GLOBAL PRIVACY POLICY
Initial Effective Date: March 1, 2023
Last Updated Date: August 6, 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.uk.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.
A. 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.
(7) Vulnerability Submission
If you discover or believe that you have discovered potential security vulnerabilities or incidents while using our products or services, we appreciate you reporting them to us. For the convenience of us to more accurately locate, verify, and handle vulnerabilities and security incidents, please provide us with the vulnerability name, vulnerability category, vulnerability type, and vulnerability details. You can choose whether to upload attachments (such as relevant screenshots, etc.). In order for us to contact you, please provide your email address as we will not use your email for any other purposes. We collect and use this information based on your consent.
B. 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.
C. 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.
D. 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.uk@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.uk@ugreen.com.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
