This Policy

This Policy is issued by  ZhengZhou Dan Ying KeJue Shang Mao Co., Ltd. and its affiliates (together, “XCWIIE”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites and Applications, or recipients of any of our other products, services, personnel of corporate customers and vendors, and visitors to our premises (together, “you”). Defined terms used in this Policy are explained below.

Except for specific XCWIIE products or services that provide independent privacy policies, this Privacy Policy applies to all XCWIIE devices, websites, or applications that reference or link to this Privacy Policy. This Policy is a general privacy policy which outlines how XCWIIE collects, uses, discloses, processes, and protects information provided to us or collected by us when using our products or services located on our websites or provided on our mobile applications. If a specific XCWIIE product or service has a separate privacy policy, that policy will take precedence. Any parts not covered by the separate privacy policy will be governed by this Privacy Policy. Additionally, depending on factors such as the device model you are using, service version or location, how specific products or services collect and process your Personal Data or Personal Information may differ. You should refer to the separate privacy policy for detailed information.

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on XCWIIE 's application or site you used prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

You may also have certain rights regarding the information we collect about you. Specifically, the rights of Data Subjects under the GDPR. Similarly, U.S. residents in general and California residents in particular may find information on their rights as a Consumer in Section (S) below.

Intended Audience: Our Sites, Applications, products, or services are not directed to children under the age of 18. As a result, our Sites, applications, products, or services do not request or knowingly collect Personal Data from individuals under the age of 18. If you are not 18 or older, you should not visit or use our Sites, applications, products, or services.

(A) Collection of Personal Data

We collect or obtain Personal Data about you from the following sources:

  • Data provided to us: We obtain Personal Data when those data are provided to us (e.g., when you register an account with us; where you contact us via email or telephone, or by any other means, or when you provide us with your business card).
  • Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you).
  • Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
  • Site or Application data: We collect or obtain Personal Data when you visit any of our Sites or Applications, or use any features or resources available on or through our Sites or Applications.
  • Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites or Applications.
  • Content and advertising information: If you interact with any third party content or advertising on our Sites and/ or applications (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
  • Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

(B) Creation of Personal Data

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, Applications, products or services, including where those data are collected from different devices.

(C) Categories of Personal Data We Process

When you register your account on our Sites or Applications, we may process the following categories of Personal Data about you:

  • such as usernames and passwords, email addresses, phone numbers, social media accounts, and third-party avatars

After successfully creating your account, you can use it to log in to our Sites and Applications of XCWIIE. When using our Sites, Applications, products or services, we may also process the following categories of Personal Data about you:

  • Personal details: such as given name(s), preferred name, and photograph you provide to us.
  • Demographic information: such as gender, date of birth/age you provide to us; nationality/district, language preferences you choose on XCWIIE's Sites or Applications.
  • Contact details: such as address, shipping address, telephone number, email address you provide to us; online messaging details, and photos/videos you uploaded when dealing with certain issues; and social media details.
  • Consent records: such as records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
  • Purchase details: such as records of purchases and prices, consignee name, address, contact telephone number, email address, details of returns, warranty details when you place orders on XCWIIE's Sites or Applications.
  • Payment details: such as invoice records, payment amount, payment date, billing address, payment method, cardholder or accountholder name when you place orders on XCWIIE's Sites or Applications.
  • Server logs: such as records of events on our servers, including search queries; IP addresses; hardware settings; browser type; browser language; the date and time of request; referral URL; and certain cookies that identify your browser or Account.
  • Content and advertising data: such as records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part).
  • Views and opinions: such as any comments, views and opinions that you choose to send to us, or publicly post about us on social media platforms.
  • Cookie data: such as personal data collected via cookies and other similar technologies – please see our Cookie Policy for more details.

(D) Purposes of Processing and legal bases for Processing

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

Processing activity

Legal basis for Processing

·         Provision of Sites and Applications: providing our Sites and Applications; providing promotional items upon request; and communicating with you in relation to those Sites and Applications.

·         The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

·         We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

·         We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

·         Operating our business: operating and managing our Sites and Applications; providing content to you; displaying advertising and other information to you; analysing trends, usage, and activities; communicating and interacting with you via our Sites and Applications, or develop and display content, features, and advertising tailored to your interests on our services as well as on other platforms and services; and notifying you of changes to any of our Sites or Applications.

·         The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

·         We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

·         We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

·         Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; personalising our Sites and Applications for you; maintaining and updating your contact information where appropriate; obtaining your prior, opt-in consent where required; enabling and recording your choice to opt-out or unsubscribe, where applicable.

·         The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or

·         We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

·         We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

·         Product safety communications: communications in relation to product safety, including product recalls and product safety advisory notices.

·         The Processing is necessary for compliance with a legal obligation; or

·         We have a legitimate interest in carrying out the Processing for the purpose of ensuring the safety, and proper use, of our products (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

·         Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.

·         The Processing is necessary for compliance with a legal obligation; or

·         We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

·         Financial management: sales; finance; corporate audit; and vendor management.

·         We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

·         We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

·         Surveys: engaging with you for the purposes of obtaining your views on our Sites.

·         We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

·         We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

·         Security: physical security of our premises (including records of visits to our premises).

·         The Processing is necessary for compliance with a legal obligation; or

·         We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

·         Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.

·         The Processing is necessary for compliance with a legal obligation; or

·         We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

·         Legal compliance:compliance with our legal and regulatory obligations under applicable law.

·         The Processing is necessary for compliance with a legal obligation.

·         Fraud prevention: Detecting, preventing and investigating fraud, breach of policies or terms, and threats or harm.

·         The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or

·         We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

·         Establishment, exercise and defence of legal claims: management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defence of legal rights and claims, including formal legal proceedings.

·         The Processing is necessary for compliance with a legal obligation;

·         We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or

·         The Processing is necessary for the establishment, exercise or defence of legal claims.

(E) Disclosure of Personal Data to third parties

We disclose Personal Data to other entities within the Xcwiie group, for legitimate business purposes and the operation of our Sites to you, in accordance with applicable law. In addition, we disclose Personal Data to:

  • you and, where appropriate, your appointed representatives;
  • as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • accountants, auditors, consultants, lawyers and other outside professional advisors to Xcwiie, subject to binding contractual obligations of confidentiality;
  • third party Processors (such as email service providers; marketing/advertising service providers; call service providers;video shopping support and showroom service providers; text message service providers; venue operators; payment services providers; shipping companies; postal carriers; etc.), subject to the requirements noted below in this Section (E). These Processors support us in processing the types of Personal Data described above in the Section (A) (B) and (C), and for the purposes described in the Section (D). They only are authorized to process that information as necessary and as directed by us.;
  • any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
  • any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
  • safety, fraud prevention, government requests and protection of our rights are all reasons where we may share Personal Data where we believe in good faith it is necessary;
  • If Xcwiie is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent; and
  • any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

(F) International transfer of Personal Data

Because of the international nature of our business, we transfer Personal Data within the Xcwiie group, and to third parties as noted in Section (E) above, in connection with the purposes set out in this Policy. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located, including China, the EEA, the UK, and the US.

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses and International data transfer agreement. You are entitled to request a copy of our [Standard Contractual Clauses] using the contact details provided in Section (N) below.

Please note that when you transfer any Personal Data directly to any Xcwiie entity established outside the UK or the EEA (as applicable), we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Policy.

(G) Data security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

(H) Data accuracy

We take every reasonable step to ensure that:

  • your Personal Data that we Process are accurate and, where necessary, kept up to date; and
  • any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

(I) Data minimisation

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

(J) Data retention

We take every reasonable step to ensure that your Personal Data is only processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:

1.     we will retain Personal Data in a form that permits identification only for as long as:

(a) we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or

(b) your Personal Data are necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

1.     the duration of:

(a) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and

(b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

1.     in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

  • permanently delete or destroy the Relevant Personal Data; or
  • anonymize the Relevant Personal Data.

(K) Your privacy rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

  • the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, if you do not provide us with your Personal Data –g., we might not be able to process your requests without the necessary details);
  • the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
  • the right to request rectification of any inaccuracies in your Relevant Personal Data;
  • the right to request, on legitimate grounds:
    1. erasure of your Relevant Personal Data; or
    2. restriction of Processing of your Relevant Personal Data;
  • the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
  • the right to cancel a specific or service, please note that the cancellation will prevent you from using the full range of XCWIIE products and services. Cancellation may be prevented or delayed in certain circumstances. When you sign in through third-party account, you need to apply for cancellation of the account from the third party;
  • the right to request the deletion or removal of your Relevant Personal Data where there is no compelling reason for us to keep using it. Please note that we may not be able to immediately remove the information from the backup system due to applicable laws and regulations or technological limitations. If this is the case, we will isolate your Relevant Personal Data from nay further processing until the backup can be deleted or be made anonymous.
  • where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases).

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

· the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR; and

·  the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (N) below. Please note that:

  • in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
  • where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

(L) Terms of Service

All use of our Sites, Applications or services is subject to our Terms of Service. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

(M) Direct marketing

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites and Applications that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, Applications, products, or services. If we provide Sites and Applications to you, we may send or display information to you regarding our Sites, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Applications, products, or services you have requested.

You may unsubscribe from our promotional text list at any time by replying T via text message. After you unsubscribe, we will not send you further text message, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Applications, products, or services you have requested.

(N) Details of Controllers

For the purposes of this Policy, the relevant Controllers are:

Controller entity

Contact details

 ZhengZhou Dan Ying Ke Jue Shang Mao Co., Ltd.

No. 403 Kai Liguo Zhixin Road, Shoufeng Street, Yanqu Town, Zhengzhou City (Zhengdong New Area), Henan Province, China

 Shenzhen Zhongyong E-commerce Co., Ltd.

406, Building C, Wisdom Cloud Valley, No.1 Sanhe Road, Dalang Street, Longhua District, Shenzhen, China

(O) Representatives

Each of the controllers established outside the EEA and listed in Section (N) above has appointed Support Team to be its representative the purposes of Article 27 of the GDPR, where applicable.

Each of the controllers established outside the UK and listed in Section (N) above has appointed Support Team to be its representative the purposes of Article 27 of the UK GDPR, where applicable.

(P) Business information and links to other websites

Business information – In the course of using our Sites and Applications, we may ask you to provide business information related to the company where you work. Business information may include information about your company’s practices, policies, processes, and supporting documentation. This business information is stored on XCWIIE systems, and we use it to provide the solutions you have contracted us to provide and in accordance with the terms and conditions set forth in agreements between XCWIIE and your company,

Links to other websites – This Policy applies only to XCWIIE practices, technologies, and services. Our online properties may include links to websites and online services that are operated by other companies not under the control or direction of XCWIIE. If you provide or submit Personal Data to those websites or online services, the privacy policies on those websites or online services apply to your Personal Data. We encourage you to carefully read the privacy policies of any website you visit.

(Q) Analytics and Tailored Advertising

XCWIIE and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Regular Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. With respect to our web services you can stop all collection of information via a web service by not using that web service. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device or internet browser. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

You may opt-out of targeted advertising utilizing the Digital Advertising Alliance (“DAA”) AdChoices Program at optout.aboutads.info. For more information on the DAA AdChoices Program at visit www.youradchoices.com. In addition, the Network Advertising Initiative (“NAI”) has developed a tool that allows consumers to opt out of certain Tailored Advertising delivered by NAI members’ advertising networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see https://optout.networkadvertising.org/.

(R) Do Not Track

Most browsers can be set to send signals to third party websites requesting them not to track the user’s activities. At this time, we do not respond to “do not track” signals. Consequently, third parties may indeed track and collect information about your online activities over time while navigating to, from and on our online services, notwithstanding any “do not track” signals we may receive.

(S) California Consumer Privacy Act Disclosures

Under the California Consumer Privacy Act (“CCPA”), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of California Residents (“Consumers”). Consumers are also afforded additional rights with regard to the Personal Information we collect about them that include the rights of access, deletion, and to be free from discrimination. This section of our Privacy Policy includes the disclosures required by the CCPA and Section (T) below describes the rights afforded to Consumers. We also describe the methods by which a Consumer may exercise these rights and some of the statutory exceptions that may apply. This Section (S) applies to XCWIIE’s Sites.

 XCWIIE Sites

Collection of Personal Information

We have collected and will collect the following general categories of Personal Information about Consumers:

Use of Personal Information

We may use the categories of Personal Information described for the following business or commercial purposes:

 XCWIIE ’s Official Websites

·         Personal identifiers, including name, postal (billing) address, and email address;

·         Categories of personal information enumerated in specific law, such as Cal. Civ. Code § 1798.80(e), including telephone number, and last four digits of bank card number;

·         Protected classifications, including date of birth and national origin;

·         Commercial information, including records of products or services purchased; and

·         Internet or other electronic network activity information, including browsing history and search history on Uaikea’s sites.

·         Comply with applicable law and law enforcement requirements;

·         To advance a commercial or economic interest (such as by inducing another person to buy, join, subscribe to, or provide products, goods, property, information or services, or enabling or affecting, directly or indirectly, a commercial transaction) ;

·         Protect against malicious, deceptive, fraudulent or illegal activity;

·         Maintain or service customer accounts;

·         Provide customer service;

·         Process or fulfil orders and transactions;

·         Verify customer information;

·         Process payments; and

·         Provide advertising or marketing services.

Categories of Sources of Personal Information

We collect or obtain Personal Information about you on our Websites and Applications from the following sources:

  • Data provided to us by consumers and app users: We obtain Personal Information when it is provided to us (e.g., where you create an account, where you contact us via email or telephone, or by any other means, or when you submit a job application).

Disclosure of Personal Information

Our use of online tracking technologies may be considered a “sale” / “sharing” under California law and you have the right to opt out of these disclosures. Visitors to our US website can opt out of being tracked by these third parties by clicking the “Do Not Sell My Personal Information” link at the bottom of our website. We do not knowingly sell or share (for cross-context behavioural advertising) the Personal Information of consumers under 16 years of age. In the preceding 12 months, we have disclosed the following categories of Personal Information to the following categories of recipients:

Categories of Recipients

Categories of Personal Information

Advertising networks, data analytics providers.

· Personal Identifiers

Internet Service Providers

· Personal Identifiers; and· Categories of personal information enumerated in Cal. Civ. Code § 1798.80(e)

Vendors who may need access to your personal information to help us provide our services

· Personal Identifiers; and· Categories of personal information; enumerated in Cal. Civ. Code § 1798.80(e)· Internet or other electronic network activity information· Commercial Information

Payment processors

· Personal Identifiers; and· Categories of personal information; enumerated in Cal. Civ. Code § 1798.80(e)· Internet or other electronic network activity information· Commercial Information

The purposes for which we disclose personal information are described in more detail in Section (E) above.

Consumer Rights under the California Consumer Privacy Act

If you are a Consumer, the CCPA grants you the following rights regarding your Personal Information. Generally, in order to verify your requests to exercise your rights, we will compare the personal information we have about you to pieces of personal information we will request in the course of processing your request. The personal information required for verification may include your name, email address, phone number, or postal address. We will deliver a response to you within 45 days of receiving your verifiable consumer request. To exercise your rights under the CCPA, please follow the instructions described in this section.

Right to Know About Personal Information.

Consumers have the right to submit a verifiable consumer request that we disclose the following in a readily useable format, covering the 12 month period preceding the verifiable consumer request:

  • The categories of Personal Information we collected about you.
  • The purposes for which the categories of Personal Information collected about you will be used.
  • The categories of sources for the Personal Information we collected about you.
  • The categories of third parties with whom we share Personal Information.
  • Our business or commercial purpose for collecting Personal Information.
  • The specific pieces of Personal Information we collected about you.
  • The categories of Personal Information we have disclosed for a business purpose.

Verifiable consumer requests to know may be submitted through the following method:

  • email at: support@xcwiie.net

Right to Request Deletion of Personal Information.

Consumers have the right to request that we delete any Personal Information that we have collected from them. However, we are not required to comply with a request to delete where it is necessary for us to retain the Personal Information in order to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with legal obligations.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Verifiable consumer requests to delete may be submitted through the following method:

Right to Non-Discrimination.

Consumers have the right to be free from discrimination when they exercise their Consumer rights under the CCPA, and should you exercise those rights we cannot:

  1. Deny you goods or services.
  2. Charge you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties.
  3. Provide you a different level of quality of goods or services.
  4. Suggest that you may receive a different rate for goods or services or a difference level or quality of goods or services.

Right to Opt-out Selling or Sharing:

Consumers have the right to opt-out of the sale of your personal information or sharing of your personal information for cross-context behavioral advertising and can request that we stop by clicking “Do Not Sell My Personal Information”.

After opting out of the sale of your personal information or sharing of your personal information for cross-context behavioral advertising, you may still receive ads from XCWIIE, however they will not be tailored to you.

Notice of Financial Incentive.

We do not offer financial incentives or price or service differences to consumers who provide Personal Information.

Authorized Agent.

Under the CCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with a signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.

(T) California’s “Shine the Light” Law

Under California’s “Shine the Light” law, California residents are entitled to ask us for a notice describing what categories of personal customer information XCWIIE shares with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident, and would like a copy of this Policy, please submit a written request to  support@xcwiie.net.

(U) Contact Us or lodge a complaint

If you have questions or concerns with respect to our Privacy Policy or Practices, please read this Policy first. For additional questions, you may contact us at  support@xcwiie.net. Please note that we take your satisfaction very seriously. Should you have a complaint, please also direct it to the same email address and we will respond to you as soon as we can. You can of course also lodge a complaint with the data protection authority of the country in which you live.

(V) Definitions

  • Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
  • California Resident” means (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the state for a temporary or transitory purpose.
  • Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
  • Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
  • Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
  • EEA” means the European Economic Area.
  • GDPR” means the General Data Protection Regulation (EU) 2016/679.
  • Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
  • Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:
    1. Personal identifiers,
    2. Categories of personal information described in Cal. Civ. Code 1798.80(e);
    3. Characteristics of protected classifications under California or federal law;
    4. Commercial information;
    5. Biometric information;
    6. Internet or other electronic network activity information;
    7. Geolocation data;
    8. Audio, electronic, visual, thermal, olfactory, or similar information;
    9. Professional or employment related information;
    10. Education information; and
    11. Inferences for use in creating a consumer profile.
  • Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
  • Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
  • Relevant Personal Data” means Personal Data in respect of which we are the Controller.
  • Sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. A business does not sell personal information when:
    1. A consumer uses or directs the business to intentionally disclose personal information or uses the business to intentionally interact with a third party, provided the third party does not also sell the personal information, unless that disclosure would be consistent with the provisions of this title. An intentional interaction occurs when the consumer intends to interact with the third party, via one or more deliberate interactions. Hovering over, muting, pausing, or closing a given piece of content does not constitute a consumer’s intent to interact with a third party;
    2. The business uses or shares an identifier for a consumer who has opted out of the sale of the consumer’s personal information for the purposes of alerting third parties that the consumer has opted out of the sale of the consumer’s personal information;
    3. The business uses or shares with a service provider personal information of a consumer that is necessary to perform a business purposes if both of the following conditions are met:
    4. The business has provided notice that information being used or shared in its terms and conditions consistent with Section 1798.135 of the CCPA; and
    5. The service provider does not further collect, sell, or use the personal information of the consumer except as necessary to perform the business purpose; or

The business transfers to a third party the personal information of a consumer as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business provided that information is used or shared consistently with Sections 1798.110 and 1798.115 of the CCPA.

  • Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
  • Site” means any website operated, or maintained, by us or on our behalf.
  • Application means any applications operated, or maintained, by us or on our behalf.

Annex I Details of Processing

Processing activity and Processed Personal Data

Purposes

Legal basis for Processing

Provision of Sites or Applications: · IP address,MAC address of the requesting computer/ phones, · Date and time of access, · Name and URL of the accessed file, · Website from which access occurred (referrer URL), · Unique identifiers. · Browser used (incl. type, ID and configuration) and your computer’s or phone's operating system, if applicable, as well as the name of your access provider.

· To ensure we can provide a smooth connection to our Sites or Applications · To ensure users can comfortably use our Sites or Applications · To assess system security and stability · For further administrative purposes

Our legitimate interest to provide secure, needs-based Website.

Binding devices with Applications: · Wi-Fi and Bluetooth data · location permission to automatically fill in your Wi-Fi network during the setup of the device · Usage data: device and App log files, settings (including settings history), usage history, device and service settings, and device status

· To ensure users can use our Applications to connect, control and operate the XCWIIE products you have purchased. · Implementation of the Product warranty claim

· The Processing is necessary for entering or performing a contract with you. or · The Processing is based on your consent.

Contacting us: -Via e-mail, the contact form or feedback form · E-mail address · Information provided by you to contact us (such as contents of your message) -Via phone: · Phone number · Information provided by you to contact us (such as contents of your message, name) -Via mail: · Name · Address · Information provided by you to contact us (such as contents of your message)

· Processing of your request · Performance of the communication · Analyzing errors and improving our services

Depending on the reason you are contacting us: · The Processing is necessary for entering or performing a contract with you. or · Our legitimate interests in Processing your request and performance of the communication.

Notification of changes, product security communications and product recalls: · Name · E-mail address · Name and title · Address (including region) · Phone number · Information about the communication we made to you and any following communications.

· Informing you about changes or security communications · notification of the need for a product recall and the manner in which such a recall will be conducted

Depending on the reason you are contacting us: · The Processing is necessary to fulfil a legal obligation, or · The Processing is necessary for performing a contract with you. or Our legitimate interests in informing you about a change or security communication.

Comments and opinions, if they are expressed directly to us: · communications data, depending on the way of contact (see above) · Your comments and opinions.

· Responding to and address your queries, issues and concerns, · Improving our products and services · Informing our marketing strategies

Our legitimate interests, namely communicating with current or prospective customers and others about our products and services.

Contract data (via our Sites or Applic ations): · Name · E-mail-address · Address (including region) · Phone number · If applicable: Deviating delivery address· Payment information · Promotion code

· Processing your order · Fulfilling the contract · Communicating with you about our products and services, · Enabling you to utilize our products and services ·Responding to any queries, issues or concerns you may have

The Processing is necessary for entering or performing a contract with you.

Express checkout (via ShopPay): · Name · E-mail-address · Address (including region) · If applicable: Deviating delivery address· Payment confirmation · Promotion code

· Processing your order · Fulfilling the contract · Communicating with you about our products and services, · Enabling you to utilize our products and services ·Responding to any queries, issues or concerns you may have

The Processing is necessary for entering or performing a contract with you.

Express checkout (via PayPal): · Name · E-mail-address · Address (including region) · If applicable: Deviating delivery address · Payment confirmation · Promotion code

· Processing your order · Fulfilling the contract · Communicating with you about our products and services, · Enabling you to utilize our products and services · Responding to any queries, issues or concerns you may have

The Processing is necessary for entering or performing a contract with you.

Express checkout (via GooglePay): · Name · E-mail-address · Address (including region) · If applicable: Deviating delivery address· Payment confirmation · Promotion code

· Processing your orders · Fulfilling the contract · Communicating with you about our products and services, · Enabling you to utilize our products and services ·Responding to any queries, issues or concerns you may have

The Processing is necessary for entering or performing a contract with you.

Payment and Transaction Information: Klarna: · You will be redirected to Klarna to complete your purchase. We will only receive payment confirmation. · Transaction-related information (i.e., payment date, amount.) PayPal: · You will be redirected to PayPal to complete your purchase. We will only receive payment confirmation. · Transaction-related information (i.e., payment date, amount.) Credit Card: · Name of the card holder · billing address · We will only receive the last four digits of the credit card number · Transaction-related information (i.e., payment date, amount.)

· Receiving renumeration that we are owed · Implementation of the contract concluded with you

The Processing is necessary for entering into or performing a contract with you.

Newsletter: · Email · Tracking information (open and click rates)

· Informing you about new developments concerning XCWIIE, our products, services and promotions · Insight into what content is of interest to you to improve our newsletter ·Advertising our products and services

· The Processing is based on your consent, or, where we have obtained your email address in the course of you ordering our services, · based on our legitimate interest in sending you offerings to products/services similar to the ones you have purchased from us.

Displaying advertisements: · IP address of the requesting computer, · Date and time of access, · Name and URL of the accessed file, · Website from which access occurred (referrer URL), · Unique identifiers. · Browser used (incl. type, ID and configuration) and your computer’s operating system, if applicable, as well as the name of your access provider · Interests, based on the use of our services and Sites/ Applications and the information provided by our ad-network partners. For more information about advertising and tracking, please also see our Cookie Notice.

· Informing you about new developments concerning XCWIIE, our products, services and promotions · Advertising our products and services

Insofar as the Processing is aimed at tailoring our advertisements to your interests, · The Processing is based on your consent. Otherwise, · The Processing is based on our legitimate interests, namely to market and advertise our products and services.

Analyzing trends, usage and activities: · IP address of the requesting computer or phones, · Date and time of access, · Name and URL of the accessed file, · Website from which access occurred (referrer URL), · Unique identifiers. · Browser used (incl. type, ID and configuration) and your computer’s operating system, if applicable, as well as the name of your access provider · Heatmaps · Session recordings · Website to which you leave our Site · Items viewed, actions performed during a browsing session

· Analyzing trends, usage and activities · Improving our services · Tailoring our advertisements · Insight into what content is of interest to you ·Analyzing errors and improving our services

The Processing is based on your consent.

Maintaining IT security (including audits): · IP address of the requesting computer or phones, · Date and time of access, · Name and URL of the accessed file, · Website from which access occurred (referrer URL), · Unique identifiers. · Browser used (incl. type, ID and configuration) and your computer’s operating system, if applicable, as well as the name of your access provider · Behavior while using our Sites, products and services.

· To ensure users can comfortably use our Sites, products and services · To assess system security and stability · Finding and eliminating security vulnerabilities · Monitoring and demonstrating of our safety level, also to achieve external certifications

· The Processing is necessary for entering or performing a contract with you. or · Our legitimate interests in ensuring the safety of our Sites, products and services.

Visiting our premises: · Name and title · Address · Phone number · E-mail-address · Date and time of your visit

· Providing access to our Site · Ensuring the security of our Site.

The Processing is necessary for entering or performing a contract with you.

Surveys: · Name and title · E-mail-address · Your responses

· Analyzing errors and improving our Sites, products and services · Obtaining customer feedback

Our legitimate interests in obtaining customer feedback and improving our Sites, products and services.

Creating user account: · Email · Password · Orders · Addresses · E-mail-preferences Via Google/ Facebook/Wechat /Apple/ Amazon account: · Login information: logging in using a Google account, Facebook account, Wechat account, or Apple account · Profile picture of the linked Google, Facebook, Wechat, Apple or Amazon account

· Provision of a user account, with address management, order overview · Organization of the email-preferences · Security of the account · Evaluation of our users

The Processing is necessary for entering or performing a contract with you.

Product reviews: · Name (public) · E-mail-address · Rating, including headline and description · Photos (optional) · Videos (optional) · Youtube-URL (optional)

· Publishing product reviews · Obtaining feedback on products · Advertising our products and services.

The Processing is based on your consent.

Quizzes, including Electricity Cost Calculator, Balcony power plant quiz:· · Technical data, as described above under "Provision of Sites" · Your answers to the relevant questions

· Providing you with the relevant quizzes and answers. · Advertising our products and services.

Our legitimate interests in providing you with quizzes and advertising our products and services.

Shipment tracking: · Order Number · Email or Phone number Or · Tracking Number

· Providing shipment tracking

Our legitimate interest in providing you with shipment tracking.

Become a partner: Trader · Company name · Countries supplied · Gross sales volume · Sales tax number · Website links · Business social media profile · Type of company · Main category of the company · Employees of the company · Contact name · Contact title · Contact e-mail address · Contact phone · How do you know XCWIIE Affiliate program · Affiliate program partner contact information Information about customers and purchases through the affiliate link

· Determining whether we want to engage in a business relationship with you or your company · Conducting the business relationship · Orderly accounting· Increasing sales of our products and services

· The Processing is necessary for entering or performing a contract with you, or, where the relevant contract is with your company, · Our legitimate interest in deciding on and engaging in a business relationship with your company

Corporate purchase program: · Contact name · Contact E-mail-address · Required product and quantity · Reason for purchase · Shipping address · Desired delivery date Phone number

· Determining eligibility to participate in our corporate purchase program · Conducting the business relationship

The Processing is necessary for entering or performing a contract with you

Refer friends: If you refer a friend · Name · Email · Purchases made though link · Information about rewards If a friend refers you: · Your Personal Data is Processed as shown above · Purchases are attributed to the link you were invited with

· Increasing sales of our products and services · Enabling participation in our refer a friend program · Paying out rewards for participation in the program

Our legitimate interest in advertising our products through a refer a friend program.

Discount networks (e.g., Studentbeans):· · Authorization to use the discount · Personalized discount codes · Purchased products

· Enabling a discount for faculty and students. · Improving the sale of our products to these groups

Our legitimate interest in advertising our products through special discount codes.

Warranty application: · E-mail-address · Name · Order number · Address · Phone number · Description of defect · File or purchase receipt Purchases via Amazon · Amazon purchase website · E-mail-address · Name · Order number · Product description · Model number · Serial number (or photo of product containing XCWIIE logo) · Address · Phone number · Description of defect

· Verification of the warranty claim · Implementation of the warranty claim · Documentation of the defect

The Processing is necessary for entering or performing a contract with you

Live Chat with Support: · Name · E-mail address · Contents of the chat

· provision of the live chat · security of the live chat · feedback on and improvement of our products

· The Processing is necessary for entering or performing a contract with you or · Our legitimate interest in providing a live chat.

Product verification: · Product security code · Captcha

· Ensuring that the product is original · Combating counterfeit products

· The Processing is necessary for entering or performing a contract with you or · our legitimate interest in providing a way to verify the authenticity of products and fight counterfeiting

Community Forum: · Profile name · Posts (including if they are edited), and anything contained therein, such as pictures · Community level · Warnings

· Providing a forum for discussion of our products · Support for engagement in this forum · Ensuring compliance with the terms of the forum

The Processing is necessary for entering or performing a contract with you

Digital showroom(Live Stream): · Email Address when users opt-in

· Send discount codes

The Processing is based on your consent.

1V1 Video Shopping: · Device type · Browsing history · Recipient information provided by users, such as name, contact number, and delivery address. · Session length · Video recording · Chat history

· Processing your orders

· Enhance our services

· The Processing is necessary for entering or performing a contract with you, and/or · The Processing is based on your consent.

Testing Club: · Name · Email · Test plan · Social media profiles · Product reviews, including photos and videos. Survey (if test requires so).

· Review of applications and selection of suitable testers · Provision of free products for testing · Obtaining reviews of the products · Improvement of the test products · Promotion of the products to be tested

· The Processing is necessary for entering or performing a contract with you Or · The Processing is necessary for our legitimate interest in improving and promoting our products.

Legal: · All of the above

· Complying with regulatory obligations · Litigation · Exercise, enforcement and defense of claims

· The Processing is necessary for our legitimate interest in compliance with regulatory obligations, and exercising, enforcing and defending of claims.