1. Purpose
This policy sets out Murzo Group's approach to AI services, algorithm recommendation, generative AI, deep synthesis, AI-generated content labelling, robotics data, server governance, data collection systems, and data compliance involving mainland China.
Murzo Group values a true, open, respectful, and transparent relationship with mainland China and with Chinese partners, customers, platforms, suppliers, regulators, and authorities. Where Murzo Group operates in mainland China, provides services into mainland China, processes mainland China-related data, uses mainland China-based systems, or works with mainland Chinese partners, Murzo Group will abide by all applicable laws, regulations, policies, standards, governance requirements, platform rules, and lawful regulatory expectations of mainland China.
2. Mainland China Scope
This policy applies specifically to mainland China. It covers mainland China-facing AI systems, chatbots, recommendation tools, automated decision tools, generative AI services, synthetic media, deep synthesis services, robotics platforms, drones, connected products, data services, websites, apps, APIs, customer platforms, servers, data collection systems, and technology collaborations.
It applies to public services, business-to-business services, internal projects, research, trials, procurement, suppliers, local partners, distributors, affiliates, contractors, and cross-border technology activity involving mainland China.
3. Mainland, Hong Kong and Macao Boundaries
Mainland China governance under this policy is the Murzo Group baseline for mainland China-related AI and data activity. Mainland China algorithm filing, CAC requirements, generative AI requirements, PIPL, data security, cybersecurity, and mainland cross-border data rules must not automatically be described as applying in, satisfying, replacing, or covering Hong Kong SAR or Macao SAR requirements.
Hong Kong SAR and Macao SAR may have their own local laws, regulators, privacy rules, platform rules, business rules, technology requirements, and court or authority expectations. Macao SAR laws apply locally, and any Macao operation, customer service, data activity, AI service, robotics activity, or platform arrangement must be assessed under Macao SAR requirements as well as Murzo Group's mainland China governance baseline where relevant.
4. Respect for Mainland Chinese Law and Governance
Murzo Group must not use AI, robotics, data services, platforms, third-party partners, overseas hosting, VPNs, APIs, resellers, Hong Kong or Macao structures, or informal arrangements to evade mainland Chinese laws, regulations, licensing requirements, security assessments, algorithm filing, data export controls, content governance, foreign investment rules, product rules, or public authority requirements.
Where mainland Chinese law, policy, platform governance, or regulator guidance applies, Murzo Group should act carefully, respectfully, and transparently. If requirements are unclear, mainland China-facing AI activity should not proceed until suitable legal, local, regulatory, or competent partner advice has been considered.
5. Chinese-Based AI Platforms and Technical Adjustment
Murzo Group reserves the right to use mainland China-based AI platforms, cloud services, data services, hosting providers, model providers, content review tools, security tools, and local technical partners where this is lawful, commercially appropriate, and necessary or helpful for mainland China compliance.
Where required by mainland Chinese law, regulation, platform governance, regulator instruction, security assessment, algorithm filing, data localisation, cybersecurity review, PIPL, data security, cross-border data transfer requirements, content governance, or lawful authority expectation, Murzo Group may adjust algorithms, model behaviour, recommendation logic, moderation rules, prompts, labels, user controls, data collection systems, analytics, logs, interfaces, servers, hosting locations, retention settings, export routes, and access controls for mainland China.
Any such adjustment must be made for lawful mainland China compliance, safety, security, transparency, operational integrity, or regulatory cooperation, and must not be used as a hidden route to unlawfully discriminate, mislead users, evade other local law, or misuse personal information.
6. Generative AI and Public Services
No generative AI service, chatbot, API, content generator, AI writing tool, image generator, audio generator, video generator, virtual scene tool, or similar AI service may be provided to the public in mainland China in Murzo Group's name unless the applicable mainland Chinese requirements have been considered and written approval has been given.
Relevant considerations may include generative AI service obligations, public opinion or social mobilisation attributes, security assessment, CAC algorithm filing, complaint and reporting routes, training data obligations, content governance, real-name or user management obligations, protection of minors, and regulator cooperation.
7. Algorithm Recommendation and Platform Governance
Where Murzo Group uses algorithmic recommendation, ranking, search filtering, personalised push, dispatching, scheduling, matching, or decision algorithms for mainland China-facing internet information services, mainland Chinese algorithm recommendation rules and platform governance requirements must be considered.
Users should be treated fairly and lawfully. Murzo Group must not use algorithms to manipulate public opinion, spread unlawful content, create fake engagement, over-consume users, harm minors, unfairly discriminate, undermine user rights, evade supervision, or breach mainland Chinese public interest requirements.
8. Deep Synthesis and AI Content Labelling
Mainland China-facing AI-generated or AI-synthesised text, images, audio, video, avatars, voice synthesis, face manipulation, virtual scenes, or chatbot interactions may require visible or technical labelling, content review, complaint channels, real identity or account controls, and platform governance.
Murzo Group must not remove, hide, falsify, or undermine AI-generated content labels, watermarks, metadata, provenance signals, or platform-required disclosure where mainland Chinese requirements apply.
9. Personal Information, Data Security and Cross-Border Transfers
Mainland China-related personal information, important data, sensitive personal information, customer data, worker data, platform data, robotics data, telemetry, location data, imagery, audio, biometric data, training data, and server logs must be handled in line with applicable mainland Chinese personal information protection, cybersecurity, data security, and cross-border transfer requirements.
Murzo Group must not export, transfer, mirror, train on, disclose, or provide mainland China-related data to third parties where doing so would breach mainland Chinese law, contract, platform rules, national security requirements, confidentiality obligations, or written approval conditions.
10. Local Partners, Suppliers and Government Interaction
Mainland Chinese partners, distributors, suppliers, agencies, platforms, cloud providers, data processors, universities, laboratories, manufacturers, robotics integrators, and consultants must be selected and managed carefully where AI, data, public services, robotics, drones, or content governance are involved.
Government, regulator, state-owned enterprise, public body, university, or sensitive sector interaction must be honest, accurate, respectful, and consistent with Murzo Group's anti-bribery, sanctions, export control, public communications, and mainland China compliance expectations.
11. Robotics, Drones and Connected Products in Mainland China
AI-enabled robotics, drones, UAVs, connected products, sensors, cameras, autonomous systems, and software operating in mainland China may be subject to product safety, robot safety, aviation, registration, identification, data reporting, cybersecurity, telecoms, encryption, import, export, mapping, and local operating rules.
Murzo Group must not operate or support mainland China-based robotics, drone, mapping, surveillance, security, or autonomous activity unless legal role, permissions, safety, data handling, customer responsibility, and local authority requirements are understood.
12. Prohibited Activity
Murzo Group prohibits mainland China-related AI or robotics activity that knowingly breaches mainland Chinese law, threatens national security or public interest, spreads unlawful or harmful information, undermines public order, infringes personal information rights, violates intellectual property, manipulates users, evades algorithm governance, fabricates news, creates unauthorised deepfakes, or misleads regulators, partners, customers, or platforms.
13. Liability and Third Parties
Third parties must not present their own mainland China AI compliance, algorithm filing, security assessment, hosting, licences, content review, server governance, data localisation, or data transfer arrangements as Murzo Group arrangements unless approved in writing.
To the fullest extent permitted by law, Murzo Group does not accept responsibility for mainland China-facing AI services, data transfers, content, filings, licences, platform breaches, regulatory failures, or user harm caused by third parties acting outside written approval or outside Murzo Group control.
14. Review and Evidence
Murzo Group may keep proportionate evidence of approvals, legal checks, partner roles, regulator communications, platform requirements, filings, data transfer assessments, server decisions, algorithm adjustments, and content governance decisions where needed for legal, regulatory, customer, supplier, or dispute purposes.
This policy should be reviewed when mainland Chinese AI, algorithm, data, robotics, platform, aviation, cybersecurity, foreign investment, product, server, Hong Kong SAR, or Macao SAR rules change.
