GLOBAL PRIVACY POLICY

Last updated: May 20, 2024

This Website Privacy Policy (“Privacy Policy”) applies to UGREEN GROUP LIMITED and its affiliates ( UGREEN America- AMERICA UGREEN LIMITED, UGREEN Hong Kong- HONG KONG UGREEN LIMITED, and UGREEN Germany- UGREEN Group GmbH) hereinafter referred to as “Ugreen,” “we,” “us,” and “our”. We recognize that privacy is an ongoing responsibility and will therefore update this Privacy Policy from time to time update this Privacy Notice as we adopt new personal data practices or adopt new privacy policies.

This Privacy Policy describes how Ugreen collects and uses the personal information you provide on our website located at: www.ugreen.com (“Website”). This Privacy Policy does not govern the use of Ugreen products or services offered under contract to Ugreen customers. To view our Product Privacy Policy, click here.

This website is intended for users all over the world. Therefore, please note that our privacy practices are subject to the applicable laws of the jurisdictions in which we operate. You will see other region-specific terms that apply only to customers in those regions or that are required by applicable law.

This policy is intended to help you understand:

WHAT PERSONAL DATA WE COLLECT AND HOW WE USE IT
HOW WE DISCLOSE YOUR PERSONAL DATA
HOW WE PROTECT YOUR PERSONAL DATA
DATA RETENTION
MARKETING COMMUNICATIONS AND SUBSCRIPTIONS
YOUR RIGHTS
INTERNATIONAL TRANSFERS
ADDITIONAL POLICY FOR CALIFORNIA RESIDENTS
ADDITIONAL POLICY FOR INDIVIDUALS LOCATED IN THE EEA AND THE UNITED KINGDOM
ADDITIONAL POLICY TO INDIVIDUALS IN CANADA
CHILDREN’S PRIVACY
UPDATE
CONTACT INFORMATION

1. WHAT PERSONAL DATA WE COLLECT AND HOW WE USE IT

The types of personal data we may collect about you include data you provide to us, data from third parties, and automatically collected information about your use of our Services.

Data that you provide to us directly and voluntarily

(1) Subscribe

If you choose to subscribe to our newsletters about new product launches, promotions and exhibitions to get 10% off voucher, you will need to provide your email address to receive the newsletters and create a Ugreen account to receive and use the voucher.

We rely on your consent as the lawful basis for processing your personal data.

(2) Register

You have the option to register as a member of Ugreen. Members can view the shopping cart, order history, registration information and point balance, etc. When registering as a member, you need to set up a user name, provide your e-mail address, and set up a password.

We rely on your consent as the lawful basis for processing your personal data.

(3) Login

As a member, you must provide your e-mail address (account number) and password when you log in.

We rely on your consent as the lawful basis for processing your personal data.

(4) Check out

When you place an order, you must enter your e-mail address (account number), as well as the name, telephone number, and postal address of the recipient so that we can send your order to you. In addition, when paying, you will be taken to a third-party provider to enter the payment information, see “Payment information” below.

We rely on fulfillment of contract as the lawful basis for processing your personal data.

(5) Online customer service

When you shop and use the website, you can click “Chat” to get help from online customer service. When communicating with customer service, you can provide the username and email (account) if necessary. If you are logged in to chat with customer service online, we will save your chat record with customer service, so that you can easily trace the problem. If you are not logged in the chat recording will not be saved.

We rely on your consent as the lawful basis for processing your personal data.

(6) Order Tracking

You can track the status of your order through the Order Tracking feature, for which you will need to provide an Order number and Email address.

We rely on your consent as the lawful basis for processing your personal data.

Data that we collect automatically.

(7) Assign Sites

To speed up your access to our website, we collect IP addresses and assign you to the nearest website.

We rely on your consent as the lawful basis for processing your personal data.

Data from third parties.

(8) Student discount register

If you are a student, you can verify your student status on Studentsbeans, after verification, you can enjoy student-related discounts, we only collect “yes” or “no” feedback from the site.

We rely on your consent as the lawful basis for processing your personal data.

Payment information.

Any credit or debit card numbers you provide to pay for our services will be processed by a third-party payment processor that complies with the Payment Card Industry Data Security Standard (PCI/DSS). Any information collected by these third- party providers for the purpose of processing your payments is not available to us unless you have otherwise provided us with this information in connection with your use of the Sites or our Services.

2. HOW WE DISCLOSE YOUR PERSONAL DATA

We do not share your information with a third party for their independent use unless: (1) you request , (2) you authorize it, or (3) it is required by law.

3. HOW WE PROTECT YOUR PERSONAL DATA

We take appropriate technical and organizational measures to ensure the security of your personal data.

We have taken appropriate security measures to protect your personal data and prevent unauthorized access, manipulation, damage or loss. We use encryption techniques to secure the transmission of your personal data. We use appropriate encryption, access control and identity verification technologies for stored personal data. We also appropriately restrict the access rights of our employees. In addition, we regularly create backup copies of personal data in order to be able to restore access to this data in the event of physical or technical incidents.

To address potential risks of leakage, damage and loss of personal data (referred to as “personal data security incidents”), we have developed a contingency plan for such incidents and conduct regular drills.

While we strive to protect your personal data, no internet transmission method or security system is perfect and we cannot guarantee that your data will be secure in all circumstances. You are often in the best position to protect yourself online. It is your responsibility to protect your login ID and password from access by third parties and to choose strong passwords.

4. DATA RETENTION

We will retain Personal Data where we have a justifiable business need to do so and/or for as long as is needed to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (e.g. for anti-money laundering, accounting or other purposes). When we do not have no justifiable business need to process your personal data, we will either delete it or, if this is not possible (e.g. because your personal data has been stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible.

5. How we share, assign, and disclose your personal information

5.1. Sharing

Your personal information will not be shared with any entities other than UGREEN or its affiliates, except under the following circumstances:

(1) We receive your or your guardian’s explicit authorization or consent.

(2) Judicial or administrative agencies demand disclosure as part of legal proceedings;

(3) We engage in legal action or arbitration against a user to protect our legal rights;

(4) Such sharing is necessitated by the service agreement or usage rules between you and UGREEN;

(5) To prevent infringement of the legal rights of UGREEN, its affiliates, users of our service, and the public to the extent permitted by law;

(6) The sharing complies with agreements made between you and third parties.

(7) The information is utilized for academic research purposes.

5.2. Assignment

We will not transfer your personal information to any company, organization, or individual outside of UGREEN’s affiliates, except under the following circumstances:

(1) With your express prior authorization and consent;

(2) To comply with legal obligations, legal proceedings, mandatory government directives, and court orders;

(3) In cases of mergers, separations, bankruptcy liquidation, or acquisition/sale of our or our affiliates’ business, your personal information may be transferred as part of the transaction. We will ensure confidentiality during the transfer and require the successor entity to adhere to this privacy policy, or otherwise, seek your reauthorization.

5.3. Disclosure

We will only publicly disclose your personal information under the following circumstances:

(1) With your express prior consent;

(2) In compliance with laws, legal proceedings, lawsuits, or government orders.

5.4. Exceptions to Obtaining Your Consent when Sharing, Assigning, or Disclosing Your Personal Data

Please be aware that in certain instances, we may share, assign, or disclose your personal data without prior authorization or consent:

(1) The request is directly related to national defense and security;

(2) The request is related to public security, public health, and other material public interests;

(3) In circumstances directly involving criminal investigations, prosecutions, trials, or court order execution;

(4) To protect vital legal rights, such as the life and property of the data subject or other individuals, when obtaining consent is not possible;

(5) If the personal data has been publicly disclosed by the data subject;

(6) Personal data obtained from legally disclosed information sources, including without limitation news reports, government information disclosure, and other legal channels.

6. How to Exercise Your Right to Manage Personal Information

Your Rights include:

(1) Access and portability. You may ask us to confirm whether we are processing your personal data, provide you with details about what we have collected and how we process your personal information,and, in some limited circumstances, give you a copy of your personal data. You may ask us to provide your personal data in a structured, commonly used, machine-readable format, or you can ask to have it ported directly to another controller.

(2) Rectification or correction. You may ask us to correct any inaccurate or incomplete personal data that we hold about you.

(3) Erasure or deletion. You may ask us to delete the personal data that we hold about you.

(4) Objection to processing including marketing and automated decision-making. You may request that we stop processing your personal data for specific purposes including marketing and profiling.

(5) Restrict the Processing or disclosure of Personal Information

You have the right to restrict the Processing or disclosure of their Personal Information where appropriate and in accordance with applicable law(for example, where you believe that the personal data we hold about you is not accurate or lawfully held),such as , blocking, or deletion of unnecessary or excessive personal information, or personal information not processed in compliance with those laws.

(6) Lodge a complaint to your local Data Protection Authority. You may have the right to lodge a complaint with your national Data Protection Authority or equivalent regulatory body.

(7) Withdraw Consent

We process most of your personal information on the basis of your consent. You have the right to give your consent ，and you also have the right to withdraw your consent.

(8) Account Closure

If you have registered an account, you have the same right to close your account.

This Policy does not create, extend, or modify rights , you may have all or some of the above rights, or other rights, under applicable law. These rights are not absolute and are subject to conditions or limitations as specified in applicable laws. If you would like to exercise any of the above rights, please contact us using the details in the end of this Policy. We will process your request in accordance with applicable privacy and data protection laws. To protect your privacy and security, we may take steps to verify your identity before dealing with the request.

Reasonable requests are typically processed free of charge. We reserve the right to deny requests that are unjustifiably repetitive, technically burdensome (such as by necessitating the development of new systems or fundamentally amending current practices), infringe on others’ legal rights, or are impractical (such as requests involving data on backup tapes).If denied, we will notify you of the reasons for the denial and you have the right to appeal the denial , file a complaint,or seek other remedies consistent with applicable law.

7. INTERNATIONAL TRANSFERS

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal data. If you do not want your Personal Data to be transferred to, or processed or stored in, a country or jurisdiction outside of the country or jurisdiction in which you are located, you should not use our Services.

8. ADDITIONAL POLICY FOR CALIFORNIA RESIDENTS

This section applies only to California residents.

You may request information concerning the categories of personal data (if any) that we disclose to third parties or affiliates for their direct marketing purposes. To make such a request, please see the “CONTACT INFORMATION ” section below.

If you are under 18 years of age and have a registered account, you may request that we remove content or information that you have posted on the Site or stored on our servers by submitting a written request as indicated in the “CONTACT INFORMATION” section below and clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed.

9. ADDITIONAL POLICY FOR INDIVIDUALS LOCATED IN THE EEA AND THE UNITED KINGDOM

This section applies only to individuals who access or use our Services while located in the European Economic Area or the United Kingdom (collectively, “Europe”).

The controller for the processing described in this Privacy Policy is America Ugreen Limited(108 WEST 13TH ST WILMINGTON, DE 19801, USA County of Delaware). You can contact our Data Protection Officer or DATAREP at service@ugreen.com.

We will protect your personal data in accordance with this Privacy Policy wherever it is processed and take appropriate contractual or other steps to protect the personal data concerned in accordance with applicable laws. These steps include implementing the European Commission’s Standard Contractual Clauses for the transfer of personal data to our service providers and business partners located in countries that are not considered by the EU to provide an adequate level of data protection.

10. ADDITIONAL POLICIES FOR INDIVIDUALS IN CANADA

You may request details about our privacy practices, access or correct your personal data, or lodge a complaint by contacting us at CONTACT INFORMATION.

11. PRIVACY FOR CHILDREN

We do not knowingly attempt to solicit or receive information from children. If you are a parent of a child and believe that your child has provided us with information about themselves, please contact us using the information in the Contact Us section below.

12. UPDATE

We may update this Privacy Policy if applicable law and our business practices change. When this policy is updated, we will notify you via a pop-up window on our website or we will seek your consent again.

13. CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy, please contact us at service@ugreen.com.

Privacy policy

This Privacy Policy describes how WINSLER US (the “Site”, “we”, “us”, or “our”) collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from www.winsler.net (the “Site”) or otherwise communicate with us regarding the Site (collectively, the “Services”). For purposes of this Privacy Policy, “you” and “your” means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the “Last updated” date and take any other steps required by applicable law.

How We Collect and Use Your Personal Information

To provide the Services, we collect and have collected over the past 12 months personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us.

In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide or improve or improve the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

What Personal Information We Collect

The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term “personal information”, we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

Information We Collect Directly from You

Information that you directly submit to us through our Services may include:

Contact details including your name, address, phone number, and email.
Order information including your name, billing address, shipping address, payment confirmation, email address, and phone number.
Account information including your username, password, security questions and other information used for account security purposes.
Shopping information including the items you view, put in your cart, saved into your account like loyalty points, reviews, referrals or gift cards, or purchases.
- Loyalty points/product reviews/referrals/gift cards saved
Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

Information We Collect about Your Usage

We may also automatically collect certain information about your interaction with the Services (“Usage Data“). To do this, we may use cookies, pixels and similar technologies (“Cookies“). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

Information We Obtain from Third Parties

Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

Companies who support our Site and Services, such as Shopify.
Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.
When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Also see the section below, Third Party Websites and Links.

How We Use Your Personal Information

Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfill your orders, to send notifications to you related to your account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and other features and functionalities related to your account.
Marketing and Advertising. We may use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in selling our products, according to Art. 6 (1) (f) GDPR.
Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in keeping our website secure for you and other customers, according to Art. 6 (1) (f) GDPR.
Communicating with You and Service Improvement. We use your personal information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you according to Art. 6 (1) (f) GDPR.

Cookies

Like many websites, we use Cookies on our Site. For specific information about the Cookies that we use related to powering our store with Shopify, see https://www.shopify.com/legal/cookies. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

Our website also recognizes the Global Privacy Control (GPC) signal, which enables you to opt-out of certain uses or disclosures of your information. If you notify us of your preference through GPC, we will treat such signal as a valid request to opt out of sharing / targeted advertising for the associated browser or device, and, if we are able to associate the device sending the signal to a Shopify account, we will apply the opt out request to the account as well. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/. Other than the Global Privacy Control, we do not recognize other “Do Not Track” signals that may be sent from your web browser or device.

How We Disclose Personal Information

In certain circumstances, we may disclose your personal information to third parties for contract fulfillment purposes, legitimate purposes and other reasons subject to this Privacy Policy. Such circumstances may include:

With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfillment and shipping).
With business and marketing partners to provide services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices.
When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.
With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

We have in the past 12 months disclosed the following categories of personal information and sensitive personal information about users for the purposes set out above in “How we Collect and Use your Personal Information” and “How we Disclose Personal Information”:

Category

Categories of Recipients

Identifiers such as basic contact details and certain order and account information
Personal information categories listed in the California Customer Records statute such as basic contact details and certain order and account information
Commercial information such as order information, shopping information and customer support information
Internet or other similar network activity, such as Usage Data
Geolocation data such as locations determined by an IP address or other technical measures

Vendors and third parties who perform services on our behalf (such as Internet service providers, payment processors, fulfillment partners, customer support partners and data analytics providers)
Business and marketing partners
Affiliates

We do not use or disclose sensitive personal information without your consent or for the purposes of inferring characteristics about you.

With your consent we share personal information for the purpose of engaging in advertising and marketing activities, as follows.

We have “sold” and “shared” (as those terms are defined in applicable law) personal information over the preceding 12 months for the purpose of engaging in advertising and marketing activities, as follows.

Category of Personal Information	Categories of Recipients
Identifiers such as name, e-mail address and phone number	Business and marketing partners
Commercial information such as records of products or services purchased	Business and marketing partners
Usage Data	Business and marketing partners

Third Party Websites and Links

Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

Children’s Data

The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.

Security and Retention of Your Information

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.

Your Rights

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

Right to Access / Know: You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.
Right to Delete: You may have a right to request that we delete personal information we maintain about you.
Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you.
Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
Right to Opt out of Sale or Sharing or Targeted Advertising: You may have a right to direct us not to “sell” or “share” your personal information or to opt out of the processing of your personal information for purposes considered to be “targeted advertising”, as defined in applicable privacy laws. Please note that if you visit our Site with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out of the “sale” or “sharing” of information for the device and browser that you use to visit the Site.
Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.
Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.
Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.
Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

Complaints

If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority. For the EEA, you can find a list of the responsible data protection supervisory authorities here.

International Users
Please note that we may transfer, store and process your personal information outside the country you live in. Your personal information is also processed by staff and third party service providers and partners in these countries.

If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission’s Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

For the purpose of applicable data protection laws and if not explicitly stated otherwise, we are the data controller of your personal information.