatives

Training or internship
Pay the bonus after the employment
Any other welfare or convenience