Privacy Policy

Effective Date: January 1, 2024 — Last Updated: June 24, 2026

1. Introduction and Scope

This Privacy Policy describes how Zunyi Xiaobo Network Technology Co., Ltd., doing business as Dawn Wise (dawnwise.autos), collects, uses, stores, shares, and protects your personal information when you visit our website, communicate with us, or use our services (collectively, the Services).

We are committed to protecting your privacy and handling your data in an open and transparent manner. This policy explains your rights and how you can exercise them. By using our Services, you acknowledge that you have read and understood this Privacy Policy.

This policy applies to all individuals who interact with our Services, including visitors to our website, prospective clients, current clients, and job applicants. If you do not agree with this policy, please do not use our Services.

2. Definitions

For the purposes of this Privacy Policy:

• Personal Data (or Personal Information) means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
• Processing means any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• Data Controller means the natural or legal person that determines the purposes and means of the processing of personal data. For the purposes of this Privacy Policy, Zunyi Xiaobo Network Technology Co., Ltd. is the Data Controller.
• Data Processor means a natural or legal person that processes personal data on behalf of the Data Controller.
• Services means the website located at dawnwise.autos, any subdomains, and all related services provided by Zunyi Xiaobo Network Technology Co., Ltd.
• Cookies means small text files stored on your device by a web browser when you visit a website.

3. Information We Collect

We collect the following categories of information:

3.1 Information You Provide Directly

• Contact Information: When you fill out our contact form, send us an email, or call us, we collect your full name, email address, phone number, company name, job title, and any other information you choose to include in your message.
• Project Information: Details about your organization, technical requirements, system specifications, project timelines, and business goals that you share during consultation discussions.
• Account Information: If we establish a client portal or account for you, we collect login credentials, preferences, and communication settings.
• Payment Information: For invoicing and payment purposes, we collect billing addresses, bank account details, or payment card information. Payment card data is processed solely by our third-party payment processors and is not stored on our systems.
• Communications: Records of correspondence, including emails, contact form submissions, meeting notes, phone call summaries, and support tickets.

3.2 Information Collected Automatically

• Log Data: When you visit our website, our servers automatically record information that your browser sends. This includes your Internet Protocol (IP) address, browser type and version, browser language, the date and time of your request, the pages you visit, the time spent on those pages, and referring and exit URLs.
• Device Information: Device type, operating system, screen resolution, and unique device identifiers.
• Usage Data: Information about how you interact with our website, including click patterns, scroll depth, mouse movements, and form interaction data.
• Performance Data: Page load times, error logs, and diagnostic information used to maintain and improve our website.
• Geolocation Data: Approximate location derived from your IP address, such as city, region, and country.

3.3 Information from Third Parties

• Analytics Providers: We use third-party analytics services that provide aggregated data about website traffic and usage patterns.
• Business Partners: Referral sources and business partners may share contact information with your consent.
• Publicly Available Sources: Business contact information from public directories, corporate websites, and professional networking platforms, where legally permissible.

4. How We Collect Information

We collect information through the following methods:

1. Direct Interactions: When you fill out forms on our website, send emails to any @dawnwise.autos address, call our phone number, attend meetings or video conferences with our team, or otherwise communicate with us directly about our services.
2. Automated Technologies: Through cookies, web beacons, server logs, and similar technologies when you browse our website. For more details, see Section 8 (Cookies and Tracking Technologies).
3. Third-Party Sources: From analytics providers, business partners, and publicly available business directories.
4. Client Engagement: During the course of providing consulting, design, and network services, we may receive technical data about your systems, with your explicit authorization.

5. How We Use Your Information

We use the information we collect for the following purposes:

1. Service Delivery: To provide, maintain, and improve our computer systems design, network infrastructure, digital transformation, and technology consulting services.
2. Communication: To respond to your inquiries, provide quotes and proposals, send service-related announcements, and communicate about your projects.
3. Client Relationship Management: To manage our client relationships, maintain records of engagements, and deliver project updates and reports.
4. Billing and Administration: To process payments, issue invoices, manage accounts, and fulfill our contractual obligations.
5. Website Improvement: To analyze website usage, diagnose technical problems, optimize performance, and improve user experience.
6. Marketing (with Consent): To send newsletters, service updates, industry insights, and promotional materials where you have explicitly opted in. You may unsubscribe at any time.
7. Legal Compliance: To comply with applicable laws, regulations, legal processes, and government requests; to enforce our Terms of Service; and to protect the rights, property, and safety of Zunyi Xiaobo Network Technology Co., Ltd., our clients, and the public.
8. Security: To detect, prevent, and address fraud, unauthorized access, and other illegal or harmful activity.
9. Business Operations: For internal purposes such as auditing, data analysis, business planning, and research to improve our services.

We will not use your personal information for purposes other than those described in this policy without providing notice and, where required by law, obtaining your consent.

6. Legal Basis for Processing

We process personal data under the following legal bases, as applicable depending on your jurisdiction:

• Consent: You have given clear consent for us to process your personal data for a specific purpose (e.g., receiving marketing communications).
• Contractual Necessity: Processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract (e.g., providing a service quote).
• Legitimate Interests: Processing is necessary for our legitimate interests or those of a third party, provided your rights and interests do not override those interests. This includes improving our services, securing our systems, and conducting business analytics.
• Legal Obligation: Processing is necessary to comply with applicable laws, regulations, court orders, or government requests.
• Vital Interests: Processing is necessary to protect someone's life.

7. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties. We may share your information only in the following circumstances:

1. Service Providers: We engage trusted third-party companies and individuals to perform services on our behalf, including website hosting, analytics, email delivery, payment processing, and IT infrastructure management. These providers have access only to the personal data necessary to perform their functions and are contractually obligated to protect it.
2. Professional Advisors: We may share information with our legal counsel, accountants, auditors, and insurers where necessary for the provision of their professional services.
3. Business Transfers: In connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred as a business asset. You will be notified of any change in ownership or control of your personal data.
4. Legal Requirements: We may disclose information when required by law, regulation, subpoena, court order, or governmental request, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
5. With Your Consent: We may share your information for any other purpose with your explicit consent.

8. Cookies and Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They are widely used to make websites work efficiently, to remember your preferences, and to provide information to the website operators. Cookies may be session-based (deleted when you close your browser) or persistent (remaining on your device for a set period or until you delete them).

8.2 Types of Cookies We Use

• Essential Cookies: These cookies are necessary for the website to function properly. They enable core functionality such as page navigation, security, and access to secure areas. The website cannot function properly without these cookies, and they can only be disabled by changing your browser settings.
• Performance and Analytics Cookies: These cookies collect information about how visitors use our website, such as which pages are visited most often and whether visitors encounter error messages. The information collected is aggregated and anonymous. We use this data to improve how our website works.
• Functional Cookies: These cookies allow the website to remember choices you make (such as your language preference or contact form inputs) and provide enhanced, more personalized features.
• Security Cookies: These cookies help us detect and prevent security threats, unauthorized access, and malicious activity.

8.3 Third-Party Cookies

Some cookies may be placed by third-party services that appear on our pages. These third parties may include analytics providers and hosting platforms. We do not control these third-party cookies, and we recommend reviewing the privacy policies of the relevant third parties.

8.4 Managing Cookies

Most web browsers allow you to control cookies through their settings preferences. You can typically configure your browser to refuse all cookies, to accept only certain types of cookies, or to notify you when a cookie is being set. Please note that disabling essential cookies may affect the functionality of our website. To learn more about managing cookies, visit the help pages for your browser:

• Google Chrome: Settings > Privacy and Security > Cookies and Other Site Data
• Mozilla Firefox: Options > Privacy & Security > Cookies and Site Data
• Apple Safari: Preferences > Privacy > Cookies and Website Data
• Microsoft Edge: Settings > Cookies and Site Permissions

8.5 Web Beacons and Similar Technologies

We may also use web beacons (also known as clear GIFs, pixel tags, or tracking pixels). These are tiny graphics with a unique identifier embedded in web pages and emails that allow us to count users who have visited specific pages or opened an email, and to collect other related website statistics.

9. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our retention periods are determined by the following criteria:

• Contractual Obligations: For the duration of our engagement with you and for a reasonable period thereafter to address any post-engagement matters.
• Legal Requirements: Where laws, regulations, or government orders require us to retain records for a specified period (e.g., tax records, business registration documents).
• Business Records: Correspondence, project files, and client records may be retained for up to seven (7) years after the conclusion of our business relationship for legitimate business purposes, including potential legal claims.
• Website Analytics: Aggregated and anonymized analytics data may be retained indefinitely for trend analysis and business planning.
• Marketing Data: Contact information used for marketing purposes is retained until you withdraw consent or unsubscribe.

When personal data is no longer required, we securely delete, destroy, or anonymize it in accordance with our data disposal procedures.

10. Data Security

We implement and maintain appropriate technical, administrative, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include, but are not limited to:

• Encryption: Data transmitted between your browser and our servers is encrypted using Transport Layer Security (TLS). Data at rest is encrypted using industry-standard encryption algorithms.
• Access Controls: Access to personal data is restricted to authorized personnel who require it to perform their job duties. Access is governed by role-based permissions and least-privilege principles.
• Authentication: Multi-factor authentication is required for administrative access to our systems.
• Monitoring: We maintain audit logs and employ intrusion detection systems to monitor for suspicious activity.
• Physical Security: Our infrastructure is hosted in facilities with 24/7 physical security, surveillance, and controlled access.
• Incident Response: We maintain a documented incident response plan. In the event of a data breach, we will notify affected individuals and relevant authorities as required by applicable law.
• Vendor Management: We conduct due diligence on all third-party service providers to ensure they maintain equivalent security standards.

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data. We encourage you to take steps to protect your own information, including using strong passwords and keeping your software up to date.

11. International Data Transfers

Zunyi Xiaobo Network Technology Co., Ltd. is based in the People's Republic of China. The personal data we collect may be transferred to, stored in, and processed from servers located in China and, where necessary for service delivery, in other countries where our service providers operate.

When we transfer personal data across borders, we take appropriate measures to ensure that the data receives an adequate level of protection, in compliance with applicable data protection laws. These measures may include:

• Transferring data only to countries that have been recognized as providing an adequate level of data protection;
• Entering into standard contractual clauses approved by relevant regulatory authorities;
• Ensuring that recipients have implemented binding corporate rules or equivalent safeguards;
• Obtaining your explicit consent for the transfer where required by law.

By using our Services, you acknowledge that your personal data may be transferred to and processed in countries outside your country of residence, which may have different data protection rules than your country.

12. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal data. We will respond to your requests in accordance with applicable law:

12.1 Right of Access

You have the right to request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format upon request.

12.2 Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal data we hold about you. We will make corrections without undue delay.

12.3 Right to Erasure (Right to Be Forgotten)

You have the right to request the deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when processing is unlawful. This right is not absolute and may be limited by our legal obligations and legitimate business interests.

12.4 Right to Restrict Processing

You have the right to request that we limit the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing.

12.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller without hindrance.

12.6 Right to Object

You have the right to object to the processing of your personal data in certain circumstances, including processing for direct marketing purposes. We will cease processing your data for direct marketing upon receipt of your objection.

12.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

12.8 Automated Decision-Making

We do not engage in automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you. If this changes, we will update this policy and provide you with information about the logic involved, as well as the significance and envisaged consequences of such processing.

12.9 Exercising Your Rights

To exercise any of these rights, please contact us using the details in Section 17 (Contact Us). We will verify your identity before processing your request and may ask for additional information to confirm your identity. We will respond to your request within the time period required by applicable law, typically within thirty (30) days. If we need more time, we will inform you of the extension period and the reasons for the delay.

If you believe that our processing of your personal data violates applicable law, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

13. Children's Privacy

Our Services are not directed to individuals under the age of eighteen (18). We do not knowingly collect, use, or disclose personal information from anyone under eighteen (18) years of age without prior parental or guardian consent. If we become aware that we have collected personal data from a child under the age of eighteen (18) without verified parental consent, we will take immediate steps to delete that information. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately using the details in Section 17 (Contact Us).

14. Third-Party Links

Our website may contain links to third-party websites, plug-ins, and applications. Clicking those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. When you leave our website, we encourage you to read the privacy policy of every website you visit. This Privacy Policy applies solely to information collected by Zunyi Xiaobo Network Technology Co., Ltd. through our Services.

15. Do Not Track Signals

Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits collected across websites. Our website currently does not respond to DNT signals. We may revisit this as industry standards evolve. For more information about DNT, visit allaboutdnt.com.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal obligations, or for other operational reasons. When we update this policy, we will:

• Revise the Last Updated date at the top of this page;
• Post the updated policy on this page;
• Notify you by email if we have your email address and the changes are material;
• Provide a prominent notice on our website for material changes.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of our Services after any changes to this policy constitutes your acceptance of the updated terms.

17. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, or if you wish to exercise any of your data protection rights, please contact us using the information below.

We will acknowledge receipt of your inquiry within five (5) business days and aim to resolve your concern within thirty (30) days.