CLAF Guangzhou Science and Technology Co., LTD and its affiliates (“CLAF”, “CLAF Power”,“we”, “us”, “our”) deeply knows the importance of your privacy. This Privacy Policy is designed to respect and protect your privacy. It sets out how we collect, use, save, disclose and protect your information you give us when you use our products and service located at our website www.clafpower.com. 

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions. 

This Policy describes:

1. Definition and Application

2. What Personal Information We Collect

3. How We Collect and Use Your Personal Information

4. How We Use Cookies Technology

5. How We Store and Protect Your Personal Information

6. How We Share and Disclose Your Personal Information

7. How You Access and Manage Your Personal Information

8. About Children’s Personal Information

9. Updates to This Policy

10. How to Contact Us

Part 1  Definition and Applications

1. CLAF Power: CLAF Guangzhou Science and technology Co., LTD and its affiliates.

2. Personal Information: any information that, either on its own or jointly with other information, can be used to identify a natural person. 

3. This Privacy Policy is applied to products and service provided by CLAF, can’t be applied to products and service provided by any other third party.

Part 2  What Personal Information We Collect

When you create an account or use our products and service, you may need to provide personal information. In some cases you may be able to opt not to disclose your personal data to CLAF Power. However, not providing CLAF with certain data may mean that we cannot provide you with certain products or services or respond to an issue that you have raised. We will only collect the information that is necessary for its specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

We may collect the following types of information (which may or may not be personal information):

1. The information you provided when creating an account on our website or using our products and services: Name, mobile phone number, email address, fax number, account ID and password, ID card, address etc. 

2. Information related to completing purchases and shipments: bank account, bank holder name, order invoice, delivery address, signature of receipt proof.

3. Social information: information related to your social activities. For example, current employer, current job title, education background, professional training background etc.

4. Log information, means the technology information may be collected automatically via cookies and web signal by system. The technology information includes IP address, specific device identification, browser features, device features, operating system, language preference, quoted URL, information related to your operate and activity time and/or date. 

5. Information from a third-party may be collected indirectly. We may also collect your information from public and commerce under the conditions permitted by the applicable laws.  

Normally we will explain to you or obtain your consent before collecting above personal data. But your personal data will be collected without requiring consent under below conditions:

（1）Related to national security and national defence and security

（2）Related to public security, public health, public interest.

（3）Related to criminal investigation, lawsuit, judgement, judgement execution.

（4）With the purpose of protect the legitimate interests of the subject of the personal information or other individuals, such as life and property safety, but it is hard to obtain your consent before collecting. 

（5）The personal data is disclosed to public by the subjects of the personal information themselves.

（6）Personal data from the legitimate public disclosed information, such as legitimate news report or government public disclosed information.

（7）The necessary information for signing and fulfilling the your requested contract 

（8）The necessary information for maintaining our provided products and service to make sure the products and service are safe and stable, such as discovering and dealing with the fault of the products and service.

（9）Other circumstances as stipulated by laws and regulations

Part 3  How We Collect and Use Your Personal Information

Personal information is collected for providing services and / or products to you, and legal compliance on our part under applicable laws.

We may use your personal information for the following purposes:

1. Providing, processing, maintaining, improving and developing our goods and/or services to you, including after-sales and customer support and for services on your device or through our websites.

2. Processing the purchase orders according to your requirements, the receipt details, including name, address, phone number and postal code are for delivery purposes. The email address is used for business communication and sending message to your contacts according to your requirements.

3. Based on legitimate commerce purpose, we may contact you and provide you related products and services that you may be interested in. we may invite you to take part in commerce activities and market investigations or send you market information. 

If you no longer wish to receive certain types of email communications you may opt-out by following the prompt unsubscribe instructions. We will not transfer your personal data to our business partners for use by our business partners in direct marketing.

4. Synchronize, share and store the data you upload or download and perform the data required for uploading and downloading, maintain information related to you, use it to conduct business or fulfill legal obligations.

5. Conduct internal audits, data analysis and research, analyze and develop statistical information related to our products and services, and improve our products and services.

6. Report to relevant departments in accordance with laws, regulations or regulatory requirements.

7. Other purposes with your consent.

Part 4  How We Use Cookies Technology

CLAF Power website uses Cookies and tag as local storage technology. We treat information collected through cookies and similar technologies as non-personal information, unless local law treats an IP address or similar identifying mark as personal information.

1. Definition

A cookie is a text file stored by a web server on a computer or mobile device. The text in a cookie often consists of identifiers, site names, and some numbers and characters. The content of a cookie can be retrieved or read only by the server that creates the cookie.

2. Purposes

The purpose of our cookies is to improve the user experience. For example, in order to make the login process of the website faster, you can choose to have the username in a cookie, so that the next time you want to log in, it will be more convenient and faster. Cookies can help us determine the page and content you are connected to. In addition, such technologies may also be used for statistical analysis, management of websites, etc.

You can reject or manage cookies through your browser. However, please note that if cookies are disabled, you may not be able to enjoy the best service experience and some services may not work properly.

Part 5  How We Store and Protect Your Personal Information

CLAF pays attention to the protection of personal information. We use the industry standard practices to protect the security of your personal information and prevent it from being unauthorized accessed, disclosed, used, modified, damaged and lost. For this purpose, we mainly have taken the following measures:

1. We take all reasonably practicable steps to ensure that the collection of personal information is kept to a minimum and that irrelevant personal information with purpose is not collected; in addition, we only keep your information in the period required by this privacy policy and the time limited required by laws and regulations.

2. Institutional Norms: we have established internal systems such as the confidentiality system and the information security incident management system, and also require new recruits to sign confidentiality agreements, the outsourcing of company documents must initiate the decryption process and be approved by the leaders at all levels.

3. Technical measures: Your personal information is stored on secure servers and protected in controlled facilities. We use various security technologies and procedures to prevent information loss, improper use, unauthorized reading or disclosure. For example, in some services, we adopt encryption technology (such as SSL) to protect your information, and the technology can ensure the confidentiality of data transmission and storage; and we will use trusted protection mechanism to prevent data and data storage server to malicious attacks.

4. We only allow employees, partners, etc. who need to know this information to access your information, and ensure that employees and third-party service providers who provide products and services to you by accessing this information have strict contractual confidentiality obligations. If they don’t abide by this, they will be looked into legal liability or termination of the partnership. 

5. Other measures: Our information management department will conduct real-time monitoring of information security protection technologies, and regularly check the collection and storage of information; in addition, we will conduct training courses on security and privacy protection, proceed internal advocacy and strengthen employee’s the recognition of the importance of protecting personal information. 

6. Information Security Incident Handling: In order to cope with possible risks such as information disclosure, damage and loss, CLAF has formulated a number of systems and control measures to clarify the classification and grading standards for security incidents and security breaches and the corresponding processing flow; A dedicated emergency response team has been established to initiate safety plans for different security events in accordance with the requirements for the handling of safety incidents to carry out stop loss, analysis, and positioning, formulate remedial measures, and unite relevant departments to back tracing and striking.

If we unfortunately happen the event of a personal information security incident, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the treatment measures we have taken or will take, the precautions you can take to prevent and reduce risks, and your remedial measures etc. We will inform you about the incident with emails, SMS, push notifications, announcements, etc. At the same time, we will report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

7. In summary, we will do our best to ensure the security of the personal information that you send to us. However, please understand that due to technical limitations and various malicious methods may exist, even if we do everything we can to strengthen security measures, it is impossible to always ensure that information is 100% safe. You need to understand that the systems and communication networks that you use to access our services may have problems due to circumstances beyond our control.

Here we also provide friendly tips:

(1) Please protect your personal data and provide it to others only when it is necessary.

(2) It is recommended that you use complex passwords when using internet tools such as e-mail, social software, etc., and pay attention to protecting your information.

(3) Prevent unauthorized use of your password or use your computer or mobile device to ensure that when you share a computer or mobile device with others, you need to log out of the computer after using.

Part 6  How We Share and Disclose Your Personal Information

CLAF will not sell your personal information to any third-party. We only share, transfer, disclose your information in the following circumstances:

1. Share

（1）In order to provide you with better products and services, we may share your information with CLAF's affiliates or business partners from time to time. We will only share your personal information for legitimate, rightful, necessary, specific, and explicit purposes, and for the service needed. Business partners mainly include:

A. Third-party sellers. Certain products or services are directly provided to you by third parties (such as dealers, traders), and CLAF must share transaction-related information with third parties to fulfill your purchase of goods or services.

B. Suppliers of goods or technical services. CLAF may share your personal information with third parties that support our functions, including third parties that supply us or provide infrastructure technology services, logistics and distribution services, payment services, and data processing services. For example, for the purpose that complete the collection and delivery of goods, we may share shipping information with third parties such as senders, recipients, third-party payers, and recipients.

C. Other service providers. We may hire other companies or individuals to be a behalf of us to perform certain functions. For examples, processing orders, delivering parcels, sending letters, emails or text messages, providing marketing assistance, handling credit card payments, and providing customer service. They have access to customer information needed to perform their duties, but they cannot use this information for any other purpose.

We usually sign strict confidentiality agreements with companies, organizations, and individuals that share information and require them to take relevant confidentiality and security measures to handle personal information.

（2）Statutory situation: CLAF may share your personal information externally according to laws and regulations, lawsuit dispute resolution needs, or according to the legitimate requirements of the administrative and judicial authorities. 

（3）Other situations where you have obtained explicit consent: After obtaining your explicit consent, CLAF will share the information within your authorized area with the third party that you designate.

2. Transfer

Transfer refers to the process of transferring the control of personal information CLAF to another personal information controller. We will not transfer your personal information to any company, organization or individual except in the following cases:

（1）With the development of business, we may conduct mergers, acquisitions, asset transfers or similar transactions. If personal information is involved in transfer, we will require new companies and organizations that hold your information to continue to be subject to this Privacy Policy. ”, otherwise we will ask the company and the organization to ask you for authorization again.

（2）We will transfer your information to other parties with your explicit consent.

3. Disclosure

（1）According to your needs, your designated information is disclosed in the form of disclosure that you explicitly agree to.

（2）Public disclosure based on legal or rational basis: If there are laws, legal procedures, lawsuits, or requests from the public and government authorities, CLAF may disclose your information publicly, and we will keep caution to check all requests to ensure that it has a legal basis and is limited to data that the law enforcement agency has obtained for the purpose of a particular investigation and has legal rights. According to the law, the sharing, transfer of de-identified personal information, and ensuring that the data recipient cannot recover and re-identify the personal information subject, is not the act of external sharing, transfer, and public disclosure of personal information, for such data, the save and dispose will not need to notify you and obtain your consent.

4. Global transfer of data

CLAF's sales network covers the world, which means that your personal information may be transferred to other jurisdictions outside the country where you use the product or service, or may be accessed from these jurisdictions. Such jurisdictions may have different data protection laws or even no relevant laws. In such circumstances, CLAF will ensure that your personal information is fully and equally protected as required by all applicable laws and regulations.

Part 7  How to Access and Manage Your Personal Information

1. Visit, update and delete

We will take appropriate technical measures to ensure that you can access, update, and correct your registration information or other personal data provided when you use our services. When you make a request to access, update, correct, and delete the foregoing information, we may ask you to perform authentication to ensure information security, as follows:

（1）Request method and channel

Your request must be made in writing. The request is valid even if you did not specify the law on which the request is based. In general, verbal requests for visits are invalid, and if legislation in some countries recognizes the validity of verbal requests, we will follow such regulations.

Your request can be made through the official website of CLAF, service email, online customer service and other channels.

（2）Validity of request

Most laws require that personal data subjects comply with specific requirements when they make requests. The Privacy Policy requires you to pay attention to the following points when you make your request:

A. Requests in accordance with the requirements of paragraph (1) above.

B. Providing sufficient information to us to verify your identity (to ensure that the personal data subject making the request is himself or his authorized person).

C. Specific content of the request with enforceability

（3）The processing deadline of the request

CLAF will do its best to ensure that we respond your request within one month, we taking into account the complexity and quantity of the request, This period may be extended for another two months if necessary. We will inform you about the circumstances and the reason for the delay in the case of deferred information. If there is a conflict between the time period set in this paragraph and the local legal regulations, the provisions of local laws shall prevail.

（4）The rejection of request

A. When local law does not grant you relevant rights.

B. When your identity cannot be verified.

C. Your request is unverifiable, out of scope, especially repeated requests.

D. If the information involved is related to the compensation or compensation received by CLAF in the dispute, the disclosure of information is likely to damage the interests of CLAF.

E. If the retained information is for statistical and research purposes only, and the publication of statistics and research results does not disclose your personal identity.

F. Situations regulated by other laws.

If we need to reject your request based on the above, we will explain the reason in writing.

（5）In principle, we will not provide the following information:

A. Information about other people - no one has the right to contact other people's personal data unless it is an authorized person or guardian.

B. Repeated applications - if you are submitting the same or similar request for the same personal data subject, the data has not changed in the past period of time, and CLAF has provided the data, in which case we usually do not provide A copy of the data. In addition, we have no obligation to provide public information.

C. Special Documents - Any special information reserved by CLAF will not be disclosed in response to your request. In general, special information includes any confidential document (such as direct communication between a client and his lawyer) and information for obtaining or giving legal advice (whether it is the litigation itself or the information involved in the court proceedings).

2. Special announcement

（1）If you are an EU user under the "General Data Protection Regulations (GDPR)", when you request deletion, restriction processing, etc., we will respond and process in accordance with GDPR regulations.

（2）Personal sensitive information. Certain information may be considered sensitive information because of its specificity, such as race, religion, personal health, personal biometric information, and medical information. You need to be careful to avoid leaks.

Part 8  About Children’s Personal Information

We do not provide products to juvenile. Therefore, we do not need to obtain personal information of juvenile. Even if information is needed, we will only collect, use, or disclose it if it is legally allowed, the guardian explicitly consents, or if it is necessary to protect the juvenile.

If you are a juvenile, please use this website with your parent or guardian. CLAF will not or attempt to seek to receive any personal information from juvenile. If the parent or guardian has reason to believe that the juvenile has submitted personal information to CLAF without their prior consent, please contact us to ensure that such personal information is deleted. 

Part 9  Updates to This Policy

We may revise the contents of this Privacy Policy in due course and publish the revised Privacy Policy on this page. If such amendments are a substantial change to this Regulation, we will notify you in a more obvious manner. In this case, if you continue to use our website and services, you agree to accept the updated Privacy Policy. We recommend that you check this page periodically for the latest information on our privacy practices.  

If any clause or part of the Private Policy in accordance with applicable laws is declared and judged be in violation of the law, invalid or unenforceable under the applicable law, but it doesn’t affect the validity of other clause of the Private Policy, explanation after these clauses are deleted according to laws. 

Part 10  How to Contact Us

In the end, what we want is to bring the best experience for our users. If you have any comments or questions about this Privacy Policy, or if you have any questions about the collection, use or disclosure of your personal information by CLAF, please contact us at the address below and refer to the “Privacy Policy”:

CLAF Guangzhou Science and Technology CO.,LTD

Room 1101, No. 270, Kefeng Road, Lianhe Street, Huangpu District, Guangzhou, China.

Postcode：510000 

E-mail：info@clafpower.com