Privacy Policy

Last Updated: October 28, 2025

When you use our Services, you may provide certain information to us.

• Account and profile: When you create an account or profile with us, we collect your name, email address, password or verification code. We also collect your country/region and language preference.
• Newsletter subscriptions: When you subscribe to our newsletter, we collect your email address, to send you updates, news, and other information about our products and services. You may unsubscribe from our newsletter at any time by following the instructions included in our emails or by contacting us directly.
• Live chat communications: When you use the live chat feature on our website, we collect the content of your communications and related information.
• User Reviews: When you post a review or comment on our website, we collect the information you provide, including your name (or display name), the content of your comment, and the time it was submitted. Please note that the information you post may be publicly visible to other users.
•  Information when you contact us: When you contact us through our website, email, or other communication channels, we collect the information you provide, such as your name, email address, phone number, and the content of your message or inquiry. We use this information to respond to your requests, provide customer support, and improve our Services.
•  Other data not explicitly listed above: We will collect other data that you provide for purposes as described in this Privacy Policy, or for any other purpose disclosed to you at the time we collect your information.

In addition to the information you provide directly, we automatically collect personal information about your use of our Services through software on your devices and other technological means.

•  Device and Connection Information: We collect your IP address, browser type and version, operating system, and unique identifiers associated with your device or browser. These identifiers may include a universally unique identifier (uuid), a browser ID (bid), a client ID (cid used by Google Analytics), or a Facebook browser ID (fbp).
• Usage and Interaction Information: We collect data about your interactions with our Services, including pages viewed, links clicked, search queries, time spent on pages. We may also collect diagnostic and performance information (e.g., crash reports, log files, and error data) to maintain and improve our Services.
• General location Information: We may infer your general geographic location from your IP address to provide localized content and comply with regional requirements.
•  Cookies and Similar Technologies: We use cookies and similar tools to collect and store information about your interactions with our Services. Some cookies are essential for basic site functionality, while others are used to analyze usage or personalize content. For more details, please refer to the section on Cookies and Similar Technologies below and our Cookies Notice.

We may receive information about you from other sources.

•  Marketing and Advertising Partners: Information such as advertisement clicks, responses to marketing emails or promotions, device data, and audience information, provided under lawful sharing agreements to help us improve and personalize our Services.
• Analytics Providers: Data about your interactions with our websites and Services (e.g., via Google Analytics, Firebase, Adobe Analytics) to analyze usage, improve Services, and diagnose technical issues.

We may combine information received from third-party sources with personal information we collect directly. Such combined information is treated as personal information under this Privacy Policy.

We may also collect de-identified data, which cannot reasonably identify you or your device. Use and disclosure of de-identified data is unrestricted under this Privacy Policy.

When you register for or use our Services, we process personal information necessary to perform the contract between you and us, including:

• Account creation and maintenance: To create and manage your account, maintain security features, and enable access settings according to your preferences.
• Customer support: To respond to inquiries, resolve disputes, and provide support regarding your account or use of the Services.
• Communication: To send administrative messages, updates, or security alerts necessary for the functioning of the Services.

We may process personal information to pursue our legitimate interests or those of third parties, provided that your rights and freedoms are not overridden. This includes:

• Platform security and safety: Detecting, preventing, and responding to unauthorized, harmful, or unlawful activities, including cyberattacks or identity theft.
• Service improvement and optimization: Analyzing usage patterns, diagnosing technical issues, improving performance, and enhancing the user experience.
• User interactions and content publication: Making user-generated content available, facilitating interactions between users, and notifying relevant parties of interactions (e.g., likes or comments).
• Marketing and personalized content: Recommending relevant content, promotions, or on-platform interest-based advertising in accordance with your settings.
• Retention for legal purposes: Retaining certain information to defend legal claims or comply with regulatory requirements.
• Handling complaints and exercising rights: Processing information to respond to Data Subject rights requests or complaints.

• With your consent, we may process personal information for purposes such as:
• Direct marketing and communications: Sending promotional or newsletter content according to your preferences.
• Off-platform interest-based advertising: Providing personalized advertising outside of our Services.

We process personal information to comply with applicable laws, regulatory requirements, or legal processes, including:

• Responding to governmental or regulatory requests.
• Detecting and preventing fraudulent or illegal activities.
• Protecting the rights, safety, or property of our users, ourselves, or others.

We may share your personal information with our subsidiaries, and affiliates within the UGREEN corporate group, as necessary to support the operation, management, and improvement of our Services. This includes purposes such as internal administration, IT and security support, compliance, and analytics.

All entities within our corporate group are required to process your personal information in accordance with this Privacy Policy and applicable data protection laws.

We engage carefully selected third-party service providers to perform services on our behalf and to support the operation of our business. These providers are only permitted to process personal information as necessary to provide their services to us and are bound by contractual confidentiality and data protection obligations.

Examples of such providers include:

• Cloud hosting and infrastructure providers (e.g., Amazon Web Services) for secure data storage and site operation.
• Customer support platforms (e.g., Zendesk, QuickCEP) to facilitate communications and resolve user inquiries.
• Analytics providers (e.g., Google Analytics, Microsoft Clarity) to help us understand usage patterns and improve our Services.
• Security and performance partners (e.g., Cloudflare) to protect our Services from unauthorized access and abuse.
• Email and communication providers to deliver administrative or service-related messages.

We may share limited personal information with marketing and analytics partners to measure the effectiveness of our campaigns and improve communications with users. These partners process information such as website interactions, engagement metrics, or cookie identifiers to help us evaluate and enhance our Services.

For more details, please see our Cookie Notice.

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be disclosed to the acquiring or successor entity as part of the transaction. If such a transfer occurs, we will ensure that the receiving entity continues to protect your information consistent with this Privacy Policy and applicable data protection laws.

We may also share information with public authorities, regulators, or law enforcement agencies:

• To comply with applicable laws, lawful requests, or court orders.
• To protect the rights, property, and safety of our company, users, or others.
• To prevent, investigate, or respond to suspected fraud, security incidents, or illegal activity.

We may share your personal information with third parties when you have given your explicit consent or requested that we do so—for example, when you interact with a third-party feature or share content to an external platform. In such cases, the third party’s own privacy policy will govern your interactions with them.

You have the right to obtain confirmation as to whether we are processing your personal information. You may request access to your personal information and receive details about its collection, use, disclosure, and retention. You may also request a copy of your personal information in a structured, commonly used, and machine-readable format (data portability).

You may request that we correct or update any inaccurate or incomplete personal information we hold about you.

You may request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected, if you withdraw consent where consent is the basis for processing, or if the processing is otherwise unlawful. Certain information may not be deleted if required to comply with legal obligations or for legitimate business purposes.

You may request that we limit the processing of your personal information in specific circumstances, including if you contest the accuracy of your personal information, if processing is unlawful but you oppose deletion, if we no longer need the personal information but you require it to establish, exercise, or defend legal claims, or if you object to processing based on legitimate interests while we assess your objection.

You have the right to object to the processing of your personal information in the following circumstances:

• Processing based on legitimate interests or public interest;
• Processing for direct marketing purposes, including profiling related to marketing;
• Automated decision-making, including profiling, that produces legal or similarly significant effects.

If you object, we will stop processing your personal information for these purposes unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

Exercising this right for marketing purposes includes the ability to unsubscribe or opt out from promotional emails, text messages, push notifications, and other marketing communications. You can manage your preferences at any time through your account settings, the links provided in our communications, or by contacting us directly.

For automated decision-making, you may request human intervention, express your point of view, and seek review of such decisions.

If processing of your personal information is based on your consent, you may withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.

You may opt out of receiving marketing communications by email, SMS, push notifications, or messaging applications. You may also adjust your preferences for cross-device tracking, cookies, and other similar technologies used for marketing or analytics purposes.

You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information violates applicable data protection laws.

To exercise any of these rights, you may submit a request by contacting us through the details provided in the “Contact Us” section of this Privacy Policy. We may require additional information to verify your identity or to authorize an agent acting on your behalf.

If you are a California resident, this section provides additional information under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).

14.1.1 Categories of Personal Information collected

We may collect (and may have collected during the 12-month period prior to the effective date of this Privacy Policy) the following categories of personal information about you:

We process limited sensitive personal information only for permitted purposes (e.g., to ensure account security) and do not use it to infer characteristics. You may request to limit certain uses as described below.

14.1.2 Sales or Sharing of Personal Information

Under the CCPA, “sharing” refers to targeting advertising to a consumer based on personal information collected from that consumer’s activity across websites, while “selling” refers to disclosing personal information to third parties in exchange for monetary or other valuable consideration. We may “share” personal information to deliver more relevant and personalized advertising about our Services. Although we do not sell our customers’ personal information for monetary gain, the use of third-party analytics and online advertising services may involve the sharing of online identifiers (such as cookie data, IP addresses, device identifiers, and usage information) in a manner that could be considered a “sale” under the CCPA.

For more details about how we disclose or share personal information, please refer to the sections “Personal Information We Collect” and “How We Share Your Personal Information” in this Privacy Policy.

To opt out of “selling” or “sharing” of personal information for targeted advertising, please contact us using the methods listed in the “Contact Us” section or adjust your preferences via the Cookie Settings tool.

14.1.3 Your rights

If you are a California resident, you have certain rights under the CCPA and the CPRA. These rights, subject to certain legal limitations, include:

• Right to Know. You have a right to request the following information about our collection, use and disclosure of your personal information over the prior 12 months, and ask that we provide you with a copy of the following: categories of and specific pieces of personal information we have collected, sold or shared about you; categories of sources from which we collect personal information; the business of commercial purposes for collecting personal information; categories of third parties to whom the personal information was disclosed for a business purpose; and categories of personal information disclosed about you for a business purpose.  
• Right to Correct. You have a right to request that we correct inaccurate personal information maintained about you.
• Right to Delete. You have a right to request that we delete personal information, subject to certain exceptions.
• Right to Opt out of Selling or Sharing. You have the right to direct a business that sells or shares personal information about you to third parties to stop doing so.  
• Right to Restrict Use of Sensitive Personal Information. You have a right to request that we limit our processing of sensitive personal information under certain circumstances.
• Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA.

To exercise your privacy rights, you may submit a request through the methods provided in the Contact Us section.

If you are located in the European Economic Area (“EEA”), this section provides additional information under the EU General Data Protection Regulation (“GDPR”).

14.2.1 Data Controller and Contact Information

For the purposes of the Services, Ugreen Group Limited acts as the data controller for personal information collected through our website and related online services.

If you have any questions about our processing of your personal information, or to exercise your rights under the GDPR, you may contact us using the following details:

Email: DPO@ugreen.com 

Address: 4/F,Plant 6,1F-6/F,Block 7, YuAn Zone 

Gaofeng Community, Dalang Street, Longhua District, Shenzhen, China

You can reach our Data Protection Office at: DPO@ugreen.com

14.2.2 Legal Bases for Processing

We process personal information only when we have a valid legal basis under the GDPR. These include:

• Performance of a contract: To create and manage your account, provide Services, and respond to your inquiries.
• Legitimate interests: To maintain security, detect and prevent fraud, analyze usage, improve Services, and provide relevant communications.
• Consent: When required, such as for marketing communications, newsletters, or non-essential cookies. Consent may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal.
• Legal obligations: To comply with applicable laws, regulatory requirements, or lawful requests from authorities.

For more details, please refer to the section “Personal Information We Collect” and “Why We Collect Your Personal Information and Our Legal Bases for Processing”.

14.2.3 International Data Transfers

Your personal information may be transferred to countries outside the EEA where data protection laws may differ from those in your jurisdiction. When we do so, we ensure appropriate safeguards are in place, including the European Commission’s Standard Contractual Clauses or other lawful transfer mechanisms recognized under the GDPR. You may contact us for more information about these safeguards.

14.2.4 Your Rights under the GDPR

Subject to applicable law, you have the following rights regarding your personal information:

• Right of Access: You may request confirmation of whether we process your personal information and obtain a copy of such data.
• Right to Rectification: You may request that we correct inaccurate or incomplete personal information.
• Right to Erasure (“Right to be Forgotten”): You may request deletion of your personal information when it is no longer necessary for the purposes for which it was collected, when consent is withdrawn, or when processing is otherwise unlawful. Certain information may not be deleted if required to comply with legal obligations or legitimate business purposes.
• Right to Restrict Processing: You may request that we limit the processing of your personal information under certain circumstances.
• Right to Data Portability: If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used, and machine-readable format, and to have us transfer your personal information directly to another “controller,” where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
• Right to Object: You may object to the processing of your personal information based on legitimate interests or for direct marketing purposes, including profiling related to marketing.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

You may submit requests through the contact details provided in the “Contact Us” section of this Privacy Policy. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).

Requests will be handled in accordance with the GDPR, generally within one month of receipt. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

You also have a right to lodge a complaint with a competent supervisory authority situated in the country of your habitual residence, place of work, or place of alleged infringement. You can find the relevant supervisory authority name and contact details for the EEA here.