In order to provide our services to you, we may process your information(personal data). We will only process personal data that is necessary for its concrete, explicit and legitimate purposes.

The purpose of processing personal data is to provide you with our products and/or services, develop our products and/or services and ensure that we comply with applicable laws, regulations and other regulatory requirements. This involves:

1 Providing, processing, maintaining, improving and developing our products and/or services to you, such as delivery, activation, verification, after-sales, customer support.

2 Advertising our products and/or services provided that your informed knowledge and consent has been granted to us when applicable.

3 Implementing and maintaining security safeguards for the purpose of preventing loss and fraud, such as assisting in identifying users, verifying the user identity. We use your information for anti-fraud purposes only when the following two conditions are met: it is necessary; and the data used for evaluation is in accordance with our legitimate interests to protect users and services.

4 Handling your questions or requests about device and services, questions, or requests, such as answering customer inquiries, sending system and application notifications, managing your activities.

5 Internal purposes, such as data analysis, research, and development of statistical information related to the use of our products or services to better improve our products or services. For example, machine learning or model algorithm training is performed after de-identification processing.

6 Storing and maintaining information related to you for our business operations (such as business statistics) or for fulfilling our legal obligations.

7 Deleting data according to our Retention Policy (section 2.6.2 below) and your requirements.

8 Other purposes with your consent.

9 Here are more detailed examples on how we use your information (which may include personal data):

10 How we use cookies and other technologies

Log files: As true of most websites and apps, we gather certain information and store it in log files. This information may include Internet protocol (IP) addresses, device MAC address and operation logs. We do not link this automatically collected data to other information we gather about you.

Provided it does not constitute information directly or indirectly identifying an individual we treat information collected by cookies and other technologies as impersonal information. Where Internet Protocol (IP) addresses or similar identifiers directly or indirectly identifies an individual we treat such information as personal data and process them in accordance with the User License Agreement and other applicable laws.

How do you get my consent?

When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

How do I withdraw my consent?

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at Support@sengled.zendesk.com

We promise not to offer, sell or rent out to any irrelevant third party, share or transact with or otherwise transfer or make available to any irrelevant third party any personal data unless we obtain the prior consent from you or such third party that provides to you services independently or jointly with us. Any third party will be forbidden to access all your personal data. We will also prevent any third party from collecting, editing, selling or freely spreading your personal data in any way.

In accordance with legal requirements, legal procedures, litigation and/or requests from government institutions, we may need to disclose your personal data. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you strictly following requirements and procedures of applicable law.

In order to enforce our terms or protect our business, rights, assets or products, or to protect users, or if the disclosure is reasonably necessary for the following purposes (detecting, preventing and resolving fraud, unauthorized use of the product, violations of our terms or policies or other harmful or illegal activities), we may also disclose information about you. For the avoidance of doubt, we may collect, use or disclose your personal data without your consent if it is and only to the extent it is expressly permitted under applicable data protection laws This may include providing your personal data to government institutions; communicating with third-party partners about the reliability of your account to prevent fraud, violations, and other harmful behaviors.

In addition, we may share your personal data with:

All your personal data is stored on secure servers, and protected in controlled facilities. We classify your information based on importance and sensitivity, and ensure that your personal data has the required level of security. We have special access controls for cloud-based data storage, and we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.

Payment:

If you choose a direct payment gateway to complete your purchase, then Sengled.com stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

The products or services we offer include products or services of third parties, which may be accessed in the form of an SDK or a link to a third party website. They may also collect personal information about you in your use.

When you use our services or require us to provide specific services, you understand and agree that the software may call a third-party system or support your use or access through a third party, and the results of use or access will be provided by the third party.

To ensure your legitimate rights and interests, please be sure to carefully read the relevant user agreement provided by any third party in the use of these third party products or services. We are not responsible for the use by third parties of the personal information they collect from you and have no control over this use. Any and all your use of third party applications is not our responsibility. We shall not be liable for any disputes or disagreements arising therefrom. Our Privacy Policy will not apply to these third party services.

The SDK we currently use is Umeng + SDK，for statistical analysis purposes, please refer to this link: https://www.umeng.com/page/policy. The types of personal information collected by this SDK are: device information (IMEI/Mac/android ID/IDFA/OPENUDID/GUID/SIM card IMSI/geolocation information).

You should make your own judgment on resources such as mobile applications in our products or services, and bear all risks arising from the use of related resources. We can’t and will not shoulder the responsibility for any loss or damage due to aforementioned risks.

To create a secure environment for personal data processing and guarantee the privacy and integrity of data processing, we have applied the Transport Layer Security protocol and other encryption technologies to prevent our transmission link from sniffing, eavesdropping and intercepting in the various ways.

All your personal data is stored on secure servers, and protected in controlled facilities. We classify your information based on importance and sensitivity, and ensure that your personal data has the required level of security. We have special access controls for cloud-based data storage, and we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.

We conduct due diligence on business partners and third party service providers to make sure that they are able to protect your personal data. We also check that appropriate security standards are maintained by these third parties by putting in place appropriate contractual restrictions, and wherever necessary, carrying out audits and assessments. In addition, our employees and those of our business partners and third party service providers who access your personal data are subject to enforceable contractual obligations of confidentiality.

We conduct security and personal data protection training courses and tests to enhance our employees' awareness of the importance of protecting personal data. We will take all practicable and legally required steps to safeguard your personal data.

Should a personal data security incident occur, we will notify the breach to the relevant data protection supervisory authority and, where applicable to data subjects and handle the incident as required by applicable data protection laws.

If you detect the leakage of your personal data, please contact us immediately. Hence, we can take countermeasures to protect the privacy of your personal data.

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.

QUESTIONS AND CONTACT INFORMATION

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact at:

USA:

Canada:

Or mailing us at:

Sengled USA, INC.

155 Bluegrass Valley Parkway, Suite 200

Alpharetta, GA 30005