Privacy Policy

Last updated: October 28, 2022

About Us

Smoore International Holdings Limited, Smoore Technology (Shenzhen) Limited and/or its affiliates (“Smoore” or “We”) value your privacy. We understand the importance of your Personal Information, and we are committed to protecting your Personal Information by taking appropriate security measures in accordance with legal and regulatory requirements as well as proven industry security standards.

This Privacy Policy

We make this Privacy Policy to describe how we collect and process your Personal Information, and then you may know how you share with us, what you share with us, and how we use your Personal Information. We may provide additional privacy information by using a supplementary privacy notice.

You are agreeing to the practices described in this Privacy Policy by using our Service. IF YOU DISAGREE WITH THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY, YOU’RE SUGGESTED TO STOP ACCESS OR USE THIS WEBSITE AND OUR SERVICE.

1. What Personal Information about You Are We Collecting?

This Smoore website mainly provides information browsing for you, in this case, we normally do not collect any Personal Information from you as it does not require any registration. However, if we do so, we will collect and process your Personal Information in accordance with this Privacy Policy, particularly when you use certain sections of our website such as "Social Recruitment", "Campus Recruitment", "Contact Us" and "Investor Contact", etc.

The Personal Information we collect from you may include three types:

(1)    The information you provide to us in connection with our website or service.

Include but not limited to your name, your email address, your physical address, your phone number, your gender identification, your verified age, credit card or payment information, age verification information, any ID you’ve used to verify your age, your warranty number, any claims or issues you've reported to us, profile information like your account id, your password, your communications (submissions, comments, and feedback) with us through the “Contact Us” section of our website, any surveys or questionnaires we conduct in different ways, and any other information related to your use of this website and our service.

(2)    The information we collect and store automatically during your use of this website and our service.

Include but not limited to your IP address when you connect to our website, browser and operating system you used to access our website, the movement of your mouse on the screen, the length of time you spend on our site, any extensions you pair with ours, and other information we collect and stored automatically in connection with your use of this website and our service.

(3)    The information we receive from other sources.

Include any information we may receive from any sources rather than ourselves, but we only get those information in legal ways and for legitimate purposes.

2. Why and How We Use Your Personal Information?

The reason why we use your Personal Information is because we need to use them to operate, provide, develop and improve our website and service for you. 

We may use your Personal Information for verifying your age, communicating with you, providing service to you, providing marking information to you, managing our services and any other necessary and applicable usage permitted by applicable law.

We collect and process your Personal Information only to the extent of the purpose herein or separately authorized by you, and we will do so in accordance with the principles of lawfulness, legitimacy and necessity.

3. What about Cookies and Other Identifiers?

We may use cookies and other identifiers to manage our systems and make them can recognize your browser or device, or provide and improve our services.

We use cookies and similar tracking technologies to track the activity on our service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service. Examples of Cookies we use:

· Session Cookies. We use Session Cookies to operate our service.

· Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

· Security Cookies. We use Security Cookies for security purposes.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.

4. Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

5. Do We Share or Disclose Your Personal Information?

We may share your Personal Information with our group companies to develop and provide our services to you.

In certain situations, if necessary, we may share your Personal Information to third party employed by us to perform certain functions on our behalf in relation to service. Such companies include server services providers, data analysis services providers, fraud monitoring and prevention providers, email delivery service providers, social media, and other marketing platforms and service providers.

We may share your Personal Information when we make available to your services, products, applications, or skills provided by third parties for use on or through our Service. However, in such cases, the third parties may have their own privacy policy, we will not guarantee third parties’ compliance. Please read their privacy policies carefully before choosing the third party-related services.

We may share your Personal Information to parties we buy, sell, transfer, or merge parts of our business with.

We may disclose your Personal Information when get your consent to make the disclosure or when it is reasonable for us to believe disclosure is appropriate to comply with the law, enforce or apply our Terms of Use and other agreements, or protect the rights, property, or safety of our business, customers or others.

6. Lawful basis for processing

Pursuant to the applicable data protection laws, we normally process your personal information under the following lawful bases:

· Your consent;

· The performance of the contract between you and us;

· Compliance with our legal obligations;

· To protect your vital interests;

· To perform a task carried out in the public interest;

· For our legitimate interests, which do not override your fundamental rights and freedoms, in particular, our legitimate interest may include, to operate our platform and communicating with you as necessary to provide our services to you, keep network and information security, detecting or preventing illegal activities, internal management of our customer information through our system, internal analysing, direct marketing related to our services.

7. How Secure Is Personal Information About You?

Although no method of transmission over the Internet or electronic storage is 100% secure, we use using encryption protocols and software during the transmission of your Personal Information. We make certain reasonable precautions and follow industry best practices to make sure your Personal Information will not be inappropriately lost, misused, accessed, disclosed, altered or destroyed. 

You agree to protect your Personal Information against unauthorized access to your password and to your computers, devices, and applications by signing off your account when finished using a shared device.

8. Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so, in particular, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements.  

When we have no ongoing legitimate business need to process your personal information, we will either delete, deidentify or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Specifically, our website servers are located in China, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information, we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy.

10. Automatic Decision-Making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We DO NOT engage in fully automated decision-making that has a legal or otherwise significant effect using your data.

11. Do Not Sell Your Personal Information

We never sell your personal information, and do not intent to sell your personal information either.

12. Your Data Protection Rights

According to applicable laws, you may have the following data protection rights:

You may access your Personal Information, including your name, password, email address, physical address, payment options, profile information, website settings, and your order history in the account.

If you find it necessary, you may correct, amend, limit usage of, or delete certain your Personal Information, or withdraw your consent, if it is inaccurate or has been processed in violation of the applicable data protection laws.

According to applicable data protection laws, you may have the right to data portability, you may request to receive data that is processed based on your consent or on a contract entered into with you, in a structured format and readable by an automated device. If you wish, where this is not excessive and technically possible, we may, at your request, transfer your data directly to a third party indicated by you.

You may also have the right to object to processing of your personal information provided there are reasons for this arising from your particular situation or if your objection is based on being targeted to personal advertising. In the latter case, you have a general right of objection, which is implemented by us without any particular situation being specified.

In addition to the rights above, if you are a resident of California, you have the right to opt out our data sharing with our independent third parties.

Applicable data protection laws may also provide you with other data protection rights. If you need other information, you can contact us through the contact information set out below.

We may provide service for the things you requested in accordance with the requirements (e.g., timeframe of response) of applicable data protection laws, you can submit your request or contact us by sending emails to the address set out below, however, please note our service related to your request may be limited or unavailable when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to your privacy, or where other parties’ legal rights may be infringed.  

You also have the right to complain to a data protection authority about our collection and use of your personal information.

13. Minors

Our services are not available to anyone under the age of 18 (“Minor”).

We do not knowingly collect personally identifiable information from any Minors. If you are a parent or guardian and you are aware that your Minor child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Minor children, we will take steps to remove that information from our systems.

14. Contact Information

If you have any questions regarding this Privacy Policy, our website or service, you may contact us by sending emails to [  ].

15. Changes to This Privacy Policy 

We may update or amend this Privacy Policy at any time by direct electronic notification to you or by publishing the updated version on this page. All amended terms will automatically be effective immediately on posting.