Privacy Policy

Page 1 | Introduction and Scope of Application

This Privacy Policy aims to clearly explain to users the principles, methods, and protection mechanisms that ROI follows when processing personal data and related information. ROI understands the importance of privacy and data security to users and therefore commits to managing all data in a prudent, transparent, and responsible manner during business operations, system management, and service provision. This policy applies to users of the ROI website, platform tools, digital services, portfolio management functions, and cattle ranchers, farm owners, member institutions, and related users who cooperate with ROI.

By accessing, browsing, or continuing to use any of ROI’s services, users are deemed to have read, understood, and agreed to the contents of this Privacy Policy. ROI reserves the right to revise this policy in accordance with legal requirements, business changes, or system updates, and will continue to ensure the security and legal use of user information after updates. If users do not agree to the updated content, they may choose to stop using the service; continued use constitutes acceptance of the revised policy. This policy aims to establish clear, predictable, and reliable data processing standards for all users.

Page 2 | Types of Data We Collect

To ensure smooth, secure, and personalized service, ROI collects various types of user data in a legal, necessary, and transparent manner. First, when users create an account or participate in a project, they may need to provide basic information such as name, gender, and age range to establish identity and service profiles. Second, to manage user accounts and permissions, the system may record identification information such as account ID, login credentials, and permission levels to ensure operational security.

When users browse platform content or use functions, the system automatically collects browsing history, click paths, preference settings, and interaction logs to help optimize the service experience, improve interface performance, and enhance functional stability. In addition, data such as IP location, operating system type, browser version, and device model generated by user devices are also used as part of system security monitoring and performance analysis.

ROI also uses cookies and other tracking technologies to store preferences, maintain login status, and analyze usage trends. Some data may come from organizations or companies that legally cooperate with ROI and is processed strictly in accordance with agreed purposes to ensure transparency, security, and compliance.

Page 3 | Data Usage

ROI will use the collected data in accordance with the principles of legality, legitimacy, and transparency, aiming to provide users with a more comprehensive and secure service experience. Firstly, user data will be used for account management, identity verification, permission settings, and to assist users in communicating and collaborating with partners, making service processes smoother. The platform will also push relevant market information, industry trends, and project updates to users based on their preferences and needs to improve information acquisition efficiency.

To continuously improve the user experience, ROI will use system operation records and user interaction data for function optimization, interface adjustments, and performance improvements, ensuring the platform remains stable, fast, and easy to operate. Simultaneously, some data will be used in the risk control module, including risk monitoring, abnormal behavior verification, and fraud detection, to ensure the safety and asset protection of all members.

Within the scope of user permission, data may be used for appropriate marketing promotion and event notifications, primarily containing industry-related information. ROI will also use the data for statistical analysis to generate industry insights, behavioral trend analysis, and business evaluation. If required by laws and regulations, ROI will cooperate with relevant agencies to perform necessary data processing in accordance with regulations.

Page 4 | Legal Basis for Data Processing

ROI will strictly adhere to legally recognized processing principles when processing user personal data. First, ROI will only initiate relevant data processing procedures with the user’s explicit consent, such as by checking the consent option, continuing to use the service, or authorizing specific functions. Second, if data use is related to providing specific services, fulfilling agreements between the parties, or completing user applications, it is considered necessary for contract performance and can serve as the basis for processing.

In some cases, ROI is required to comply with relevant legal obligations, such as cooperating with regulatory reviews, maintaining records, or responding to regulatory requirements; such processing falls within the scope of compliance obligations. Furthermore, ROI may process data based on legitimate interests, such as improving system security, preventing fraud, optimizing service experience, or developing new features, but all processing will be conducted without infringing on user rights.

ROI consistently adheres to the principle of transparent data processing and will clearly explain the purpose, scope, and method of data use. Users also have the right to withdraw their consent. Upon withdrawal, ROI will cease processing activities based on that consent, but this will not affect previously completed legal processing.

Page 5 | Data Storage and Retention Period

ROI employs stringent security measures when processing and storing user data to ensure its full protection throughout its lifecycle. All data is encrypted and uses a tiered storage structure to restrict access permissions at different levels, ensuring only authorized personnel can read the relevant information. Furthermore, the platform utilizes access control mechanisms and operation audit logs to mitigate the risk of unauthorized access.

Regarding data retention periods, ROI will retain user data for a certain period based on the nature of the service, business needs, or relevant regulatory requirements. When data is no longer necessary to retain, or when a user submits a legitimate deletion request, the system will initiate a deletion process, including data erasure, anonymization, or automatic expiration deletion mechanisms, to ensure that data is not stored indefinitely.

Simultaneously, ROI establishes backup systems and disaster recovery mechanisms to ensure timely data recovery and reduce the risk of data loss in the event of system anomalies, technical failures, or unforeseen incidents. ROI consistently adheres to the principle of data minimization, collecting and storing only the necessary information required to provide the service.

Page 6 | Data Sharing and Third-Party Disclosure

ROI adheres to principles of caution and compliance in data sharing, only sharing certain information with legitimate and directly business-related partners to the necessary extent, such as operations support providers, system service providers, security review agencies, or commissioned professional teams. The primary purposes of sharing include service delivery, system operation processing, risk control analysis, and functional improvement, to ensure stable platform operation and provide a high-quality experience.

ROI will not sell users’ personal information, nor will it engage in any sharing activities inconsistent with its privacy policy. All third parties involved in processing data must comply with the same privacy protection standards as ROI and sign relevant compliance documents to ensure that data remains secure, transparent, and regulated when processed externally.

In certain circumstances, ROI may need to disclose data to the necessary extent based on legal requirements, regulatory reviews, or the protection of user safety, such as when required by suspected illegal activities, risk events, or legal proceedings. All disclosures will strictly adhere to the principles of legality and minimization, ensuring they do not exceed reasonable limits.

Page 7 | User Rights

ROI respects and protects all users’ rights regarding the protection of their personal data. Users have the right to access their data held by ROI, including basic information, account records, and related processing information, to ensure they have a full understanding of their personal data. If the data is found to be inaccurate, incomplete, or expired, users can request corrections, and ROI will assist in updating it within a reasonable timeframe.

Subject to applicable laws and service procedures, users may also apply to delete part or all of their personal data, such as when the data is no longer necessary to retain or when the user withdraws their consent. Furthermore, users may request restrictions on certain data processing activities to prevent the continued use of their data in specific situations.

Users also have the right to data portability and can request structured, commonly formatted copies of their data within reasonable limits. If users object to certain processing actions based on legitimate interests, they can also file an objection. ROI is committed to adhering to the principle of non-discrimination, and users exercising the above rights will not be subject to discriminatory treatment or unfair service.

Page 8 | Data Security Protection Measures

ROI considers data security a core responsibility and has adopted multiple technical and management measures to ensure that user data is protected to the greatest extent possible during storage, transmission, and processing. At the technical level, the platform employs encryption, anonymization, multi-layered authentication mechanisms, and secure communication protocols to prevent data theft or tampering during transmission or access. Simultaneously, the system conducts continuous risk monitoring, utilizing algorithms and security modules to detect abnormal behavior and promptly prevent potential risks.

At the management level, ROI implements strict access control policies, allowing only authorized personnel to access necessary data and maintaining operation logs to track critical operations. Employees receive privacy protection and data security training to ensure internal personnel fully understand their responsibilities.

ROI also establishes multiple mechanisms to prevent unauthorized access, including authentication, firewalls, and behavioral detection systems. In the event of a potential data breach or data leak, ROI will initiate a dedicated data breach response process to quickly mitigate the impact, protect user rights, and comply with relevant regulatory requirements.

Page 9 | Cookies and Tracking Technologies

To enhance user experience and system efficiency, ROI uses various cookies and related tracking technologies on its platform. Necessary cookies are used to maintain the basic functions of the website or platform, such as login status, page loading, and security verification; they are an indispensable part of system operation. Analytical cookies are used to track website traffic, browsing behavior, and interaction patterns to help optimize interface and functionality. Functional cookies record user preferences, allowing the platform to provide a more tailored experience upon repeat visits.

Some third-party service providers may use independent tracking technologies, such as traffic analysis tools or security monitoring modules, but all technologies will operate legally, transparently, and with authorization, and will not exceed their intended purpose.

Users can manage their cookie settings in their browser or device, including refusing, deleting, or restricting certain types of cookies. However, completely disabling cookies may cause some functions (such as personalization settings, automatic login, and data retention) to malfunction, thus affecting the overall user experience. ROI will continue to ensure that all tracking technologies are used safely and reasonably.

Page 10 | Terms Update and User Confirmation

ROI’s privacy policy may be revised from time to time due to changes in regulations, business adjustments, or technological updates. All updates will automatically take effect upon publication and will apply to users’ subsequent access and use of the platform. ROI will ensure that changes to the terms are implemented within a reasonable scope and will continue to adhere to the principles of legality, transparency, and prudence.

By continuing to access or use ROI’s services after the update is released, users agree to and accept the revised terms. If users have questions about the updated content or disagree with the terms, they may choose to discontinue using the relevant services.

To ensure a concise and clear privacy statement, this agreement does not include specific contact information such as address, telephone number, or email address. ROI will inform users of the main changes to the terms through appropriate means to ensure that users are aware of their rights and obligations in a timely manner.

ROI reserves the right to the final interpretation of this privacy policy, which aims to protect user rights, regulate data processing practices, and establish a transparent and trustworthy protection mechanism.