Privacy Policy

(A) This Policy

This Policy is issued by Athom Technology Co.,Ltd (together, “Athom”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, or recipients of any of our other products, services, personnel of corporate customers and vendors, applicants for employment, and visitors to our premises (together, “you”). Defined terms used in this Policy are explained in Section (X) below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, Personal Information or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

You may also have certain rights regarding the information we collect about you. Specifically, the rights of Data Subjects under the GDPR are explained in Section (N) below. Similarly, U.S. residents in general and California Residents in particular may find information on their rights as a Consumer in Section (U) below.

Intended Audience: Our Sites, products, or services are not directed to children under the age of 13. As a result, our Sites, products, or services do not request or knowingly collect personal information from individuals under the age of 13. If you are not 13 or older, you should not visit or use our Sites, products, or services .

This Policy was last updated on June 5th, 2022.

(B) Collection of Personal Data

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

Data provided to us: We obtain Personal Data when those data are provided to us (e.g., when you register an account with us; where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).
Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you).
Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, products, or services.
Content and advertising information: If you interact with any third party content or advertising on our Site(including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, products or services, including where those data are collected from different devices.

(D) Categories of Personal Data we Process

We Process the following categories of Personal Data about you:

Personal details: given name(s); preferred name; and photograph.
Demographic information: gender; date of birth / age; nationality/district; and language preferences.
Contact details: address; shipping address; telephone number; email address; online messaging details; and social media details.
Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
Purchase details: records of purchases and prices; consignee name; address; contact telephone number; email address; details of returns; warranty details;
Payment details: invoice records; payment records; billing address; payment method; last four digits of bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date.
Data relating to our Sites: Internet Protocol (IP) address; internet service provider; referring/exit pages; language settings; dates and times of connecting to a Site.
Server logs: records of events on our servers, including search queries; IP addresses; hardware settings; browser type; browser language; the date and time of request; referral URL; and certain cookies that identify your browser or Account.
Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part).
Views and opinions: any comments, views and opinions that you choose to send to us, or publicly post about us on social media platforms.
Cookie data: personal data collected via cookies and other similar technologies

(E) Purposes of Processing and legal bases for Processing

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.

To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at support@athom.tech and be sure to include your name, testimonial location, and contact information.

Request feedback. We may use your information to request feedback and to contact you about your use of our Website.

To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.

To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

To send administrative information to you. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.

To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).

To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements, or in connection with our contract.

To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.

Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

To deliver and facilitate the delivery of services to the user. We may use your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing, or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).

Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

(F) Disclosure of Personal Data to third parties

We disclose Personal Data to other entities within the Athom, for legitimate business purposes and the operation of our Sites to you, in accordance with applicable law. In addition, we disclose Personal Data to:

you and, where appropriate, your appointed representatives;
legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
accountants, auditors, consultants, lawyers and other outside professional advisors to Athom, subject to binding contractual obligations of confidentiality;
third party Processors (such as email service providers; marketing/advertising service providers; venue operators; payment services providers; shipping companies; postal carriers; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
any relevant third party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

(G) International transfer of Personal Data

Because of the international nature of our business, we transfer Personal Data within the Athom group, and to third parties as noted in Section (F) above, in connection with the purposes set out in this Policy. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located, including China, the EU, the UK, and the US.

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of [Standard Contractual Clauses]. You are entitled to request a copy of our [Standard Contractual Clauses] using the contact details provided in Section (Q) below.

Please note that when you transfer any Personal Data directly to any Athom entity established outside the UK or the EEA (as applicable), we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Policy.

(H) Data security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

(I) Data accuracy

We take every reasonable step to ensure that:

your Personal Data that we Process are accurate and, where necessary, kept up to date; and
any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

(J) Data minimisation

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

(K) Data retention

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than 2 years

(L) Your legal rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
the right to request rectification of any inaccuracies in your Relevant Personal Data;
the right to request, on legitimate grounds:

erasure of your Relevant Personal Data; or
restriction of Processing of your Relevant Personal Data;

the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the UK Information Commissioner’s Office, or the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR; and

the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:

in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

(M) Terms of Service

All use of our Sites or services is subject to our Terms of Use. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

(N) Direct marketing

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, Apps, products, or services. If we provide Sites to you, we may send or display information to you regarding our Sites, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send or by unsubscribing online After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, products, or services you have requested.

(O) Details of Controllers

For the purposes of this Policy, the relevant Controllers are:

Athom Technology Co., Ltd.

C402 Tianhui Bldg Yousong Road

Shenzhen Guangdong

China

+86 (755) 23746321

For general enquiries, or to exercise any of the rights set out in this Policy, please contact support@athom.tech

(P) Representatives

Each of the controllers established outside the EEA and listed in Section (Q) above has appointed Support Team to be its representative the purposes of Article 27 of the GDPR, where applicable.

Each of the controllers established outside the UK and listed in Section (Q) above has appointed Support Team to be its representative the purposes of Article 27 of the UK GDPR, where applicable.

(Q) Analytics and Tailored Advertising

When you visit a Site, we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with applicable laws.

Certain Cookies may be stored on your machine by third parties when you use our Sites. We have no control over these Cookies or how the third parties use them. These Cookies allow third parties to provide us with a service, for example, analytics about the effectiveness of our marketing activities and user behaviour.

Regular Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. With respect to our web services you can stop all collection of information via a web service by not using that web service. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device or internet browser. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

You may opt-out of targeted advertising utilizing the Digital Advertising Alliance (“DAA”) AdChoices Program at optout.aboutads.info. For more information on the DAA AdChoices Program at visit www.youradchoices.com. In addition, the Network Advertising Initiative (“NAI”) has developed a tool that allows consumers to opt out of certain Tailored Advertising delivered by NAI members’ advertising networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see https://optout.networkadvertising.org/.

(R) Do Not Track

Most browsers can be set to send signals to third party websites requesting them not to track the user’s activities. At this time, we do not respond to “do not track” signals. Consequently, third parties may indeed track and collect information about your online activities over time while navigating to, from and on our online services, notwithstanding any “do not track” signals we may receive.

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