COMPREHENSIVE PRIVACY NOTICE AND DATA PROCESSING AGREEMENT

Last Updated and Effective Date: April 20, 2026

This Comprehensive Privacy Notice and Data Processing Policy (hereinafter referred to as the “Privacy Notice,” “Notice,” or “Policy”) is promulgated by and constitutes a binding legal framework established by 2BILLIONBEATS LIMITED, a private limited liability company duly incorporated and validly existing under the laws of the Hong Kong Special Administrative Region of the People’s Republic of China (hereinafter referred to as the “Company,” “we,” “us,” or “our”).

This Notice governs the ubiquitous collection, transmission, processing, storage, dissemination, and ultimate destruction of personally identifiable information and proprietary data generated, submitted, or otherwise facilitated by you (the “Data Subject,” “User,” or “Customer”) during your utilization of our Database-as-a-Service (DBaaS) infrastructure, proprietary software, application programming interfaces (APIs), and ancillary technological services (collectively, the “Services”).

YOUR AFFIRMATIVE ACT OF REGISTERING FOR AN ACCOUNT, EXECUTING A TRANSACTIONAL AGREEMENT, OR OTHERWISE ACCESSING, BROWSING, OR UTILIZING THE SERVICES CONSTITUTES YOUR UNCONDITIONAL, IRREVOCABLE, AND EXPRESS CONSENT TO THE OBLIGATIONS, PROCEDURES, AND METHODOLOGIES SET FORTH IN THIS PRIVACY NOTICE. IF YOU DO NOT UNEQUIVOCALLY CONSENT TO THE TERMS DELINEATED HEREIN, YOU ARE STRICTLY INSTRUCTED TO IMMEDIATELY CEASE AND DESIST ALL INTERACTION WITH THE SERVICES.

1. DEFINITIONAL FRAMEWORK AND INTERPRETATION

For the explicit purposes of this Privacy Notice, the ensuing terminologies shall possess the specific meanings ascribed to them hereunder:

  • “Personal Data” shall mean any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.
  • “Customer Data” shall mean the disparate arrays of electronic data, database schemas, records, and unstructured information explicitly uploaded, ingested, or stored by the Customer within the partitioned DBaaS environment.
  • “Data Controller” refers to the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the requisite purposes and means of the processing of Personal Data.
  • “Data Processor” refers to a natural or legal person, public authority, agency, or other body which processes Personal Data strictly on behalf of the Data Controller.
  • “PDPO” refers to the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong.

2. DUAL ROLE CAPACITIES AND BIFURCATION OF DATA

You expressly acknowledge and agree that 2BILLIONBEATS LIMITED operates in a bifurcated legal capacity depending on the topological classification of the data in question:

2.1 Capacity as Data Controller. With respect to the Account Information, Billing Information, and Telemetry Data (as defined in Section 3) utilized to manage your subscription, authenticate your identity, and facilitate the commercial relationship, the Company operates strictly as a Data Controller.

2.2 Capacity as Data Processor. With respect to the substantive Customer Data hosted within your instantiated database clusters, the Company operates strictly as a Data Processor. We possess no pedagogical knowledge of, nor do we exercise any dominion or control over, the specific informational contents, regulatory classifications, or legal provenance of the Customer Data you choose to inject into the DBaaS platform.

3. TAXONOMY OF DATA SUBJECT TO COLLECTION

Pursuant to your continuous interaction with the Services, we systematically harvest, aggregate, and log various classifications of data, including without limitation:

3.1 Account and Identity Particulars. Upon registration, we mandate the submission of specific nomenclature and contact heuristics, including your full legal name, valid primary electronic mail address, geographical billing domicile, and associated cryptographic authentication credentials.

3.2 Financial and Transactional Informatics. To facilitate our flat-fee subscription model, we necessitate the processing of financial instruments. Such data includes primary account numbers (PAN), cardholder names, expiration dates, and Card Verification Values (CVV). Notwithstanding the foregoing, you acknowledge that 2BILLIONBEATS LIMITED utilizes PCI-DSS compliant third-party payment gateways, and we do not persistently store raw PAN or CVV data upon our proprietary hardware.

3.3 Diagnostic, Telemetry, and Infrastructural Metadata. We continuously and automatically interdict and record volumetric infrastructural metadata generated by your utilization of the Services. This encompasses, but is absolutely not limited to, Internet Protocol (IP) addresses, user-agent strings, query execution latencies, database connection pooling metrics, Input/Output Operations Per Second (IOPS), computational resource consumption (CPU/RAM telemetry), and time-stamped granular event logs.

3.4 Ephemeral and Persistent Tracking Technologies. The Company deploys complex arrays of HTTP cookies, web beacons, tracking pixels, and local storage objects (collectively, “Tracking Technologies”) to persistently identify your session state, authenticate API requests, and compile aggregated topographical analytics regarding user navigational behaviors.

The Company shall solely process your Personal Data in strict accordance with Applicable Law, predicated upon one or more of the following legally cognizable justifications:

4.1 Contractual Necessity. The processing is materially indispensable for the execution, performance, and fulfillment of the Terms of Service Agreement to which you are a signatory party, including the provisioning of the DBaaS infrastructure and the processing of financial remittances.

4.2 Legitimate Commercial Interests. The processing is necessary for the purposes of the legitimate operational and mercantile interests pursued by the Company, provided such interests are not fundamentally overridden by the fundamental rights and freedoms of the Data Subject. Such interests encompass network security optimization, fraud prophylaxis, infrastructure scaling, and the empirical formulation of new technological features.

4.3 Legal and Regulatory Compliance. The processing is mandated for compliance with a binding legal obligation, subpoena, judicial order, or regulatory mandate to which the Company is subject under the jurisdiction of Hong Kong or other competent international tribunals.

5. DISCLOSURE, DISSEMINATION, AND THIRD-PARTY SUB-PROCESSORS

The Company vigorously guards the confidentiality of your Personal Data. However, you hereby grant express, informed consent for the Company to disseminate your Personal Data to the following restricted classifications of third parties:

5.1 Infrastructural Sub-Processors. We reserve the right to engage specialized, third-party cloud computing providers, managed data centers, and network transit operators to facilitate the underlying hardware layer of the Services.

5.2 Operational Auxiliaries. We may disclose data to duly authorized payment processors, commercial communication platforms, and certified public accounting or legal firms acting under strict obligations of professional confidentiality.

5.3 Corporate Restructuring. In the event of a prospective or consummated merger, acquisition, corporate reorganization, asset divestiture, or bankruptcy proceeding, your Personal Data and Customer Data may be legally transferred or assigned as a constituent commercial asset to the acquiring entity.

5.4 Law Enforcement and Judicial Directives. We unequivocally reserve the right to unilaterally disclose any Personal Data or Customer Data to authorized law enforcement agencies, regulatory bodies, or judicial entities without prior notice to you, provided we formulate a good-faith determination that such disclosure is legally compulsory pursuant to a valid warrant, subpoena, or analogous compulsory legal process.

6. CROSS-BORDER DATA TRANSFERS AND DATA LOCALIZATION

You acknowledge and consent that 2BILLIONBEATS LIMITED is a globally facing enterprise domiciled in Hong Kong. Consequently, your Personal Data and Customer Data may be systematically routed, transmitted, exported, and stored across international borders, including to jurisdictions that may possess disparate or less stringent data protection legislative frameworks than your jurisdiction of habitual residence. By utilizing the Services, you expressly and irrevocably consent to such trans-border data flows.

7. DATA RETENTION LIFECYCLES AND DESTRUCTION

7.1 Personal Data Retention. The Company shall retain your Personal Data only for as long as is strictly and commercially necessary to fulfill the operational purposes enumerated in Section 4, or as perpetually mandated by statutory accounting, tax, and liability retention laws.

7.2 Customer Data Post-Termination. As strictly stipulated in Section 10 of the Terms of Service Agreement, upon the formal termination or expiration of your subscription, your Customer Data shall be held in a suspended state for a non-extendable grace period of exactly thirty (30) calendar days. Upon the exhaustion of this temporal window, all Customer Data shall be subjected to irreversible cryptographic wiping and permanent destruction from all active sectors and disaster recovery archives.

8. SYSTEMIC SECURITY MEASURES AND DISCLAIMER OF LIABILITY

8.1 Implementation of Safeguards. The Company deploys commercially reasonable, industry-standard administrative, technical, and physical safeguards-including cryptographic protocols (e.g., TLS/SSL in transit, AES-256 at rest), firewalls, and role-based access controls-designed to mitigate the risk of unauthorized access, accidental exfiltration, or malicious destruction of your data.

8.2 Absolute Disclaimer. NOTWITHSTANDING THE FOREGOING SECURITY POSTURE, YOU ACKNOWLEDGE AND UNEQUIVOCALLY AGREE THAT NO ELECTRONIC TRANSMISSION OVER THE PUBLIC INTERNET, NOR ANY CLOUD-BASED STORAGE ARCHITECTURE, CAN BE GUARANTEED TO BE COMPLETELY, ABSOLUTELY, OR IMPENETRABLY SECURE. THE COMPANY EXPRESSLY DISCLAIMS ANY AND ALL WARRANTIES, EXPRESS OR IMPLIED, GUARANTEEING THE ABSOLUTE SECURITY OF YOUR DATA. YOU ASSUME ALL RISKS ASSOCIATED WITH THE TRANSMISSION AND STORAGE OF DATA WITHIN THE SERVICES.

9. STATUTORY RIGHTS OF THE DATA SUBJECT

Depending upon your geographical jurisdiction of residence and the applicability of extraterritorial privacy frameworks, you may possess specific, legally enforceable rights regarding your Personal Data, which may include:

  • The Right of Access: The prerogative to demand formal disclosure of the categories and specific pieces of Personal Data we have amassed concerning you.
  • The Right of Rectification: The ability to mandate the correction of materially inaccurate, erroneous, or incomplete Personal Data.
  • The Right to Erasure (“Right to be Forgotten”): The qualified right to request the systemic deletion of your Personal Data, subject strictly to our overriding legitimate interests or legal obligations to retain such data. To exercise any legally applicable rights, you must submit a formally drafted, written request to our designated Data Protection Officer (DPO) utilizing the official contact modalities provided below. We reserve the statutory right to authenticate your identity utilizing rigorous verification protocols prior to honoring any such request.

10. UNILATERAL MODIFICATIONS TO THIS POLICY

2BILLIONBEATS LIMITED reserves the absolute, unilateral, and uncontestable right to amend, supplement, modify, or completely restate this Privacy Notice at any given time, without prior consultation. Any such modifications shall become legally binding and effective immediately upon their digital publication on our official corporate website or user portal. Your continued, persistent access to or utilization of the Services following the promulgation of any revised Policy shall constitute your affirmative, binding acceptance of all amended terms and conditions contained therein.