隐私条款 (Privacy Policy)

neumee Privacy Policy

Last Updated: [May 12, 2026]

Effective Date: [May 12, 2026]

I. Introduction

neumee (hereinafter referred to as “we”, “us”, or “neumee”) understands the importance of personal information to you. We are committed to protecting the security of your personal information and strictly comply with the

Personal Information Protection Law of the People's Republic of China

, the

Cybersecurity Law of the People's Republic of China

, the

Data Security Law of the People's Republic of China

, the

Network Data Security Management Regulations

, and other laws and regulations as well as relevant national standards (such as GB/T 35273-2020

Information Security Technology—Personal Information Security Specification

). On this basis, we have formulated this

neumee Privacy Policy

(hereinafter referred to as “this Policy”).

This Policy is intended to explain to you how, when you visit and use the official neumee website ([

www.neumee.cn

]), mobile applications, WeChat mini-programs (collectively referred to as the “neumee online platforms”) and purchase goods or use our services at neumee offline stores in mainland China (if any), we collect, use, store, transmit, publicly disclose, and protect your personal information, as well as the rights you have in relation to your personal information.

Before using neumee's products or services, please carefully read and fully understand this Policy, especially the clauses marked in bold/bold underline. If you have any questions, comments, or suggestions regarding this Policy, you may contact us through the contact details listed in Section XI of this Policy.

By checking “Agree” or otherwise confirming this Policy, you indicate that you have fully read, understood, and agreed to all terms of this Policy. If you do not agree with any content of this Policy, please do not use our products or services.

II. How We Collect and Use Your Personal Information

Personal information refers to various information recorded electronically or by other means that is related to an identified or identifiable natural person, excluding information after anonymization.

We collect and use personal information only for the purposes stated in this Policy, follow the principles of lawfulness, legitimacy, necessity, and good faith, and collect only the minimum information necessary to realize the relevant functions or services when you use such functions or services.

(I) Information You Directly Provide to Us

1. Registration and Account Management Information

When you create a neumee account, we need to collect your mobile phone number, email address, and the account password you set yourself. You may also choose to provide additional information such as your nickname, avatar, gender, date of birth, height, weight, clothing/shoe size, and sports preferences (such as yoga, running, fitness, etc.), so that we can provide you with more personalized product recommendations and service experience.

2. Purchase and Transaction Information

When you purchase goods through the neumee online platforms or offline stores, we will collect transaction information such as your name, mobile phone number, delivery address, email address, payment information (including payment card number, payment method, etc.), details of purchased goods, order amount, and order date. The payment process is handled by third-party payment service providers (such as Alipay, WeChat Pay, etc.), and we do not directly store your full payment card number information.

3. Customer Service and Communication Information

When you contact our customer service team (including by telephone, online customer service, email, and other channels), we will collect the contact details, inquiry content, order information, after-sales requirements, and communication records between you and us that you proactively provide, in order to provide you with timely customer support.

4. Subscription and Marketing Information

When you subscribe to neumee newsletters, event notifications, or marketing information, we will collect your email address and/or mobile phone number in order to send you brand information, new product launch information, and personalized recommendations.

5. Offline Store Interaction Information

If you visit neumee offline stores in mainland China, we may collect records of your try-on and trial use in stores, information about your participation in experiential classes (such as yoga classes, fitness activities), and the content of your interactions with store staff, in order to enhance your shopping experience.

(II) Information We Automatically Collect

When you visit the neumee online platforms, we may automatically collect the following information through Cookies, web beacons, and similar tracking technologies:

• Device and network information

: including your device model, operating system version, unique device identifier, IP address, browser type, language settings, screen resolution, mobile carrier information, etc.

• Usage behavior information

: including the date and time of your page visits, browsing and search records, page dwell time, click and swipe behavior, shopping cart operation records, page navigation paths, etc.

The above automatically collected information is intended to help us understand how you use the neumee online platforms, optimize website functions and user experience, and be used for analytics and marketing purposes.

(III) Information We Obtain from Third Parties

We may obtain information related to you from the following third-party channels:

• Third-party platforms

: When you log in to the neumee online platforms through third-party social platform accounts such as WeChat, Alipay, Weibo, and Xiaohongshu, we will, after obtaining your authorization, obtain public information such as your platform nickname and avatar.

• Service providers

: Our payment service providers, logistics service providers, data analytics service providers, etc. may provide necessary transaction status and logistics information back to us.

(IV) Purposes of Using Personal Information

We use the personal information collected for the following purposes:

1. Providing products and services

: completing your orders, arranging shipment and logistics delivery, handling returns, exchanges, and refunds, and providing after-sales services and customer support.

1. Account management

: creating and managing your neumee account and maintaining your membership information and points/benefits records.

1. Service notifications

: sending you service-related messages concerning orders, accounts, logistics, and after-sales services.

1. Marketing and promotion

: after obtaining your consent, sending you brand information, promotional activities, new product recommendations, and other marketing information (you may unsubscribe at any time).

1. Experience optimization

: analyzing your browsing and purchasing behavior, understanding your interests and preferences, optimizing online platform functions and product displays, and providing personalized recommendations.

1. Security assurance

: detecting and preventing fraud, abuse, and security risks, and protecting the lawful rights and interests of you and neumee.

1. Compliance and legal obligations

: complying with legal and regulatory requirements, including tax compliance, anti-money laundering, and cooperation with regulatory authorities.

If we intend to use your personal information for other purposes not stated in this Policy, or beyond the scope necessary to achieve the original purposes, we will obtain your separate consent.

III. How We Use Cookies and Similar Technologies

The neumee online platforms use Cookies, web beacons, pixel tags, device identifiers, and similar tracking technologies to ensure the normal operation of the website, optimize service experience, and provide personalized content. Cookies are small text files stored on your device when you visit a website. They can record your preferences, shopping cart status, and browsing behavior, and help us identify your browser when you visit again.

The Cookies we use mainly include the following types:

1. Necessary Cookies

: used to ensure the normal operation of basic website functions, such as page navigation, access to secure areas, and shopping cart functions. They cannot be disabled.

1. Preference Cookies

: used to record your personalized options such as language preferences and regional settings to enhance your experience.

1. Statistical and Analytical Cookies

: used to help us understand how users interact with the website, such as the most visited pages and user source channels, so as to optimize website design and services.

1. Marketing Cookies

: used to track your browsing behavior across different websites so as to display more relevant neumee advertising content to you.

You may manage or disable Cookies through your browser settings. However, please note that disabling certain necessary Cookies may affect your normal use of some functions of our website.

IV. How We Entrust Processing, Share, Transfer, and Publicly Disclose Your Personal Information

(I) Entrusted Processing

We may entrust partners (such as logistics service providers, payment service providers, SMS/email delivery service providers, data analytics service providers, etc.) to process your personal information in order to achieve the processing purposes described in Section II of this Policy. We will sign strict confidentiality agreements with entrusted parties, requiring them to process personal information only according to our instructions, the purposes and periods agreed in this Policy, and to take appropriate security protection measures.

(II) Sharing

We will share your personal information with third parties only in the following circumstances:

1. Obtaining your separate consent

: Where laws and regulations require separate consent, we will obtain your explicit consent after informing you of the name or title and contact details of the recipient, the processing purpose, processing method, and types of personal information.

1. Sharing with affiliates

: For business operation needs, we may share your personal information with neumee's parent company and affiliates (including Neume LLC and its affiliates) for purposes such as unified customer service and data analytics. We will ensure that affiliates comply with personal information protection standards of an equivalent level.

1. Sharing with service providers

: We will share information with necessary business partners to realize service functions, including logistics and delivery service providers, payment service providers, information technology service providers (such as cloud hosting and customer support platforms), marketing service providers, anti-fraud service providers, etc.

1. Legal and regulatory requirements

: We may lawfully provide your personal information in accordance with laws and regulations, government regulatory requirements, or judicial rulings.

(III) Transfer

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

1. We obtain your explicit consent;
2. In circumstances such as asset acquisition, restructuring, merger, division, or bankruptcy liquidation, if personal information transfer is involved, we will inform you of the name or title and contact details of the recipient and require the recipient to continue to perform the obligations under this Policy. If the recipient changes the original processing purpose or processing method, we will obtain your consent again.

(IV) Public Disclosure

We will not publicly disclose your personal information unless we obtain your separate consent or laws and regulations provide otherwise.

Please note that the neumee online platforms may contain links to third-party websites or services (such as social media platforms). These third-party websites have their own independent privacy policies, and we assume no responsibility for their privacy protection practices. We recommend that you carefully read their privacy policies before providing personal information to such third parties.

V. Storage and Cross-Border Transfer of Personal Information

(I) Storage Location

Personal information collected and generated by us within the People's Republic of China will be stored within the People's Republic of China.

(II) Cross-Border Transfer

Given that neumee's brand division is located in the United States (Neume LLC), for purposes such as providing customer service, order management, and system maintenance, some of your personal information may need to be transferred from mainland China to neumee affiliates or service providers in the United States or other countries/regions for processing. When conducting such cross-border transfer, we will strictly comply with the

Personal Information Protection Law of the People's Republic of China

and relevant national data export security management regulations, and adopt one or more of the following measures to protect the security of your personal information:

1. Pass a data export security assessment in accordance with the regulations of the Cyberspace Administration of China;
2. Sign a standard contract for cross-border transfer of personal information that complies with national standards (such as GB/T 44588-2024) with the overseas recipient, specifying the rights and obligations of both parties;
3. Other security safeguard measures that comply with laws and regulations.

Before cross-border transfer occurs, we will lawfully inform you of the name or title and contact details of the overseas recipient, the processing purpose, processing method, types of personal information, and the methods and procedures for you to exercise rights with the overseas recipient, and obtain your separate consent.

(III) Retention Period

We will retain your personal information only for the period necessary for the purposes described in this Policy and the minimum period required by laws, regulations, and regulatory requirements. After the necessary period expires, we will delete or anonymize your personal information, unless laws and regulations provide otherwise.

• Account information

: retained during the existence of your account.

• Order and transaction information

: retained for at least three years after the completion of the transaction in accordance with the

E-commerce Law of the People's Republic of China

and other relevant laws.

• Marketing preference information

: retained until you unsubscribe.

• Website browsing logs and automatically collected information

: generally retained for no more than twelve months.

VI. Your Rights Regarding Personal Information

In accordance with the

Personal Information Protection Law of the People's Republic of China

and other laws and regulations, you enjoy the following personal information rights. You may exercise these rights through the contact details in Section XI of this Policy, and we will respond within fifteen (15) working days after receiving your request:

1. Right to access and copy

: You have the right to access your personal information on our platforms and request a copy.

1. Right to correct and supplement

: When you find that the personal information we process is inaccurate or incomplete, you have the right to request us to correct or supplement it.

1. Right to deletion

: You have the right to request us to delete your personal information in the following circumstances:

(1) The processing purpose has been achieved, cannot be achieved, or is no longer necessary for achieving the processing purpose;

(2) We stop providing products or services, or the retention period has expired;

(3) You withdraw your consent;

(4) We process your personal information in violation of laws and regulations or our agreement with you;

(5) Other circumstances provided by laws and regulations.

1. Right to withdraw consent

: For personal information processing activities carried out based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the validity of personal information processing activities already carried out based on consent before the withdrawal. We provide convenient methods for withdrawing consent, including but not limited to:

• Marketing emails

: click the “Unsubscribe” link at the bottom of each marketing email;

• Marketing SMS

: reply “TD” to unsubscribe;

• Personalized recommendations

: turn off the relevant option in account settings.

1. Right to cancel account

: You have the right to cancel your account on the neumee online platforms. After account cancellation, we will delete or anonymize your personal information in accordance with legal requirements, but information on completed orders may continue to be retained within the statutory retention period.

1. Right to data portability

: Where statutory conditions are met, you have the right to request that your personal information be transferred to another personal information processor designated by you.

1. Right to restrict processing and right to object

: Under the circumstances provided by laws and regulations, you have the right to request us to restrict or object to our processing of your personal information.

To protect information security, before responding to your request, we may need to verify your identity. We may refuse requests that are unfoundedly repetitive, require excessive technical means (such as developing a new system or fundamentally changing current practices), pose risks to the lawful rights and interests of others, or are highly impractical.

VII. Protection of Minors' Information

neumee's products and services are intended for adults with full civil capacity. We do not proactively collect personal information from minors under eighteen (18) years of age.

If you are a child under fourteen (14) years of age, your parents or guardians need to agree to the terms of this Policy on your behalf. If you are a parent or guardian and believe that your child has provided personal information to us without your consent, please contact us through the contact details in Section XI of this Policy, and we will promptly delete the relevant personal information.

We do not intentionally collect personal information from children under fourteen (14) years of age. Once we discover that we have collected a child's personal information without the consent of the parents or guardian, we will immediately delete it.

VIII. Personal Information Security Protection Measures

We attach great importance to the security of your personal information and have adopted management and technical measures that meet industry standards to protect your personal information from unauthorized access, public disclosure, use, modification, damage, or loss. Our security measures include but are not limited to:

• Data encryption

: SSL/TLS and other encryption protocols are used at the transmission layer, and sensitive information is encrypted at the storage layer.

• Access control

: A strict internal data access authorization mechanism is established. Only authorized employees can access personal information, and the scope of access is limited according to the principle of least necessity.

• Security audit

: Regular system security vulnerability scanning and risk assessments are conducted to promptly fix potential risks.

• Employee training

: Regular personal information protection and security compliance training is provided to employees to strengthen security awareness.

• Emergency response

: A personal information security incident emergency response plan is formulated to enable timely response and handling when security incidents occur.

If a personal information security incident unfortunately occurs, we will, in accordance with legal and regulatory requirements, promptly inform you by SMS, email, letter, or other means of the basic situation and possible impact of the security incident, the handling measures we have taken or will take, suggestions you can take to prevent and reduce risks on your own, and our contact details. We will also report the incident to the relevant regulatory authorities.

IX. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. In the event of the following material changes, we will notify you through appropriate means (including but not limited to pop-up notifications, in-site messages, SMS, or email):

1. Our service model undergoes material changes, such as changes in the purposes of processing personal information, the types of personal information processed, or the methods of using personal information;
2. Our ownership structure or organizational structure undergoes material changes, such as owner changes caused by business adjustments, bankruptcy, mergers and acquisitions, etc.;
3. The main recipients of personal information sharing, transfer, or public disclosure change;
4. Your rights in relation to personal information processing and the methods of exercising them undergo material changes;
5. The responsible department, contact details, or complaint channel for personal information security changes;
6. The personal information security impact assessment report indicates high risks.

We will also archive previous versions of this Policy for your reference.

X. Governing Law and Dispute Resolution

The conclusion, effectiveness, interpretation, performance, modification, and dispute resolution of this Privacy Policy shall be governed by the laws of the People's Republic of China (for the purposes of this Policy only, excluding the laws of the Hong Kong Special Administrative Region, the Macao Special Administrative Region, and the Taiwan region).

Any dispute arising from or related to this Policy shall first be resolved through friendly negotiation between the parties. If negotiation fails, you agree to submit the dispute to the people's court with jurisdiction in Shanghai for litigation.

XI. How to Contact Us

If you have any questions, comments, or suggestions regarding this Privacy Policy, or wish to exercise the personal information rights described in Section VI of this Policy, please contact us through the following methods:

Personal Information Processor

: Shanghai Neumee Fitness Equipment Co., Ltd.

Contact Address

: 6G, Oriental Financial Park, Lane 2981, Dongfang Road, Pudong New Area, Shanghai

Personal Information Protection Officer / Contact Email

: Operation@topko.com

Customer Service Telephone

: 400-111-8126

We will reply within fifteen (15) working days after receiving your request.

If you are dissatisfied with our reply, or believe that our personal information processing activities have infringed upon your lawful rights and interests, you may complain or report to the relevant regulatory authorities performing personal information protection duties, or file a lawsuit with the competent people's court in accordance with the law.

XII. Historical Versions

• V1.0, Effective Date: May 12, 2026

Issuing Entity

: Shanghai Neumee Fitness Equipment Co., Ltd.

Release Date

: May 12, 2026