Welmo Technology Account Deletion & Data Export Rules

This English version is a courtesy translation. In case of any discrepancy between the Chinese and English versions, the Chinese version shall prevail.

Important Notice

This Account Deletion & Data Export Rules (the "Rules") sets out the specific procedures and timelines for deactivating your Welmo Technology account, exercising your data portability right, and your right of personal information deletion. These Rules are based on Article 45 (right to copy), Article 47 (right to delete), and Article 50 (processing time limits) of the PIPL, as well as Article 24 (right to deactivate accounts) of the E-Commerce Law.

Please read these Rules carefully before submitting a deletion request. Account deletion is irreversible; you cannot recover the account or access historical data after deletion.

1. Account Deletion

1.1 Your Rights

You have the right to request deletion of your Welmo Technology account at any time. After deletion, Welmo Technology will process your personal information in accordance with these Rules.

1.2 Pre-Deletion Conditions

In the following circumstances, your deletion request will be temporarily refused until the relevant matter is resolved:

1.3 Deletion Channels

Welmo Technology's current deletion process is "manual channels", as the backend automated deletion API is being developed. We commit to handling your requests efficiently through:

Channel A · Email Application (Recommended)

Send an email to legal@welmotech.com with:

Channel B · Customer Service Phone

Call +86 158 3825 5257 (Daily except Wednesdays, 09:00–18:00 CST). The customer service representative will record your request and assist with processing.

Channel C · Mini-Program Entry (if launched)

Navigate to the Mini-Program "Profile → Settings → Account Deletion" and follow the instructions to submit.

1.4 Identity Verification

To protect your account security, Welmo Technology will verify your identity before processing deletion requests:

• SMS verification code sent to your registered mobile;
• May require you to provide registered mobile, purchase order number, recent order information, or other supporting verification;
• We reserve the right to refuse requests that fail verification.

1.5 Processing Timeline

1.6 Consequences of Deletion

The following take effect immediately upon deletion:

1. Account invalidation: Your Welmo account will be permanently disabled; the same mobile number cannot be used to log in or re-register.
2. Personal information deletion: Welmo Technology will delete or anonymize your personal information within 90 days (see Chapter 3 for details).
3. Forfeiture of unconsumed benefits: All your unconsumed benefits (e.g., remaining Welmo Spices refill cycles, unexpired LumaPet storage) will be forfeited; Welmo Technology will not refund the amounts you paid on external e-commerce.
4. Deletion of uploaded content: Memorial photos and videos uploaded to LumaPet, trial videos uploaded to The Greens, etc. will be deleted (except videos already used for marketing where you have not withdrawn authorization).
5. No reclamation of received benefits: Refunds, cashback, or physical goods you have received will not be reclaimed.
6. Statutory retention: Transaction records, order information, etc. required by Article 31 of the E-Commerce Law and other laws will be retained in anonymized form until the statutory period expires.

2. Data Export (Right to Personal Information Portability)

2.1 Your Right

Pursuant to Article 45 of the PIPL, when conditions set by the Cyberspace Administration of China are met, you have the right to request that Welmo Technology provide your personal information in a commonly used format or transfer it to another personal information processor of your choice.

2.2 Application Channel

Send an email to legal@welmotech.com with:

2.3 Export Scope

Welmo Technology will provide the personal information we hold about you, including:

• Account information (mobile, nickname, registration time);
• All benefit activation and fulfillment records;
• All refill claims and logistics records;
• A list of your uploaded image and video files (with OSS paths; actual files obtainable via authorized download links);
• Records of your communications with customer service (if any);
• History of your exercise of personal information rights.

2.4 Information Not Exported

• Parts involving the lawful rights of others (e.g., names and phones of others in customer service records) will be redacted;
• Parts involving trade secrets or security risk control (e.g., internal anti-fraud scores) will not be exported;
• Content that does not constitute "your personal information" (e.g., Welmo Technology's product formulas, internal review notes) will not be exported.

2.5 Processing Timeline

2.6 Frequency Limit

• Each account may apply for data export only once every 6 months (reasonable frequency principle);
• For requests exceeding reasonable frequency, Welmo Technology may extend the processing time or charge a reasonable cost.

3. Data Retention and Deletion Details

3.1 Treatment of Different Data Types

After account deletion, Welmo Technology processes your personal information as follows:

3.2 Meaning of "Anonymization"

"Anonymization" in these Rules means replacing fields that can identify you (mobile, name, address, device ID, etc.) with irreversible random identifiers or hashes, so that the retained data cannot be re-associated with you and cannot be restored.

3.3 Deletion Technical Details

• Database layer: Sequentially delete relevant rows in users, user_subscriptions, refill_records, media_files, etc.;
• OSS layer: Delete uploaded file entities (including all thumbnails) via OSS API;
• Backups: After 90 days from deletion, the next full backup will no longer contain your information; existing backups will be auto-overwritten on expiry without separate operations;
• Cache: Distributed cache key-value entries become invalid immediately after deletion.

4. Exceptions

In the following circumstances, Welmo Technology may lawfully retain certain data:

4.1 Legally Required Retention

Pursuant to Article 31 of the E-Commerce Law, the Tax Collection and Administration Law, anti-money laundering, anti-terrorism, and other laws, certain transaction records, tax certificates, and compliance audit materials must be retained until the statutory period expires.

4.2 Administrative or Judicial Requirements

Accounts and related data under administrative regulatory inspection or judicial investigation will be retained at the request of regulators or judicial authorities until released.

4.3 Dispute Resolution

For accounts with unresolved disputes (complaints, lawsuits, arbitration), relevant evidence data will be retained for 3 years after the dispute is resolved.

4.4 Security Retention

Minimal information necessary to prevent fraud, abuse, and security incidents (e.g., blacklists of mobile numbers and device identifiers from violating accounts) will be retained until the risk control purpose is achieved.

5. Special Circumstances

5.1 User Death

If you unfortunately pass away, your legal heirs or guardians may, with appropriate documentation (death certificate + proof of relationship), apply via legal@welmotech.com to:

• Deactivate the account;
• Export your personal information;
• Download your memorial imagery uploaded to LumaPet.

Welmo Technology will process in accordance with these Rules.

5.2 Incapacity or Disappearance

If you are long-term incapacitated (mental illness, Alzheimer's, etc.) or legally missing, your legal guardian may, with appropriate documentation, apply on your behalf.

5.3 Guardian Acting on Behalf

For minor users (see the Minors Personal Information Protection Rules, Document 07), guardians may apply for deletion and data export on behalf of the minor without the minor's own consent.

6. Honest Disclosure of Engineering Status

This section is a transparency statement to users.

Welmo Technology currently does not have an automated account deletion API or data export API. Both deletion and export requests are handled through manual channels. We have included automation in our future product roadmap.

Before automation launches, we safeguard your rights by:

• Designating a responsible person to monitor legal@welmotech.com;
• Committing to processing within 15 business days;
• Retaining processing records for audit;
• Clearly defining responsibilities at each step in internal operating procedures.

7. Contact Us

To submit a deletion or data export request, or for any questions about these Rules, contact us via:

• Legal / Personal Information Protection Email: legal@welmotech.com
• Customer Service Phone: +86 158 3825 5257 (Daily except Wednesdays, 09:00–18:00 CST)
• Customer Support Email: support@welmotech.com
• Company Name: Henan Welmo Technology Co., Ltd.
• Registered Address: Room 2501, 25/F, Unit 1, Building 5, Yard 66 Zhengtong Road, Erqi District, Zhengzhou City, Henan Province, China

Revision History

All rights of final interpretation reserved by Henan Welmo Technology Co., Ltd.

Document ID: WELMO-LEGAL-09 · Version v1.0 · April 7, 2026