Privacy Policy

This policy applies to all products and services provided in China by “Hongfeng Intelligent Home Technology (Beijing) Co., Ltd.”, “HC28”, and “HC28 COSMO”. This includes both online and offline shopping experiences, customer services, membership services, product promotions, and distribution of promotional materials.

“Hongfeng Intelligent Home Technology (Beijing) Co., Ltd.” (hereinafter referred to as “we”) understands the importance of personal information to you and will do its utmost to protect the security and reliability of your personal information. We are committed to maintaining your trust, protecting your personal information, and promise to take appropriate security protection measures according to mature industry standards to safeguard your personal information. Please read and understand this Privacy Policy carefully before using our products (or services), especially the terms marked in bold. By choosing to use or continue to use our services, it means that you fully understand the entire content of this Privacy Policy and agree that we will collect, use, store, and share your relevant information in accordance with this Privacy Policy. If you have any questions, comments, or suggestions, you can contact us through the contact information listed in the "Any Questions" section of this policy.

Note: This version of the Privacy Policy will take effect on August 2, 2024.

Contents

How We Collect and Use Your Personal Information

How We Use Cookies and Similar Technologies

Will Your Personal Information Be Shared, Transferred, or Disclosed?

Your Rights

How We Handle Minors' Personal Information

How Your Personal Information is Transferred Globally

How This Policy is Updated

Questions and Concerns

How We Collect and Use Your Personal Information

We provide a variety of products and services and are committed to creating a better daily life for the public. When you use our products or services, we will only collect and use your personal information for the purposes stated in this policy.

We collect and use your personal information in the following scenarios:

To provide you with products or services, we need to collect and use your necessary personal information. If you do not provide or do not agree to our collection and use of such personal information, it may cause the relevant products or services to not function properly, or we may not be able to provide you with the related products and services. The specific channels, scenarios, and functions of collecting and using personal information include:

(1) Official Website

A. Online Services and Experience

Register/Login Account: You do not need to register or log in to browse the "HC28 COSMO" official website. However, when you download the required materials from our online channels, you need to register an account and log in. When registering or logging in, you may need to provide your phone number, email address, and depending on the registration or login method you choose, provide an email address or WeChat account information. To protect your account security, you need to set or enter a password for your account; we will also send a verification code to your provided email to verify the authenticity and validity of your identity. You can also choose to link your account with membership information to enjoy the corresponding membership benefits. If you forget your password, we will collect your email address and send and collect a verification code to reset your password.

Receiving Marketing Information: You can choose whether to receive marketing information sent by us, or our affiliated companies, or service providers through phone, email, SMS, or printed materials. For marketing emails from HC28| HC28 COSMO, you can choose to subscribe or unsubscribe via the link in the email.

(2) Consulting, After-Sales

A. Hotline, Online Chat, and Email Customer Service

To provide you with more convenient and personalized services, we will match your personal information and historical complaint records based on your call number, email address, or login account. To complete customer service, customer service personnel may also contact and communicate with you through the phone number or email address you provide.

B. After-Sales Service

To verify and resolve the issues you raise, we will use the personal information and purchase proof you provide to query your relevant account information or membership information, as well as related order information, consultation, and complaint history.

Identity Verification

To protect your account security, our customer service personnel will use your account information, membership information, or information on your purchase proof to verify your identity. When you need us to provide customer service and after-sales service related to your order, we will query your order information.

You are fully aware that in the following situations, we may collect and use personal information without your authorization and consent:

Necessary for the conclusion or performance of a contract to which you are a party;

Necessary for fulfilling statutory duties or obligations;

Necessary for responding to public health emergencies or for protecting the life, health, and property of natural persons in emergencies;

Necessary for news reporting, public opinion supervision, and other acts carried out in the public interest, within a reasonable range;

Reasonable processing of personal information that you have disclosed or other legally disclosed information;

Other circumstances stipulated by laws and administrative regulations.

Rules for Using Your Personal Information

We will use your personal information for the following purposes:

We will use your personal information to provide our products and services according to this privacy policy;

To ensure service stability and security, we will use your personal information for identity verification, security precautions, fraud detection, prevention or prohibition of illegal activities, risk reduction, archiving, and backup;

We will use your personal information for data analysis to help further improve HC28 products and services and provide you with more suitable products and services;

We will share your personal information with government agencies, judicial institutions, or other third parties designated by law, regulations, or regulatory requirements;

We may conduct statistics on the usage of our products or services and may share statistical information that does not contain your personal information with the public or third parties to show the overall usage trends of our products or services.

When we use your personal information for purposes not specified in this policy, we will seek your consent in advance or rely on other legal bases.

How We Use Cookies and Similar Technologies

Use of Cookies: Our website and app have various useful Cookie features, and we store small data files called Cookies on your computer or mobile device. Cookies are small files that typically contain identifiers, site names, and some numbers and characters. With the help of Cookies, our website and app can record your activity information during browsing to make your next visit to the website or app easier and faster. For example, we use Cookies to remember your preferred language and other personal browsing preferences and to count the number of website visitors. Cookies cannot be used to "steal" information about you or your computer system, so you don't need to worry about personal privacy issues arising from this. We will not use Cookies for purposes other than those stated in this policy. You can manage or delete Cookies according to your preferences.

Web Beacons and Pixel Tags: In addition to Cookies, we also use other similar technologies like Web Beacons and Pixel Tags on our website and app. We use Web Beacons and Pixel Tags on the website and app to count the number of users visiting and to collect statistics on users' preferences. The emails we send to you may contain URLs that link to our website and app. If you click on that link, we will track the click to help us understand your preferences for products or services and improve our services. If you do not wish to be tracked in this way, you can unsubscribe from our mailing list at any time.

Will Your Personal Information Be Shared, Transferred, or Disclosed?

Sharing with Third Parties: Based on our business needs, your personal information may be shared within the domestic dealer system to provide you with better services. We will disclose the specific situation to you and obtain your separate consent or rely on other legal bases to share it with our affiliated companies. We promise that all sharing is limited to your necessary personal information and is subject to this privacy policy. If we need to change the purpose of using and processing personal information, we will seek your consent again. We will also strictly comply with relevant laws and regulations for cross-border data transmission. Please refer to the "How Your Personal Information is Transferred Globally" section of this privacy policy for more details.

We will not share your personal information with any company, organization, or individual outside the franchise system, except in the following cases:

Sharing with Explicit Consent: We will share your personal information with others after obtaining your explicit consent.

Legal Sharing: We may share your personal information according to laws and regulations or mandatory requirements of government authorities.

Sharing with Authorized Partners: To achieve the purposes stated in this policy, some of our services will be provided by authorized partners. We may share certain personal information with partners to provide better customer service and user experience. We will list the situations where your personal information is shared with authorized partners in the "Personal Information Third-Party Sharing List."

We will sign strict confidentiality agreements with companies, organizations, and individuals with whom we share personal information, requiring them to process your personal information according to our instructions, this privacy policy, and any other relevant confidentiality and security measures.

Entrusted Processing

To provide you with relevant products and services, we may engage third-party service providers to assist in delivering related operational and service support. We may share your personal information (i.e., information that can identify you, including your name, contact information, email address, and device identification code) with suppliers, service providers, and other partners who support our business operations, in order to provide logistics services, delivery services, installation services, technical services, marketing information dissemination, analysis of service usage, measurement of advertisement and service effectiveness, and customer support. For instance, the types of personal information that may be processed by our partners include but are not limited to the following:

1. Logistics Service Providers: To fulfill your order, we may share the recipient's name, contact information, address, and order details you have provided with logistics service providers to facilitate delivery services.

2. Advertising and Data Analysis Authorized Partners: We will not share your personally identifiable information (i.e., information that can identify you, including your name or email address, through which you can be contacted or identified) with partners providing advertising or data analysis services without your consent. However, we may share device information and browsing data with data analysis partners to provide you with personalized content and enhance service quality. To monitor the effectiveness of advertisements placed by HC28, we may engage third-party partners to collect your device information and track the clicks and browsing data related to the advertisements and our services.

3. Installation Service Providers: To offer installation services, we may share your name, contact information, address, and order details with installation service providers to facilitate the installation process.

4. Technical Service Providers: Technical service providers may remotely access your personal information from overseas to deliver technical support services.

Transfer of Personal Information

We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:

1. Transfer with Explicit Consent: We may transfer your personal information to other parties after obtaining your explicit consent.

2. In the Event of a Merger, Division, Dissolution, or Bankruptcy: If your personal information is involved in a transfer due to a merger, division, dissolution, or bankruptcy liquidation, we will require the new entity holding your personal information to continue to be bound by this policy, or we will require that entity to seek your authorization and consent again. We will fulfill the corresponding notification obligations as required by law.

Public Disclosure

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

1. After obtaining your separate consent.

2. Disclosure Based on Law: We may publicly disclose your personal information in cases where it is required by law, legal procedures, litigation, or mandatory requests from government authorities.

Retention of Your Personal Information

We will retain your personal information for the shortest period necessary to achieve the purposes outlined in this policy. We will also comply with mandatory personal information retention periods as stipulated by laws and regulations. For example, under the "E-Commerce Law of the People's Republic of China," your transaction information, including details of goods and services involved in the transaction, will be retained for no less than three years from the date the transaction is completed. After the retention period expires, we will delete your personal information or anonymize it in accordance with applicable legal requirements.

Your Rights

We will implement appropriate technical measures to ensure your rights to access, update, correct, or delete your personal information, and provide you with various options related to the collection, use, sharing, and storage of your personal information.

Right to Access and Update/Correct Information

You may access and view your personal information, historical shopping orders, and other related data left with HC28 | HC28 COSMO through the account management page provided via our website or other online channels. For example, you can access and view your personal information in the "My Profile" section on our website.

You have the right to update or correct any erroneous, outdated, or incomplete personal information. You may update or modify your personal information on the corresponding pages mentioned above. For example, if you change your phone number, you should promptly update the phone number associated with your account to protect the security of your personal information.

If you need to access or correct other personal information generated while using our products or services, please feel free to contact us. We will respond to your request in accordance with the methods and timelines outlined in this Privacy Policy. However, please note that due to technical limitations or security considerations, we may not be able to provide access to or update/correct certain personal information.

Right to Copy

You have the right to obtain a copy of your personal information. If you wish to receive a copy of the personal information we have collected about you, you may contact us using the information provided in the "Any Questions" section. We will provide a copy of your personal information upon request, subject to applicable legal requirements and technical feasibility.

Right to Erasure

You have the right to request the deletion of your personal information under the following circumstances: (a) If we have collected or used your personal information in violation of laws and regulations; (b) If we collected your personal information without legal grounds, or if you have withdrawn your consent; (c) If we have violated our agreement with you in collecting or using your personal information; (d) If you have cancelled your account; or (e) If we no longer provide products or services to you.

You may request the deletion of your personal information by contacting us using the information provided in the "Any Questions" section.

Right to Withdraw Consent

Each of our business functions requires certain basic information to operate. You may change or withdraw your consent regarding the scope within which we can process your personal information by deleting information or disabling device permissions. You may also withdraw your consent for us to continue collecting your personal information by cancelling your account. For any additional personal information we have collected, you may grant or withdraw your consent at any time. If you require any assistance during this process, please contact us using the information provided in the "Any Questions" section.

Right to Restrict/Refuse Processing

You have the right to restrict or refuse the processing of your personal information. You may contact us using the information provided in the "Any Questions" section to request the restriction or refusal of our processing of your personal information.

Right to Refuse Automated Decision-Making

You have the right to refuse the use of automated decision-making processes for information push notifications, commercial marketing, and to request an explanation of any decisions made solely by automated means that have a significant impact on your personal rights. You may also refuse to have such decisions made solely by automated means. You can contact us using the information provided in the "Any Questions" section to exercise these rights.

If we are required by applicable laws and regulations to collect, use, or share your information, we may refuse your request to the extent permitted by applicable laws and regulations. We reserve the right to adjust your rights in accordance with applicable laws and regulations.

Responding to Your Requests

To ensure security, you may be required to submit a written request or otherwise verify your identity. We may require you to verify your identity before processing your request. We will respond to your request within 15 business days.

For reasonable requests, we do not charge a fee in principle. However, for repeated requests or those that exceed reasonable limits, we may charge a reasonable fee based on the costs incurred. We may refuse requests that are unduly repetitive, require excessive technical means (e.g., developing new systems or fundamentally changing current practices), pose risks to the legitimate rights of others, or are otherwise impractical.

We will not be able to respond to your request under the following circumstances, as required by laws and regulations:

If it is directly related to national security or defense security;

If it is directly related to public safety, public health, or major public interests;

If it is directly related to criminal investigation, prosecution, trial, and judgment enforcement;

If there is sufficient evidence that you have malicious intent or are abusing your rights;

If responding to your request would cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

If it involves trade secrets;

Any other circumstances as required by laws and regulations.

How We Handle Minors' Personal Information

Hongfeng Intelligent Home Technology (Beijing) Co., Ltd. does not intentionally seek or collect personal information from minors under the age of 18. In the event that services are provided to minors, we may, based on the principles of clear purpose and minimal necessity, collect personal information of minors under 18 directly from their parents or guardians, with their explicit consent.

Before using our services, please ensure that you are an adult, or that you are using our services under the guidance of a parent or guardian. Parents and guardians are advised to carefully read our privacy policy before providing us with any information about minors, in order to better protect your child.

Hongfeng Intelligent Home Technology (Beijing) Co., Ltd. will not send any marketing information to minors. If we discover that we have collected personal information from a minor without verifiable parental consent, we will make every effort to promptly delete the relevant data.

How Your Personal Information is Transferred Globally

In principle, the personal information we collect and generate within the People's Republic of China (PRC) will be stored within the PRC. However, as Hongfeng Intelligent Home Technology (Beijing) Co., Ltd. conducts international business, and for the purposes of global operations and management, we may provide products or services through resources and servers located worldwide. This means that, with your authorized consent, your personal information may be transferred to or accessed from a jurisdiction outside of the PRC where you use our products or services.

These jurisdictions may have different data protection laws, or in some cases, may not have established relevant laws. In such instances, we will ensure that your personal information receives adequate protection equivalent to that provided within the PRC. We will always take necessary measures during management, technical processing, and other procedures to ensure the security of your information, preventing it from being compromised by foreseeable risks.

How This Policy is Updated

We may periodically update this policy to reflect changes in national laws and regulations, as well as adjustments to our service policies. Your continued use of our services will be deemed as your acceptance of the relevant adjustments to this privacy policy.

We will not diminish the rights you are entitled to under this privacy policy without your explicit consent. For significant changes, we will provide more prominent notices (including, for certain services, sending notifications via email to outline the specific changes in the privacy policy).

Significant changes referenced in this policy include, but are not limited to:

Major changes to our service model, such as changes in 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 or organizational structure, such as ownership changes resulting from business adjustments, bankruptcy, mergers, and acquisitions;

Changes in the primary recipients of personal information sharing, transfer, or public disclosure;

Significant changes to your rights and the methods through which you can exercise them regarding personal information processing;

Changes in the department responsible for personal information security, contact methods, or complaint channels;

When the personal information security impact assessment report indicates a high level of risk.

We will also archive previous versions of this policy for your reference.

Questions and Concerns

If you have any questions or concerns regarding this policy or the handling of your personal information, you may contact us through the following customer service hotline. Generally, we will respond within 15 business days.

Customer Service Hotline of “Hongfeng Intelligent Home Technology (Beijing) Co., Ltd.”: 400-900-2128
Customer Service Email of “Hongfeng Intelligent Home Technology (Beijing) Co., Ltd.”: info@hc28.com.cn

This privacy policy is written in both Chinese and English, and both versions have equal legal effect. In the event of any inconsistency between the Chinese and English versions, the Chinese version shall prevail.

You agree that any disputes arising from this policy between you and us (hereinafter referred to as "disputes") shall be governed by the laws of the People’s Republic of China, excluding conflict of law rules. Unless prohibited, you agree that any disputes, claims, and litigation arising directly or indirectly from or related to this policy shall be resolved by a court of competent jurisdiction in the location of the operator in accordance with the laws of the People’s Republic of China.