This Privacy Policy describes how we collect, use and share your personal information when you visit or purchase products or services from xppartner.com and other websites owned or controlled by our company or owners.
Briefly describe how we will use your information
We will use your information in order to meet your requests, communicate with you, manage events or process your orders with us or our affiliates;
This information will be shared with our affiliated companies, most of which are located outside the European Economic Area (EEA);
For actions that require your consent (such as sending you marketing materials), you can withdraw your consent at any time. See below for more details on how to withdraw consent.
FOOMKIT LTD AND ITS OWNERS AND YOUR PRIVACY
FOOMKIT LTD and its affiliated entities and brands (xppartner) are committed to protecting the privacy of personal information. We will only collect, use or disclose personal information to the extent permitted by relevant laws and this Privacy Policy. If you are under the legal age for products and services in your region, or if you do not agree to the terms of this policy, please do not provide us with your personal information.
Information you provide us

You provide us with information about you when you communicate with us, participate in our events, purchase our products and services, use our website or register on our website. These situations may include:
when you transact with us online, over the phone or in person;
when you participate in marketing or activities organised by us (including through our website or social media sites);
when you visit and/or register to use any of our websites, or when you participate in discussion boards or other social media features of our websites; or
when You contact us for information or support related to our company, products or services (including information or support related to our brand, shares of our company, product quality, visits to our website or employment opportunities). For example, if you need to purchase products and services from us online, you may need to provide us with your name, address and telephone number so that we can process your order and ship your products and services to you. We may also need your date of birth, and your credit card number to complete the purchase. Of course, generally payment information is processed and stored by Stripe, PayPal, Alipay, WeChatPay and other related service providers Information we collect and our use of browser cookies (cookies)
In addition to the information you give us directly, we also automatically collect information about you when you visit our website, including through the use of cookies. Cookies are small data files that are downloaded to your computer when you visit certain websites. The information we collect is:
Technical information such as your IP address, hardware type, browser type, device identifier and screen type/resolution;
any search terms entered on our website;
general location information based on your device or IP address;
any technical malfunction or anomaly; and
Information about your visit such as the products you browsed or retrieved, how long you browsed, how fast web pages load, and which web pages you have visited.
Cookies help us obtain and store information about our website visitors, help our website remember choices you have made on previous pages (to avoid re-entering information), and help us identify you as a unique visitor based on your Previous access to customize content and provide you with the most optimized experience.
The tracking technologies we use on our website
Strictly Necessary Tracking Technologies - These technologies are necessary to allow you to browse our website and use its features.
Performance-related tracking technologies - These technologies collect anonymous information about how people use our website. For example, we use Google Analytics and tracking programs, codes from platforms such as Baidu, CloudFlare, etc. to help us better understand how users find our website, how they browse or use our website and identify areas we can improve, such as Navigation, interactive experience and marketing activities. The data stored by these technologies does not reveal personal information that could identify you personally.
Performance-related tracking technologies - these technologies record your choices, such as which country you visit our website from, confirmation of age verification you have completed, language preferences, and retrieval parameters. This information can then be used to provide you with an experience more tailored to your choices and to make your browsing of the site more personal and satisfying. The information collected by these technologies may be anonymous and cannot track your visits to other websites.
Targeting or advertising-related tracking technologies - These technologies collect information about your visiting habits to deliver advertisements more relevant to you and your interests. These technologies are also used to limit the number of times you view the same advertisement and to measure the effectiveness of advertising campaigns. These technologies are often placed in third-party advertising networks that record the websites you visit and share this information with other parties such as advertisers. For example, we use third-party companies, such as Facebook, Quantcast and Google, to provide you with more personalized advertising as you browse other websites and social networks. A mix of first-party and third-party cookies will be used.
Social Media Related Tracking Technologies - These technologies allow you to share content from our website on social media, such as Facebook and Twitter, or to verify your age by logging into these social media when visiting our website. These technologies are not under our control. For information on how other parties' technologies work, please see their respective privacy policies.
Commerce-Related Technologies - These technologies are essential to provide a fully functional online shopping experience on our website, store and payment/checkout platforms. These technologies continuously track the items and quantities in your shopping cart, your membership tier, your country/state (if applicable for tax or shipping compliance reasons), and any coupons or discount codes you use.
If you do not wish to receive cookies, you can adjust your web browser to refuse cookies or to warn you when cookies are used. However, some features of our website will not work when cookies are turned off. Therefore, we strongly recommend that you retain the full functionality of cookies. See below for more information on cookies and here for information on how to manage cookies, including how to disable cookies in most web browsers. You can also opt out of Google's targeted advertising by visiting: https://support.google.com/ads/answer/2662922?hl=en-AU.
Regulations in California and the People's Republic of China
For California residents, please see the "About Your California Privacy Rights" section below for additional information about the categories of personal information we collect.
For personal information subjects located in China, for other information about the categories of personal information we collect, as well as the specific content of personal information protection, please refer to the section "Relevant Provisions of the People's Republic of China on Personal Information Protection" below. If there is any inconsistency between the "Relevant Provisions of the People's Republic of China on the Protection of Personal Information" and other parts of this Privacy Policy, the "Relevant Provisions of the People's Republic of China on the Protection of Personal Information" shall prevail
Our use of your information

We will not use your information for electronic marketing without your consent. For example, if you want to participate in promotional activities related to our products, we will obtain your consent to send you marketing materials related to those products. If you receive an email from us, we will always provide you with an opportunity to unsubscribe, and by clicking on the unsubscribe link provided in the email, you will no longer receive further information from us.
We may use or disclose the personal information we collect for one or more of the following purposes, to conduct our business operations and to pursue our legitimate business interests (where necessary, with your consent):
To fulfill or satisfy your reason for providing the information. For example, if you provide your personal information to purchase our products, we will use that information to process and manage your order. If you provide your details to apply for a job with FOOMKIT LTD, we will use these details to process your employment application.
To provide, support, personalize and develop our website, products and services and to help us better understand your likes and dislikes in order to improve our website and the services we provide.
To help maintain the security, confidentiality and integrity of our website, products and services, databases and other technical assets and business. Personalize your website experience and provide content, products and services relevant to your interests, including through our website, third-party websites and by email or text message (where we do not require your consent) to provide targeted pushes and Advertising (this article does not apply to personal information collected in China).
To allow you to use the interactive features of our website and to learn about our marketing and events. Verify that you are of legal age for purchasing products and services in your area.
To suggest or recommend products or services to you or other users of our website that may be of interest to you or them.
To perform a contract we may have with you, such as when you purchase products from us or attend our events. For necessary legal claims, compliance, regulatory and investigative purposes (including responding to law enforcement requests and complying with applicable laws, court orders or government regulations).
To develop understanding of consumers (eg, general research on our consumers; conduct consumer testing, surveys and seminars; data analysis and modeling). Content described to you when your personal information was collected, or otherwise specified in the CCPA or the Personal Information Protection Law of the People's Republic of China. Evaluate or carry out a merger, divestiture, reorganization, reconstruction, dissolution or other sale or transfer of some or all of the assets of FOOMKIT LTD, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, in which , the personal information held by FOOMKIT LTD about our website users is a transferable asset.
In some cases, you must provide us with information. For example, if you purchase products and services from us, but do not provide specified personal information (such as your age, your contact information and shipping address), we will not be able to complete your order. We will always ensure that the amount of data we collect is minimised and only request the data necessary to process your request. FOOMKIT LTD will generally not collect additional categories of personal information or use the personal information we collect for substantially different, unrelated or inconsistent purposes without notifying you. However, FOOMKIT LTD may collect additional categories of personal information or transfer the personal information we have collected without notifying you if there are special requirements of relevant departments and agencies such as national authorities, police, taxation, law, etc. that have jurisdiction or are involved. For a substantially different, unrelated or inconsistent purpose.
Withdraw consent or otherwise refuse direct marketing
Where your consent is required, you can always withdraw your consent, although we may still process your information for other purposes (such as those described above) on other legitimate grounds. At any time, you have the absolute right to opt out of direct marketing and to object to our analysis for direct marketing purposes. You can opt out by following the instructions in the email (when receiving electronic messages) or by contacting us directly, as described below.

How long we will keep your information

Generally, we will retain your personal information for as long as necessary to achieve the purposes for which it was collected (as set out in this Privacy Policy), unless longer retention periods are required by law.
For registration information, we may retain information about active users of the website that we believe to be active, and may continue to retain information for 2 years after they cease to be active.
For personal information processed for promotional purposes or with your consent, we may continue to process the information until you ask us to stop, and may continue to retain it for a short period (to allow us to process your request). We may also permanently record your request that we stop direct marketing or processing of your information so that we can comply with your request in the future.
For personal information related to contract performance (such as your purchase of products and services from us) or activities, we may retain your information for a period of 6 years after your last interaction with us.
We may retain personal information for 3 years for website security and/or fraud management purposes.
Our disclosure of your information
We will not disclose your personal information to third parties except in the following cases:
with your consent;
Where we are required or permitted by law to disclose, such as to law enforcement agencies; Third parties designated by us need to obtain personal information held by us in order to provide services (in which case we require those third parties to keep personal information confidential and will not use or disclose it for any purpose other than providing those services Personal information). Third parties to whom we may transfer information include sellers, service providers, intermediaries and others who support our business and assist in the management of certain activities on our behalf, such as the provision of technical infrastructure services, promotional services, user services, data hosting and management services , credit card payment processing services, and global partners who provide logistics and shipping services to help us deliver our products and services; or Disclosure to our affiliates to conduct global business operations and comply with legal requirements. We may also transfer personal information to affiliates or third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets and stock. In some cases, the above actions include the transfer of your personal information to other countries (including countries outside the European Economic Area) for the purposes of data processing and storage (including fulfilling any orders you place with us, if any). Depending on which brand, manufacturer or office you are involved in or registered with, information is transferred to the United States, Australia, Japan, Singapore and other countries where we do business. When information is transferred outside the European economy and to shareholders or sellers in countries that are not adequately governed by the European Commission, the information will be adequately protected by standard contractual clauses recognized by the European Commission. Upon your request, a copy of the relevant terms can be provided for your review, and the contact details can be found in the "Contact Us" section. We will use a All reasonable means necessary to ensure that your information is disposed of securely and in accordance with this Privacy Policy.
Our website may contain links to other websites. The privacy policies of other websites linked from our website other than those owned by us are not under our control. If you have questions about the privacy policies of those websites, you should contact the relevant companies directly.
Your rights regarding your information
Under applicable law, you may have the right to request a copy of the personal information we hold about you, including to request that we correct, delete or restrict the processing of your personal information. In some jurisdictions, applicable law may allow you to require us to automatically transfer your data to another controller based on your consent, or allow you to object to the processing of your personal information in certain circumstances (in particular where we do not need to use the information to satisfy an agreement or other statutory requirements, or we use the information for direct marketing or analysis). However, these rights may be limited, such as potentially revealing personal information of others if your request is fulfilled, or if you ask us to delete information that we are legally required to retain or retain based on our vital legitimate interests.
To exercise these rights, you may contact us, as described below.
safety
We have appropriate measures in place to keep your information secure. We employ appropriate physical and electronic procedures to protect the personal information we collect. If you have an account with us, you are obliged to keep your account information confidential, including your password, and be responsible for any operations on your account. We are not responsible for any damages caused by your failure to comply with this obligation.
Due to the nature of the Internet itself, the transmission of information over the Internet is not completely secure. Although we will protect your personal data in accordance with this policy, we cannot guarantee the security of any data transmitted to our website and you will assume the risk of any data transmission. Once we receive your information, we will adopt strict procedures and security measures to prevent your information from being illegally obtained.
contact us
If you have any questions or concerns regarding our collection, use and disclosure of personal information, need to exercise your data protection-related rights or make a privacy protection-related complaint, please visit our Privacy Portal. If you have any dissatisfaction or questions about how we use your personal data, please contact us immediately and we will deal with it as soon as possible. You also have the right to lodge a complaint with the data protection supervisory authority in your country at any time.
According to the EU Data Protection Regulation and the UK Data Protection Act, the data controller is FOOMKIT LTD, UK
About Your California Privacy Rights
If you are a legally recognized California resident, the California Consumer Privacy Act ("CCPA") provides you with a number of specific rights regarding our collection and use of your personal information over the past 12 months. This "California Privacy Rights" section supplements this "Privacy Policy" and applies only to legally recognized California residents as of January 1, 2020. Any term not defined in this section shall have the same meaning as defined in the CCPA.
Information we collect
Information collected by our website includes identifying, relating to, describing, referring to a particular consumer or device, being able to be associated with a particular consumer or device, or being reasonably directly or indirectly associated with a particular consumer or device device to match ("Personal Information"). In particular, the FOOMKIT LTD website has collected the following categories of personal information from its customers during the past twelve (12) months:
A. Identifier
Collected: yes
For example: This category may include: name, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver's license number, passport number, or other similar identifiers. In CCPA, a "unique identifier" or "unique personal identifier" refers to a permanent identifier that can be used to identify a consumer, household, or device associated with a consumer or household, used across services over time , including but not limited to device identifiers; Internet Protocol addresses; browser caches (cookies), beacons, pixel tags, mobile advertising identifiers, or similar technologies; customer numbers, unique pseudonyms, or user aliases; Other forms of permanent or probabilistic identifiers for consumers or devices.
B. Categories of Personal Information Listed in the California Customer Records Act (Cal. Civ. Code § 1798.80(e))
Collected: yes
For example: This category may include: name, signature, social security number, physical characteristics, address, phone number, passport number, driver's license or national ID number, insurance policy number, education or employment information, financial account numbers, medical information or Health Insurance Information.
C. Classification Characteristics Protected by California or Federal Law
Collected: yes
For example: This category may include: age, race, color, ancestry, country of birth, national origin, religion or belief, marital status, medical condition, physical or mental disability, gender and sexual orientation, veteran or military status, or genetic information.
D. Commercial Information
Collected: yes
For example: this category may include: records of personal property, records of products or services purchased, obtained or intended, or other purchase or consumption histories or tendencies.
E. Biometric Information Collected: No For example: this category may include: images of iris, retina, fingerprints, face, hand, palm, vein pattern, and voice recordings from which identification templates, such as face prints, minutiae templates or voiceprints, and Key pattern or cadence, gait pattern or cadence, and sleep, fitness or exercise data. F. Internet or other electronic network activity information Collected: yes For example: this category may include: browsing history, search history, Internet site interaction information, applications or advertisements. G. Geolocation Data Collected: yes For example: this category might include: physical location or mobile data. H. Sensory data Collected: No For example: This category may include: audio, electronic, visual, thermal, olfactory or similar information. I. Professional or Recruitment-Related Information Collected: Yes (potential employees only) For example: this category might include: current or previous work experience or performance appraisals. J. Nonpublic educational information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Collected: Yes (potential employees only) For example: This category might include: Education records (such as grades and transcripts) that are directly related to students maintained by an educational institution or its representative. K. Inferences drawn from other personal information Collected: yes For example, this category may include: inferences drawn from the above information that may reflect information about your preferences, characteristics, tendencies, behaviors, attitudes or similar behaviors. Please note that some categories of personal information described in the CCPA are duplicates; for example, your name is both an identifier and a type of data described in section 1798.80(e) of the California Civil Code. Personal information does not include publicly available information in government records, nor does it include any de-identified or aggregated consumer information. Additionally, CCPA excludes from its scope the following information: Health Insurance Portability and Accountability Act of 1996 (HIPAA) and California Confidentiality of Medical Information Act (CMIA) ) or health or medical information covered by clinical trial data; and certain industry-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act (FIPA) and Personal Information covered by the Driver's Privacy Protection Act of 1994. FOOMKIT LTD obtains the above categories of personal information directly from you (for example, from forms you fill out or products and services you purchase) and/or indirectly from you (for example, by observing your behavior on our website). Use of personal information We may use or disclose the personal information we collect for the purposes described in the "How we will use your information" section above. share personal information FOOMKIT LTD may disclose your personal information to third parties for business purposes. When we disclose personal information for a business purpose, we will enter into a contract describing the purpose and require the recipient to keep the personal information confidential and not use it for any purpose other than the performance of the contract. The CCPA prohibits third parties who purchase personal information in our possession from resale of that information unless you receive express notice and have the opportunity to object to the resale. FOOMKIT LTD shares your personal information with the various third parties listed above under "Our Disclosure of Your Information". Specifically, in the past twelve (12) months, FOOMKIT LTD has disclosed the following categories of personal information for business purposes: Identifiers; California Customer Records Act (California Customer Records) categories of personal information; subject to California law or classified characteristics protected by federal law; business information; Internet or other similar network activity; geographic location data; professional or recruitment-related information (prospective employees only); non-public educational information (prospective employees only); Inferences drawn from personal information. sell personal information In the past twelve (12) months, FOOMKIT LTD has not sold personal information. Your rights and choices (a) Right to know about personal information collected, disclosed or sold You have the right to request that we provide you with certain personal information about you that we have collected and used over the past twelve (12) months. Specifically, you have the right to request disclosure of the categories and specific personal information we have collected about you from you over the past 12 months. After submitting a verifiable consumer request (see Exercising Your California Privacy Rights), we will disclose to you: the categories of personal information we collect about you; The categories of sources of personal information we collect about you; Our business or commercial purpose for collecting that personal information; Our business or commercial purpose for selling or disclosing that personal information; and The categories of third parties with whom we share this personal information. If you also request access to specific personal information we collect about you (subject to certain exceptions under applicable law), we will also provide that information. In addition, if we sell or disclose your personal information for a business purpose, we will also specify: (i) the categories of personal information about you that we sell; (ii) the categories of third parties to whom the personal information is sold by The categories of each third party to whom your personal information is sold; and (iii) the categories of personal information we disclose about you for business purposes. (b) Right to request deletion of personal information If you are a California resident, you also have the right to request that we delete any personal information about you that we have collected and retained from you, subject to certain exceptions. Once we receive and acknowledge your verifiable consumer request, we will conduct a reasonable search of our records for any deletable personal information we have collected about you and delete such personal information. If we have shared any personal information we have collected about you with service providers who are eligible for deletion, we will instruct those service providers to delete that personal information as well. However, for clarity, FOOMKIT LTD may not be able to fully comply with your request to delete all of your personal information under the CCPA. For example, if you place an order with us, the CCPA allows us to keep records related to these types of transactions in order to complete the transaction for which your personal information was collected. Specifically, we and our service providers are not required to delete any personal information we collect about you in order to: To complete transactions for which personal information was collected, to fulfill written warranties or product recall provisions enforced under federal law, to provide goods or services that you have requested that are reasonably expected in our ongoing business relationship with you, or to fulfill FOOMKIT LTD’s relationship with you between the contracts. Detect security incidents and prevent malicious, deceptive, fraudulent or illegal activity; or prosecute those responsible for that activity. Debug to identify and fix bugs that impair existing intended functionality. Exercising freedom of speech, safeguarding other consumers' rights to exercise their freedom of speech, or exercising other rights provided by law. Comply with the California Electronic Communications Privacy Act pursuant to Title 12, Title 12, Chapter 3.6 of the Penal Code (beginning with Section 1546). If you have provided informed consent to participate in public or peer-reviewed scientific, historical or statistical research that complies with all other applicable ethics and privacy laws and is in the public interest, our deletion of information may render such research unattainable or subject to serious damage. Only conduct internal uses that are reasonably consistent with your expectations based on your relationship with us. To comply with a legal obligation, such as by Keep records for as long as required by local, state or federal law. Otherwise, use your personal information internally and in a lawful manner consistent with the circumstances in which you provided the information. Upon receipt of a deletion request, your personal information that has not been deleted from our systems will only be used for the purposes specified in the applicable exceptions. Accordingly, all personal information about you that is not subject to the deletion exception will be: (1) permanently deleted on our existing systems (except for archival or backup systems maintained for emergency disaster recovery and business continuity purposes); ( 2) De-identification; or (3) Aggregation not specific to you (c) Right not to be discriminated against for exercising consumer privacy rights We will not discriminate against you for exercising any privacy rights. Except as permitted by applicable law, we will not: refuse to provide you with goods or services. Charge you different prices or rates for goods or services, including by granting discounts or other benefits or imposing penalties. To provide you with goods or services of different grades or qualities. Indicates that you may obtain goods or services at different prices or rates, or obtain goods or services of different grades or quality. However, we may offer you certain financial incentives permitted under the CCPA, which may result in different prices, rates or quality levels. Any CCPA-allowed financial awards we offer will be reasonably related to the value of your personal information and contain written terms describing the substance of the program. Participation in the Financial Rewards Program requires your prior opt-in consent, which you may withdraw at any time. (d) Exercise Your California Privacy Rights To exercise your rights of access and deletion described above, please submit a verifiable consumer request to us via our contact details: Only you, or a person registered with the California Secretary of State who you authorize to act on your behalf, may make verifiable consumer requests related to your personal information. However, you may make verifiable consumer claims on behalf of your minor child. You may designate an authorized representative to represent you and submit a verifiable consumer request through the online application portal. Additionally, you may only initiate 2 verifiable consumer access requests within a 12-month period. Your verifiable consumer request must: (i) provide sufficient information to enable us to reasonably verify that you are the person to whom we collected personal information or an authorized representative; (ii) describe your request in sufficient detail to enable us to Correctly understand, evaluate and respond to your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make a request and confirm the personal information about you. We will only use personal information provided in a verifiable consumer request to verify the requester's identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us. (e) Time and form of responses We will do our best to respond within 45 days of receiving a verifiable consumer request. If we need more time (up to 90 days), we will notify you in writing of the reason and the extended period. Within ten (10) days of receipt of the request, we will acknowledge receipt and provide information regarding our verification and processing of the request. FOOMKIT LTD will maintain records of consumer requests required by CCPA and our responses to such requests for a minimum period of twenty-four (24) months. If you have an account with us, we will provide you with a written response through that account. If you do not have an account with us, we will provide you with a written response by mail or electronically, at your option. Any disclosures we provide will only include information within the 12 months prior to receipt of your request. The response we provide will also explain why, if any, we were unable to complete the request. For data transfer requests, we will choose a form for providing your personal information that will allow you to transfer the information from one entity to another without hassle. We will not charge a fee for processing or responding to your verifiable consumer request unless the request is excessive, repetitive, or manifestly unfounded. If we believe the request requires payment, we will tell you the reasons for our decision and provide you with a cost estimate before completing your request Your Rights Under California Privacy Laws (Shine the Light) In addition to your rights under the CCPA, California Civil Code Section 1798.83 allows California residents to request personal information, if any, of that resident that we disclose to third parties for their direct marketing purposes. If applicable, you can obtain the names and addresses of all third parties who obtained personal information for direct marketing purposes in the preceding calendar year and the categories of personal information shared (for example, requests made in 2018 will receive information on the information shared in 2017 event information). To make such a request, please provide sufficient information for us to determine whether the request applies to you, demonstrate that you are a California resident, and provide a current California address for us to respond to. You can make this request to us in writing through our Privacy Portal. Relevant Provisions of the People's Republic of China on Personal Information Protection about us This section "Relevant Provisions of the People's Republic of China on the Protection of Personal Information" applies to the processing of personal information collected in China by FOOMKIT LTD and its affiliated entities ("we"). Information we collect According to the "Personal Information Protection Law of the People's Republic of China", personal information refers to all kinds of information related to identified or identifiable natural persons recorded in electronic or other ways, excluding anonymized information. Sensitive personal information refers to personal information that, once leaked or used illegally, is likely to cause damage to the personal dignity of natural persons or endanger personal and property safety. We collect and use your following information through websites, applications, H5 pages, consumer hotlines, offline writing and other channels in accordance with the principles of legality, righteousness and minimum necessity and only for the purpose of realizing this privacy policy: A. Personal Information Collected: yes For example: this category may include: Basic information: your WeChat nickname, WeChat avatar, location, username, name, gender, nationality, date of birth; Contact: email address, telephone number; Information required for transaction logistics and distribution: mailing address; your preferences and interests; Information that may be disclosed when you contact us; Login data (such as your IP address, your terminal characteristics and your logs).
B. Sensitive Personal Information
Collected: yes
For example: This category might include: Your credit card number, payment account information, ID number. .
Use of personal information
We may use or disclose the personal information we collect for the purposes described in the "Our Use of Your Information" section above.
Delegated processing
We may entrust third parties such as partners to process your personal information to ensure the smooth completion of the services provided to you. However, we will only entrust a third party to process your personal information for legal, legitimate, necessary, specific and explicit purposes, and will only entrust a third party to process the personal information necessary for the service. Our third-party partners are not authorized to use the entrusted personal information for any other purpose.
transfer personal information
We will not transfer your personal information to any companies, organizations and individuals, except in the following cases: We will transfer your personal information to other parties after obtaining your express consent or authorization; When a merger, acquisition or bankruptcy liquidation is involved, if it involves the transfer of personal information, we will require new companies and organizations that hold your personal information to continue to be bound by this Privacy Policy, and will inform you of the company, The name and contact details of the organization. Otherwise, we will require the company or organization to seek authorization from you again. Public disclosure of personal information
We will not publicly disclose your personal information, except for necessary public disclosure due to displaying relevant desensitized information when announcing account winnings, or obtaining your separate consent.
Cross-border transfers of personal information
In principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China.
For the needs of unified management of the group, we need to share your personal information with third parties located in countries or regions outside China (such as Australia) to complete and provide corresponding services. Privacy-related laws in these countries or regions may differ from those in China. We will abide by the relevant laws of personal information protection in China, and try our best to ensure that these third parties who obtain your personal information will provide similar and/or comparable levels of personal information safeguards.
Safety precautions
We employ appropriate physical and electronic procedures to protect the personal information we collect, as described in the "Security" section above.
Your rights and choices
(a) Access, copy, correct, amend your personal information
You have the right to access, copy, correct, and modify your personal information, subject to exceptions provided by laws and regulations.
(b) delete your personal information
if our processing purposes have been achieved, cannot be achieved or are no longer necessary to achieve the processing purposes;
If we terminate our services and operations, or if the retention period has expired;
if you withdraw your consent;
If our processing of personal information violates laws and regulations or violates our agreement with you.

(c) obtain a copy of your personal information
You have the right to obtain a copy of your personal information. Under the premise of technical feasibility, such as data interface matching, we can also directly transmit a copy of your personal information to a third party designated by you upon your request.
(d) change the scope of your consent or withdraw your authorization
You can change the scope of your authorization for us to continue processing personal information or withdraw your authorization at any time by contacting us.
Please understand that when you withdraw your consent or authorization, we cannot continue to provide you with some or all of the services corresponding to the withdrawal of your consent or authorization, and we will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the previous processing of personal information based on your consent or authorization.
(e) Exercising your rights related to the protection of personal information of the People's Republic of China
To exercise your above rights, please submit a verifiable consumer request to us via our contact details:
(f) Time and form of responses
For security purposes, we may require you to provide a written request, or otherwise prove your identity, and we will respond to your request within 15 business days of receiving your feedback and verifying your identity.

Handling Rules for Sensitive Personal Information
We may collect your sensitive personal information. Before collecting your sensitive personal information, we will obtain your authorization and consent separately.
(a) Necessity for processing sensitive personal information
Your sensitive personal information that we collect may include: your credit card number, payment account information, ID number.
(b) Impact on your rights
If your sensitive personal information is leaked or used illegally, your personal dignity may be violated or your personal and property safety may be endangered.
At the same time, please be aware that we have taken strict protective measures to prevent the leakage or illegal use of your sensitive personal information. In the event of a security incident such as personal information leakage, we will activate an emergency plan in accordance with the law, and inform you of the relevant situation, impact, and measures to be taken by means of push notifications, announcements, etc.

Privacy Policy for Minors
If you are under the age of 18, please do not provide us with your personal information. Please consciously abide by these fiduciary obligations so that we can better protect your personal information.

Storage of personal information
Generally, we will retain your personal information for the shortest period necessary to achieve the purposes for which it was collected (as set out in this Privacy Policy), unless longer retention periods are required by law.
For registration information, we will retain the information of the active users of the website as we determine, and continue to retain the information for 2 years after the inactivity.
For personal information processed for promotional purposes or your consent, we will continue to process the information until you ask us to stop, and continue to retain it for a short period (to allow us to process your request). We will also permanently record your request to cease direct marketing or processing of your information so that we can comply with your request in the future.
For personal information related to contract performance (such as your purchase of products and services from us) or activities, we will retain your information for 3 years after your last interaction with us. We will retain personal information for 3 years for website security and/or fraud management purposes. After the storage of personal information expires, we will delete it, anonymize it, or take other processing methods approved by laws and regulations.

Scope of application
Any entity, company, individual, resident, citizen, legal person, document, data, information, article related to the People's Republic of China

Policy Effective Date
This Privacy Policy remains in effect and was last updated in October 2021. From time to time, we may publish new versions of this Privacy Policy and update this Privacy Policy. We will also notify you of updates to this Privacy Policy by email or other prominent means.

contact details privacy@o3omail.com