Issue Date: 2023/1/14

Effective Date: 2023/1/14

Summary

Ugreen Japan Co.,Ltd. (hereinafter referred to as "we") understands the importance of your personal information, and this summary is intended to show you indirectly and clearly how we handle and protect your personal information. If you need further information, please read the full UGREEN Privacy Policy.

How we collect and use your personal information
Account Data: When you register or login to our account, you need to provide us with at least an cell phone number(Users in Chin) oran E-mail address( Users not in China).We will desensitize your cell phone number or your the E-mail address. If you refuse to provide your cell phone number or E-mail address, you will not be able to complete registration, log in to and use UGREEN normally; on the other hand, you can create an account and use UGREEN by using a quick login with a third party login. You can also choose to provide us with your nickname, gender, motto, and custom avatar information to enrich your account information.
Third party login account data: If you choose to authorize the use of third party account login (QQ/Wechat/ Facebook/ Apple ID) for quick login, we will obtain your shared account information (avatar, nickname) from the third party. We will use your personal information in accordance with the agreement with the third party and the terms of the third party's published privacy policy regarding the sharing of personal information and in compliance with relevant regulations. If you refuse to provide authorization, you will not be able to use your third party account to log into UGREEN.
UGREEN app connects to UGREEN smart device data: When you use UGREEN software to connect to UGREEN smart devices, we will collect your location information, Wi-Fi list information, Bluetooth information with your permission to help you realize the connection between your phone and the device, and the control of your phone to the device. Once connected, you can monitor your device's operating status and control it remotely via UGREEN. This is the core function of UGREEN, if you choose not to provide the above information, you will not be able to use this core function.
Feedback: When you provide feedback to us through the "Help Center - Feedback", you need to provide your feedback content (required), optional pictures, videos, contact information (WeChat/QQ/cell phone number/ E-mail address). If you do not provide feedback content, you will not be able to submit feedback; After we receive your feedback, we will reply to you through the contact information you provide. If you refuse to provide contact information, we will not be able to respond to you, and can not deal with your problems and device failure for you. If you do not provide pictures, videos, you may not be able to well illustrate the problem of your feedback.
Information on permissions requested for use in providing services.

In order to provide services to you, we will ask you to obtain the following permissions: access camera album permissions, network permissions, storage permissions, Bluetooth permissions, geolocation permissions, system settings permissions, and update and install applications permissions. If you do not agree to grant the above permissions, you will not be able to use the functions associated with the permissions, but it will not affect your use of other functions. Special Note: We only get the permission to read and do not collect or use the content of your local files, nor do we make any modification or editing to the above content.

II.How you manage your personal information

You can click "Settings-Personal Center-Account Security" in the upper left corner of UGREEN app to manage your personal information, including inquiry, correction, withdrawal, deletion of your personal information, and cancellation of your account.

If you encounter problems in managing your personal information, you may contact us. However, please also understand that we may not be able to fully comply with your request due to compliance with legal and regulatory obligations or the necessity of the services we provide.

III. How we share your personal information

Please be aware that some parts of the products/services we provide to you cannot be done alone, so we may share or entrust some of your personal information with third parties such as our partners, and we will take the necessary technical and administrative measures to protect the security of your personal information as much as possible. For a list of the personal information we share, please click on "List of Third Party Information Sharing" to review.

Our protection of personal information of minors

Our products and services are primarily intended for adult users. If you are a minor under the laws of your country or region, please ensure that your parent or guardian reviews this Policy thoroughly. We require that you use our services or share information with us only with the explicit consent of your parent or guardian.Once a child's personal data is collected with parental consent, we will use or disclose it only as explicitly agreed by the parent or guardian, in compliance with applicable laws, or when necessary for the child's protection.If a guardian believes we have collected a minor's personal information without consent, please contact us through the contact information in Article 5 of this policy, and we will delete the relevant data promptly upon request.

Contact us

You can contact us in any of the following ways.

We have established a dedicated personal information protection team and person in charge. If you have any questions, comments or suggestions regarding this policy or our services, you can contact us at:

1. you can contact us through the "Feedback" on the UGREEN app, the approach: Settings - Help Center - Feedback.
2. Send an email to the person in charge of personal information protection: cnfw@ugreen.com (contact email).

UGREEN Privacy Policy

Application name: UGREEN

The basic function of this app is "monitoring and remote control of the operation status of the device after connecting to the UGREEN smart device with the UGREEN app." This app requires an email address to log in, and after logging in and associating the device, you can use its functional services.

UGREEN is a product and service provided by Ugreen Japan Co.,Ltd. (hereinafter referred to as "UGREEN" or "we", with registered office at No.205, Seijo 1-26-9, Setagaya-Ku, Tokyo, Japan). It is our obligation to protect your personal information and we will provide adequate protection for your personal information in accordance with legal and regulatory requirements. To this end, we have developed the UGREEN Privacy Policy ("Policy") to help you understand how we handle your personal information and your rights during your use of UGREEN hardware, firmware and application(app).

Before you interact with our UGREEN products, please make sure you read this Privacy Policy (especially those marked in bold) carefully and understand the purposes and security measures we use to process your personal information, including how we collect, use, store, share and transfer your personal information. In this policy, you can use our tips to enforce your rights related to your personal information, such as the right of inquiry, the right of deletion, etc.

At the same time, you have the right to refuse to agree to this policy, but please know that if you choose to refuse, you may not be able to fully use the relevant services and functions of UGREEN, or to achieve the results of our intended services. Your consent to this Privacy Policy means that you understand the functions provided by the application and the necessary personal information required for the operation of the functions, and give the corresponding authorization to collect and use, but it does not mean that you have separately agreed to open additional functions, processing of non-essential personal information, the opening of the relevant additional functions, processing of non-essential personal information and handling of sensitive personal information, we will seek your consent separately according to your actual use. During the reading process, if you have any questions, comments, suggestions or complaints, please contact us through the contact information in Article 9 of this policy.

This policy describes.

How we collect and use your personal information
How we share, transfer and publicly disclose your personal information

III. How you can exercise your rights

IV.Protection of personal information of minors

Data Retention Period
How your personal information is transferred globally

VII.Safety and security measures

VIII. Statement on policy changes

I. How we collect and use your personal information

1. Definition

Personal information: all kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding information after anonymization.

Smart device: It is a non-standard computing device produced or manufactured by hardware manufacturers that can transmit information through wireless networks, such as UGREEN smart devices.

Application: means a mobile application provided by Ugreen Group Limited that helps the end user (you) remotely control smart devices and connect to the Internet of Things (IoT) platform of the provider Aliyun Computing Co., Ltd..

2. The types of personal information we collect and the purposes for which it is used

In the course of your use of the UGREEN Services, UGREEN collects information that you voluntarily provide when using the Services or as a result of your use of the Services in order to provide you with the Services, to optimize our Services, and to protect your account security in the following ways.

（1） Information you voluntarily provide to us, purpose of use

Account Data: When you register or log in to our account, you will need to provide us with at least your cell phone number( User in China) or an E-mail address (Users not in China). We will desensitize your cell phone number or your E-mail address. If you refuse to provide your E-mail address or your cell phone number, you will not be able to complete the registration, login and use UGREEN normally;on the other hand, you can create an account and use UGREEN by using a quick login with a third party login. You can also choose to provide us with your nickname, gender, motto, and custom avatar information in order to enrich your account information.
Third party login account data: If you choose to authorize the use of third-party account login(QQ/ Wechat/ Facebook/ Apple ID), we will obtain your account information (avatar, nickname) from the third party. We will use your personal information in accordance with the agreement with the third party and the terms of the third party's published privacy policy regarding the sharing of personal information and in compliance with relevant regulations. If you refuse to provide authorization, you will not be able to use your third-party account to log into UGREEN.
UGREEN app connects to UGREEN smart device data: When you use UGREEN software to connect to UGREEN smart device, we will collect yourlocation information, Wi-Fi list information , Bluetooth information with your permission to help you connect your phone to your device and control your phone to your device. Once connected, you can monitor your device's operating status and control it remotely through UGREEN. This is the core business function of UGREEN, if you choose not to provide the above information, you might not be able to use this core function.
Feedback: When you feedback to us through the "Help Center - Feedback", you need to provide your feedback content (required), optional pictures, videos, contact information (QQ/ Wechat/cell phone number/ E-mail address). If you do not provide feedback content, you will not be able to submit feedback; if we receive your feedback, we will reply to you through the contact information you provide. If you refuse to provide contact information, we will not be able to respond to you, and can not deal with your questions and device failure for you. If you do not provide pictures, videos, you may not be able to well illustrate the problem of your feedback.
Invoked mobile device permissions (Checklist of System Rights Management)

UGREEN Cloud may request certain permissions to provide services.

Rest assured that UGREEN will not activate these permissions by default. Only if you approve and confirm to grant those permissions will UGREEN use them to collect your data, which will only be used in the necessary contexts specified.It is worth noting that granting UGREEN a specific permission does not necessarily mean your data will be collected. Although you have granted such permissions to UGREEN, your data will only be collected under lawful, valid, and necessary circumstances.Refusing to grant permissions may lead to the unavailability of specific features reliant on said permissions, but that will not affect you using other UGREEN features.

Permission Type	Usage scenario or purpose	Turning on permissions ask(Yes/No)	Is it possible to turn off permissions (Yes/No)	Impact of closure	Mobile OS
Camera	Need to get your camera permission: using the camera within the App, avatar upload/replacement, question feedback	Yes	Yes	Avatar upload/replacement, camera not available when question feedback	Android iOS
Albums	Retrieve your selected pictures/videos from your phone album for picture upload/replacement to avatar and question feedback	Yes	Yes	Unable to read the picture/video information in your phone album to upload to the avatar and problem feedback	Android iOS
Network (Traffic/Wi-Fi)	Mobile traffic/Wi-Fi to connect App and UGREEN smart devices	Yes	Yes	Unable to connect App and UGREEN smart devices	Android iOS
Bluetooth	The phone searches for a nearby UGREEN smart device via Bluetooth and pairs with the device to connect	Yes	Yes	Unable to search and connect to UGREEN smart devices	Android iOS
Storage Space	App reads picture/video information from phone storage space; App writes picture/video information to phone storage space	Yes	Yes	Unable to store, select photo/video information	Android iOS
Location	Works with Bluetooth and Wi-Fi to get a list of Bluetooth devices and Wi-Fi names, as well as for determining the server's region	Yes	Yes	Unable to get the list of Bluetooth devices and Wi-Fi names, unable to correctly determine the user's region to assign to the corresponding server	Android iOS
System Setup	Set Bluetooth and Wi-Fi on status	Yes	Yes	Unable to turn on Bluetooth and Wi-Fi, thus making it impossible to connect to UGREEN smart devices	Android iOS
Update and install applications	Update APP application	Yes	Yes	Unable to update the app, resulting in known app issues that cannot be fixed	Android iOS

Please note that by turning on any of the permissions, you authorize us to collect and use the relevant personal information to provide you with the corresponding services, and by turning off any of the permissions, you cancel your authorization, and we will no longer collect and use the relevant personal information based on the corresponding permissions, nor will we be able to provide you with the services corresponding to the permissions. However, your decision to close the permission will not affect the collection and use of information based on your authorization.

For an itemized list of the relevant business functions that may open your mobile device access rights, please refer to the Checklist of System Rights Management.

（2） Information we collect automatically, purpose of use

Mobile device information: Inorder to bind UGREEN smart devices and ensure the stability and security of the software system, we will get your phone model, brand, OS version, ROM version and screen resolution. If you refuse to provide it, we will not be able to connect your cell phone to the device and send the device information to your phone.
Log information: When you use our application, system and exception logs are uploaded, including your IP address, the language used, the version of the operating system, and the date or time of access.

（3） Information about UGREEN smart devices

Basic information of UGREEN smart devices: When you use UGREEN to connect UGREEN smart devices, we collect basic information about the devices, including device name, device ID, firmware version and upgrade information, activation time,online status, and system language, for the app to connect to the devices, display device usage information, and update and upgrade thedevice firmware. In order to implement pushing device usage information to users, we need to collect device identifiers (IMEI, IDFA, Android ID, MAC, OAID, Advertising ID, Serial Number, IMSI, UAID, ICCID), device platform, and device vendor information. If not collected, users will not be able to receive device usage information.
Information reported by UGREEN smart devices:We collect information reported by smart devices when you use UGREEN software to connect to the smart devices we serve.
Device identifier information:UGREEN software is developed based on DCloud uni-app (5+ App/Wap2App), which needs to collect your device identifier (IMEI/android ID/DEVICE_ID/IDFA, SIM card IMSI information, OAID) during application operation to provide statistical analysis service. And UGREEN software improves performance and user experience through application launching data and abnormal error log analysis to provide better service for users.

Please note that separate device information and service log information cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information will be treated as personal information during the period of combined use, and we will anonymize and de-identify such information unless we obtain your authorization or unless otherwise required by law or regulation.

Please refer to the Checklist of Personal Information Collection for an itemized list of the information UGREEN collects and uses about you.

3. Legal basis for processing personal information

The purposes for which we process your information are as follows:

Services for you: We process your account and profile data, log information, permission information, location information and information related to your smart device, andthe legal basis for such processing is our agreement with you.
Improving our services: We process your device information, usage data, location information and smart device-related information to ensure the functionality and security of our products, to develop and improve our products and services, to analyze the efficiency of our operations, and to prevent and track fraud or misuse. The legal basis for such processing is the performance of our agreement with you in accordance with our terms of use.
Non-marketing communications: We process your personal information for the purpose of sending you important information related to services, changes to terms/conditions and policies, and/or other administrative information. At the same time, we may also send you notifications related to the services you use, such as alert services. You can manage whether you request to receive such communications by going to UGREEN's "Message Center - Settings" and when you choose to turn off push notifications, we will not continue to send you such information. The legal basis for such processing is our agreement with you.

4. Exception for prior authorized consent

Please note that your prior authorized consent is not required for the collection and use of personal information in the following cases：

directly related to national security and national defense security；
directly related to public safety, public health, and significant public interest；
directly related to crime investigation, prosecution, trial, and sentence enforcement；
For the purpose of safeguarding your or other individuals' significant legal rights and interests, such as life and property, but where it is difficult to obtain my consent；
The personal information collected is disclosed by you to the public at your own discretion；
Where personal information is collected from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure and other sources；
necessary to enter into and perform the contract at your request；
Necessary for maintaining the safe and stable operation of the product or service provided, such as detecting and disposing of malfunctions of the product or service；
Where it is necessary to conduct statistical or academic research in the public interest and where it provides the results of academic research or descriptions to the public by de-identifying the personal information contained in the results；
Necessary for the conduct of legitimate journalism；
Other circumstances specified in laws and regulations.

II. How we share, transfer, and publicly disclose your personal information

1. Who do we share your personal data with?

We will not share your personal information with any company, organization or individual outside of Ugreen Group Limited except as follows：

(1) Sharing with explicit consent: We may share your personal information with other parties after obtaining your explicit consent.

(2) Sharing with our affiliates: As permitted by law, we may share your information with our affiliates for the purpose of providing you with UGREEN products and services. We will only share personal information that is necessary and is subject to the purposes stated in this Privacy Policy. Affiliates who wish to change the purposes for which personal information is processed will again seek your authorized consent.

(3) Sharing with Authorized Partners: Certain of our services will be provided by authorized partners only to fulfill the purposes stated in this policy. We may share some of your personal information with our partners in order to provide better customer service and experience. We will only share your personal information for purposes that are legal, legitimate, necessary, specific, and explicit, and only as much personal information as is necessary to provide the services. Our partners do not have the right to use the personal information shared for any other purpose. Typically, our partners are:

①Third party service providers: Provide us with application development.

②Third party SDK service provider : In order to ensure the stable operation and function of the application, so that you can use and enjoy more services and functions, we will embed the third party's SDK in the application. This privacy policy only applies to the information we collect from you, not to the products or services provided to you by the third party alone, and we are not responsible for how the third party's products or services collect, use, or process your personal information. We are not responsible for how third party products or services collect, use, or process your personal information. When you use the products or services provided by the third party alone, the third party may collect your personal information; when you use the third party products or services, please also carefully read and fully understand the privacy policy of the products or services provided by the third party; please refer to the valid version provided by the third party when you use the third party products or services. In order to provide you with more services, ensure the stability and quality of services or upgrade the relevant functions, we may need to adjust the third-party SDK/API that we access, and we will update the directory of the third-parties that UGREEN app accesses in a timely manner to explain to you the latest situation involving the third-party SDK so that you can check the third-party data usage rules.

Please refer to the List of Third-Party Information Sharing for the third-party SDKs embedded in the platform and the information to be collected by or shared with the third-party SDKs.

(4) Fulfillment of legal obligations: We may share your personal information to the public in accordance with laws and regulations, or in accordance with mandatory requirements of government authorities.

2. Transfer

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.

3. Public Disclosure

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

(1) after obtaining your express consent;

(2) disclosure based on law: We may publicly disclose your personal information if compelled to do so by law, legal process, litigation, or governmental authority.

4. Exception for prior authorized consent

Prior authorized consent of the subject of personal information is not required for the sharing, transfer, or public disclosure of personal information in the following cases:

(1) directly related to national security and national defense security;

(2) directly related to public safety, public health, and significant public interest

(3) for the purpose of safeguarding the significant legitimate rights and interests of the subject of personal information or other individuals, such as life and property, but where it is difficult to obtain the consent of the individual;

(4) directly related to crime investigation, prosecution, trial, and sentence enforcement;

(5) Those that collect personal information from legitimate public disclosures, such as legitimate news reports, government information disclosure and other channels.

(6) Personal information disclosed to the public by the subject of the personal information itself;

III. How you can exercise your rights

1. Rights related to personal data

In accordance with the relevant laws, regulations and standards of, we protect your right to exercise the following rights with respect to your personal information.

(1) Inquiries about your personal information

Approach: Personal Center - Account & Security

For information that cannot be accessed through the above means, you may contact us at any time through the contact information in Article 9 of this policy, and we will respond to your request for access within 15 business days of verifying your identity information.

(2) Correction of your personal account information

Approach: Personal Center-Account & Security (you can edit your avatar, nickname, gender, modify your personality signature, change your password and gesture password)

For information that cannot be corrected through the above means, you may contact us at any time through the contact information in Section 9 of this policy and we will respond to your request for correction within 15 business days of verifying your identifying information.

(3) Change the scope of your authorized consent or withdraw your authorization

The approach to change the authorization scope of related functions: Personal Center - Privacy Permissions Settings.

When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization. If you encounter operational problems during this process, you may contact us at any time via the contact information in Article 9 of this policy.

(4) Deletion of your personal information

You can delete it yourself by going to: Personal Center - Account & Security.

If we have processed your personal information in violation of laws and regulations, or we collected or used your personal information without your consent, or you no longer use our products or services canceled account, you need to delete personal information, you can submit a request to delete your personal information to us through the contact information in Article 9 of this policy, we will respond to your deletion request within 15 business days. When your information is executed deleted, we will no longer use the data, but may not be able to delete it immediately in order to accommodate the necessary relevant legal policy requirements or to protect the integrity of the data necessary for the normal operation of the service, store or backup it for the necessary period of time, but delete it in a timely manner after that period of time.

(5) Cancellation of your account

You can cancel your account at any time. Once you cancel your UGREEN software account, you will not be able to use the services of UGREEN remote monitoring and operating smart devices, and we will delete or anonymize your personal information as required by applicable laws, and the relevant data will not be recoverable, so please proceed with caution!

Cancellation approach: Personal Center-Account & Security-Cancel Account

If you are authorized to log in to the UGREEN software platform through a third party account (QQ/ Wechat/ Facebook/ Apple ID), you will need to apply to the third party to cancel your account. However, you can also contact us through the contact information in Article 9 of this policy and we will respond to your cancellation request by deleting the personal information under the account associated with your registered cell phone number within 15 business days after verifying your identity information.

(6) Access to copies of personal information by subjects of personal information

You have the right to obtain a copy of your personal information by sending a request to cnfw@ugreen.com.

When an individual user logs out, the system may delete personal information and we will not be able to provide a complete copy of personal information.

(7) Constraint information system automatic decision making

In some business functions, we may make decisions based solely on non-human automated decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legal rights, you have the right to an explanation. If these decisions significantly affect your legal rights, you have the right to seek an explanation from us and we will provide appropriate remedies.

(8) Processing restrictions

In some cases, you have the right to ask us to stop processing your personal information and only store such information. However, we may process your personal information if we have a legitimate reason to do so (for example, to defend a legitimate claim or to protect others).

If we agree to stop processing personal information, then we will take reasonable steps to do so. Please inform any third party to whom we have disclosed the relevant personal information so that they may also cease processing it.

You may request that we stop processing the personal information we hold about you and only store it if.

You believe that personal information is inaccurate and that the data whose accuracy is in doubt may lead to a loss of the data subject's own interests.
We no longer need the personal data for the purposes of the data processing activities, but at this time you have a legal claim, and in order to bring, exercise or defend that legal claim, you have the right to exercise the right to restrict processing against the data controller in order to ensure that the data subject's legal claim can be successfully pursued;or
The processing of data by us, and the purposes for which the data are processed, is deemed unlawful by official authorities such as the courts (you want us to retain personal information in storage form only).

(9) Respond to your request above

For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before we process your request. We will respond within 15 business days. (However, this may be extended for an additional two months in certain circumstances, such as when the request involves a large amount of information or a complex situation)

In principle, we do not charge a fee for your reasonable requests. We may refuse requests that are unwarrantedly repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical (for example, involving the backup of information stored on tapes).

If you are a user located in one of the following countries: Australia, Japan, the United Arab Emirates, the Kingdom of Saudi Arabia, the United Kingdom ,California and Other US states, or Europe. the terms set forth under your jurisdiction at Supplementary Terms apply to you in addition to the terms set forth in our Privacy Policy.

2. In the following cases, we will not be able to respond to your requests for correction or deletion of information in accordance with the requirements of laws and regulations:

(1) directly related to national security and national defense security;

(2) directly related to public safety, public health, and significant public interest;

(3) directly related to the investigation, prosecution, trial, and enforcement of sentences for crimes;

(4) Where we have sufficient evidence of subjective malice or abuse of your rights (e.g. where your request would endanger public safety and the legitimate rights and interests of others, or where your request is beyond what can be covered by ordinary technical means and commercial costs);

(5) involving trade secrets.

(6) When responding to a request from a subject of personal information will result in serious damage to the legitimate rights and interests of you or other individuals or organizations;

This Policy does not create, extend, or modify rights for data subjects and consumers or UGREEN's obligations unless otherwise required by the GDPR, CCPA, or other privacy laws.

IV. Protection of personal information of minors

We are committed to the protection of minors' personal information.If you are a parent or guardian, please ensure that any child under your care uses our services with your authorized consent.For inquiries regarding a child's personal information, please contact our dedicated personal information protection department.If you are considered a minor under the laws of your area, it's important to review this policy with your guardian before using our product/service. Please make certain that you have your guardian's explicit consent both for using this product and for sharing your personal information with us.Once a child's personal data is collected with parental consent, we will use or disclose it only as explicitly agreed by the parent or guardian, in compliance with applicable laws, or when necessary for the child's protection.If a guardian believes we have collected a minor's personal information without consent, please contact us through the contact information in Article 9 of this policy,, and we will delete the relevant data promptly upon request.

V. Data retention period

During your use of the Service, we will continue to store your personal information for you. If you need to delete your personal information, you can contact us through the contact information in Article 9 of this policy. In addition, we will delete or anonymize your personal information after the above retention period, except as expressly provided by law or regulation. If we are unable to destroy the data for technical reasons, we will take appropriate measures to prevent further use of your personal data.

VI. How your personal information is transferred globally

In principle, personal information collected and generated by us in Europe, the United States, Japan, and the People's Republic of China will be stored locally. Due to our provision of products or services through globally distributed resources and servers, this means that your personal information may be transferred to, or accessed from, jurisdictions outside the country where you use the product or service, with your expressly authorized consent. Such jurisdictions may have different data protection laws . Regardless of the data storage location, UGREEN commits to processing it in accordance with this policy, adhering to applicable legal requirements, and implementing contractual or other measures to secure your personal data. Specifically, if the data of EEA and UK users needs to be accessed by affiliated entities in other countries/regions of the UGREEN Alliance, we will adhere to the European Commission's standard contractual clauses for the transfer. If you would like more information about this, please contact us.

VII. Safety and security measures

1.We prioritize the security of your personal information and adhere to prevailing information security standards. Our aim is to remain at the forefront of industry security practices.Our security strategy includes advanced security technologies such as encrypted transmission, secure data storage, intrusion detection, firewall protection, and regular vulnerability scanning to safeguard your data.Beyond technical solutions, we implement comprehensive management systems to bolster information security. This includes staff training in data protection and meticulous scrutiny and improvement of all data processing and storage procedures.Recognizing that no system is infallible, we continuously identify potential risks and implement precautions to mitigate the likelihood of information leaks, destruction, misuse, unauthorized access, disclosure, or alteration of your personal information.In the event of a security incident, we have established protocols and response mechanisms to promptly notify affected users, rectify security vulnerabilities, and take steps to prevent future occurrences.

(1)Your information is collected and used in accordance with industry-standard security practices, and you will be informed of the purposes and scope of data use through our user agreement and privacy policy.

(2)Our network services employ encryption technologies, such as transmission security protocols, to protect your data during transmission.

(3)Your personal information is encrypted and stored using advanced encryption and isolated through state-of-the-art technology.

(4)When processing personal information, such as when disclosing personal information and measuring the degree of association, we apply data desensitization techniques, including substitution and encryption-based methods, to enhance the security of any personal data we process.

(5)Our stringent data access control and multiple identity authorization systems are designed to prevent misuse of personal data and ensure compliance with regulations.Staff authorized to access personal information undergo identity verification, and access control measures, and sign confidentiality agreements, ensuring only authorized employees have access to your data.

The Internet is not an absolutely secure environment, and even if we do our best to strengthen security measures, we cannot always guarantee the absolute security of information. Please understand that your use of our products and services may be subject to malicious attacks that result in security problems beyond our control, etc.

2.Your cooperation

Although we have taken reasonable and effective measures as described above and have complied with the standards required by relevant laws and regulations, we still cannot guarantee the security of your personal information when communicating through unsecured means. Therefore, you should take active measures to ensure the security of your personal information, such as: setting complex passwords, changing your account password regularly, and not disclosing your account password information to others to help us keep your account and personal information secure. If you discover that your personal information has been compromised, especially your account or password, please contact us immediately using the contact information provided at the end of this Privacy Policy so that we can take appropriate measures to protect the security of your information.

VIII. Statement on Policy Changes

We may make changes to this policy from time to time. We will not reduce your rights under this policy without your express consent. We will post any changes to this policy on this page. For material changes, we will notify you by pop-up information, email, etc., and ask for your consent again.

Material changes referred to this policy include, but are not limited to:

significant changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used;
significant changes in our ownership structure, organizational structure, etc. such as changes in ownership due to business restructuring, bankruptcy and mergers, etc.;
changes in the primary recipients of personal information sharing, transfer or public disclosure;
significant changes in your rights to participate in the processing of personal information and in the manner in which it takes place;
in the event of a change in the department responsible for handling the security of personal information, our contact information and complaint channels;
when the personal information security impact assessment report indicates a high risk.

By continuing to use the Service after we update this Policy, you agree to the contents of this Policy (including the updated version) and consent to our collection, use, retention, disclosure, and transfer of information about you in accordance with this Policy.

IX. Contact Us

We have established a dedicated personal information protection team and person in charge. If you have any questions, comments or suggestions regarding this policy or our services, you can contact us:

(1) You can contact us through the "Feedback" on the UGREEN app, approach: Settings - Help Center - Feedback.

(2) Send an e-mail to the person in charge of personal information protection: Name of the person in charge (legal representative) : Mengxin He ; cnfw@ugreen.com (contact e-mail).

In order to ensure that we handle your problem efficiently and provide you with timely feedback, we need you to submit proof of identity, valid contact information, written request and relevant evidence, and we will process your request within 15 business days after verifying your identity.
If you are not satisfied with our response, especially if you believe that our personal information processing practices have harmed your legitimate rights and interests, you may first negotiate with us, and if you are not satisfied with the results of the negotiation, you may also seek a solution by filing a lawsuit with a court of competent jurisdiction in Longhua District, Shenzhen. Please note that if you are a resident of EEA, UK, you have the right to lodge a complaint with the data protection authority of your country.

Supplementary Terms

If you are a user located in one of the following countries: Hong Kong SAR, Macau SAR, Taiwan China Australia, Japan, California and Other US states, Kingdom of Saudi Arabia, United Arab Emirates, Europe,the terms set forth under your jurisdiction apply to you in addition to the terms set forth in our Privacy Policy.

Hong Kong SAR

If you choose not to provide personal information, you may not be able to use some of the features of UGREEN properly.

As a user in the Hong Kong SAR, you have the legal rights (to the extent permitted by applicable laws and regulations) to the personal information we hold about you.

You have the right to make an access request to obtain a copy of the data we process about you. You can also exercise the right to data correction and the right to stop the use of personal data for direct marketing purposes.

Macau SAR

If you choose not to provide personal information, you may not be able to use some of the features of UGREEN properly.

As a user of the Macau SAR, you have the legal rights (to the extent permitted by applicable laws and regulations) to the personal information we hold about you.

You have the right to make an access request to obtain a copy of the data we process about you. You may also exercise the right to data correction and the right to stop the use of personal data for direct marketing purposes, or the right to object to using your personal data based on your own reason.

Taiwan( China)

We do not knowingly collect or solicit personal information from children under the age of 7, nor do we knowingly allow children under the age of 7 to register with UGREEN. If you are under the age of 7, please do not attempt to use or register with UGREEN, or provide us any personal information about yourself. Even if a user under the age of 7 uses UGREEN and its services, he or she must not provide us with any personal information. If the user is located in Taiwan, and is under 20 years of age, you must obtain parental/guardian consent to use UGREEN and its services.

We will first obtain your consent before transferring your personal information in order to provide you with personalized advertising (if any). You may exercise the rights set forth in Article 3 of the Personal Data Protection Act to: (1) access your personal information for inspection and review; (2) obtain a copy of your personal information; (3) supplement or correct your personal information; (4) request that we stop collecting, processing or using your personal information; and (5) request that we delete your personal information. To the extent permitted by law, our ability to comply with your request may be limited.

Australia

By clicking "Accept" you consent to the transfer of your information across borders to any country in which our database is located or to any country in which our service providers are located.

We take reasonable steps to ensure that the receipt and processing of your personal information by third parties located outside of Australia complies with Australian privacy laws. However, you acknowledge that we have no control over, and are not responsible for, the actions and omissions of such third party recipients.

If you are dissatisfied with our response to your privacy complaint involving your personal information, you may contact us via email: cnfw@ugreen.com.

Japan

Your information will be stored on a local server in Japan. Once the purpose of collecting your personal information is completed, we will delete your personal data within the scope of legal provisions.

When you provide data to us, you need to know that China is not a country that has obtained an adequacy determination under Article 45 of the GDPR, and is not a member of APEC's CBPR system or the OECD. For information on the personal information protection systems of major countries and regions, please visit the website of the Commission for Personal Information Protection: https://www.ppc.go.jp/en/index.html

Kingdom of Saudi Arabia

By clicking "Accept" you consent to the transfer of your information across borders to any country in which our database is located or to any country in which our service providers are located..

You consent to the collection, use, correction, deletion, sharing and storage of your personal information as set forth in this Privacy Policy (including the Supplementary Terms), including (without limitation) for the purpose of displaying personalized advertisements to you in connection with your use of the Services. If you need to make such a request, please contact us (the person responsible：MENGXIN HE) at cnfw@ugreen.com.

United Arab Emirates

By clicking on "Accept" you are consenting to the transfer of your information across borders to any country where our database is located or to any country where our service providers are located.

You may request that we notify you of the purposes for which we use, disclose, correct, discontinue using or providing, and/or delete any and all personal information we store about you. If you need to make such a request, please contact us via cnfw@ugreen.com (responsible person:MENGXIN HE）. We may also use the personal information you provide for the purpose of displaying personalized advertisements to you when you use the Services. For information on personal information protection systems in major countries and regions, please visit the website of the Commission for Personal Information Protection at https://www.ppc.go.jp/en/index.html

California and Other US states

If you are located in California or another U.S. state, the provisions in this section supplement those in this Policy.Your information will be stored on a local server in the United States, and once the purpose of collecting your personal information is completed, we will delete your personal data within the scope of legal provisions.

The California Consumer Privacy Act of 2018 and the California Privacy Rights Act (CPRA), as amended, along with their implementing regulations (collectively referred to as the "CCPA"), grant California residents specific rights regarding their personal information.

This section details your rights under the CCPA and how to exercise them.

1.Your Personal Information Rights：

(1)Right to Know of the Collection, Disclosure, and Sale of Your Personal Information

California residents are entitled to request that a business collecting their personal information disclose the following:

①Categories, purposes, and sources of personal information collected in the past 12 months;

②Specific personal information collected in the past 12 months;

③Types of personal information disclosed for commercial purposes in the past 12 months.

You are entitled to submit up to two free, verifiable consumer access or data portability requests to us within a 12-month period.

(2)Right to Request the Deletion of Personal Information

California residents are entitled to request businesses delete any personal information they have collected, subject to exceptions as outlined in the CCPA.UGREEN will provide a clear bases for any denied requests for deletion.

(3)Right to Limit Use of Sensitive Personal Information

You have the right to limit the use of your sensitive personal information for any purpose, except as provided under Section 7027 (m) of the CCPA.

(4)Right to Opt-Out of the Sale of Personal Information

We do not, nor have we in the past 12 months, sold any personal information we have collected.

(5)Right to Non-Discrimination

UGREEN will not discriminate against individuals exercising their rights under the CCPA.

These rights are not absolute, and in some cases, we may be legally required or permitted not to fulfill your request.

2.How to Exercise Your Rights

To exercise any of the above rights you may submit a verifiable consumer request to us through cnfw@ugreen.com .Only you or an authorized agent can make a verifiable consumer request related to your personal information.An authorized agent must submit your written permission and their registration filed with the California Secretary of State to make a request on your behalf.

3.Validating Your Request

To respond to your CCPA request, we need to verify your identity or your authorized agent's authority.

If initial verification is unsuccessful, we may request additional information for verification purposes.

Any personal information provided for verification will solely be used for that purpose.For verification, please provide your name, address, phone number, and email address.We will compare this information with what we already hold and may request additional documentation, including identification documents, to minimize fraud risks.We may deny or partially fulfill certain requests as permitted or required by law.For example, in requests for deletion of CCPA Personal Information, we may retain necessary information for legal purposes, like tax accounting.California consumers have the right to file a complaint with the California Attorney General's Office under the CCPS.

The Attorney General's Office can be contacted via https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by calling (916) 210-6276.

Contact us using the methods below, and we will respond within 30 days.Should more time be needed to process your request, we will inform you within the initial 30 days.

Europe

As a user in the European Economic Area (EEA) or the UK, Your information will be stored on a local server in Europe. Once the purpose of collecting your personal information is completed, we will delete your personal data within the scope of legal provisions.you are entitled to the following rights regarding the personal data we process as a personal data controller:

(1)Right to Data Access/Portability: You have the right to access personal information held by us and can request that we provide this data for you to transfer to other service providers;

(2)Right to Erasure: You can request the erasure of your personal data held by us under certain circumstances (such as where the data is no longer necessary for the purposes for which it was initially collected);

(3)Right to Object to Processing: You have the right to object to our processing of your personal data and require us to stop such and/or stop sending you instant messaging marketing;

(4)Right to Correction: You have the right to require us to correct any inaccurate or incomplete personal data;

(5)Right to Restrict Processing: You have the right to require that we limit the processing of your personal data under certain circumstances (for example, if you dispute the accuracy of the data we hold or if you believe the processing is unlawful).

To exercise these rights, please reach out to us through cnfw@ugreen.com.We will review and respond to each request in accordance with applicable data protection laws. Note that we may request further information from you to verify your identity and ensure your entitlement to access your personal data.You also have the right to file a complaint with a data protection agency.For more details, please contact your local data protection agency.