Item 1B. Unresolved Staff Comments
Item
1B. Unresolved Staff Comments
Not
Applicable.
Item
1C. Cybersecurity
Risks
from Cybersecurity Threats
The
Company faces risks associated with cybersecurity threats in carrying out its business operations. For more details regarding the risks
related to PRC’s cybersecurity regulation, see “ Item 1A. Risk Factors—Compliance with China’s new Data Security
Law, Measures on Cybersecurity Review, Personal Information Protection Law, regulations and guidelines relating to the multi-level protection
scheme and any other future laws and regulations may entail significant expenses and could materially affect our business. ”;
and “I tem 1A. Risk Factors—Recent greater oversight by the CAC over data security, particularly for companies seeking
to list on a foreign exchange, could adversely impact our business and our offering. ”
For
the year ended March 31, 2025, the Company was not subject to material fines or penalties in connection with cybersecurity, and there
were no material cybersecurity incidents arising from cybersecurity or personal data protection.
Governance
Our
board of directors does not have a standing risk management committee, but rather administers this oversight function directly through
our board of directors as a whole, as well as through various standing committees of our board of directors that address risks inherent
in their respective areas of oversight. While our board of directors has a fiduciary duty to monitor and assess strategic risk exposure,
our audit committee is responsible for overseeing our major financial risk exposures and the steps our management has taken to monitor
and control these exposures, overseeing cybersecurity risks and assisting the board of directors in its oversight over enterprise risk
management. The audit committee also approves or disapproves any related person transactions. Our nominating and corporate governance
committee monitors the effectiveness of our corporate governance guidelines and manages risks associated with the independence of the
board of directors. Our compensation and leadership development committee assesses and monitors whether any of our compensation policies
and programs has the potential to encourage excessive risk-taking.
Engagement
of Third-Party Service Providers
We
have in place certain infrastructure, systems, policies, and procedures that are designed to proactively and reactively address circumstances
that arise when unexpected events such as a cybersecurity incident occur. These include processes for assessing, identifying , and managing
material risks from cybersecurity threats. Identifying, assessing, and managing cybersecurity risk is integrated into our overall risk
management systems and processes, and we have in place cybersecurity and data privacy training and policies designed to (a) respond to
new requirements in privacy laws and (b) prevent, detect, respond to, mitigate and recover from identified and significant cybersecurity
threats.
We
have relied on the third-party security assessment procedures and data outflow control procedures to manage risks from cybersecurity
threats associated with our use of third-party service providers. For example, the servers of the system of Hunan Ruixi are housed at
third-party data centers, and its operations depend on the service providers’ ability to protect such systems in their facilities
as well as their own systems. The qualified third-party performs security assessment by timely assessing their cybersecurity policies,
data encryption and privacy policies and relevant certificates, establishing procedures in granting such third parties access to our
database and requiring them to conduct regular inspections. Since in cooperation with third-party service providers may involve data
outbound, we desensitize sensitive information before transferring such data.
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Our
Chinese subsidiaries and affiliates have incurred, and will continue to incur, significant expenses in an effort to comply with cybersecurity
and information security standards and protocols imposed by law, regulation, industry standards or contractual obligations to the date
of this Report in all material respects.