Privacy Policy

Last Updated of 25 April 25,, 2025

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GuanGu Tech and its global affiliates respect your privacy. We understand that creating a Privacy Policy that satisfies everyone’s needs can be challenging. Most people prefer a concise and easy policy. However, legal requirements mandate that we provide detailed information.

GuanGu Tech is a multinational company and the GuanGu Tech Products and Services are provided by GuanGu Tech and/or its third-party partners. As such, the Personal Data may be collected, processed or accessed by us in countries or regions where you use our products or services, or other countries or regions where we or our affiliates, service providers, or business partners are located. We always aim to ensure that your personal data will be processed to the extent necessary and only for the necessary purposes in accordance with applicable privacy legislation, in particular the General Data Protection Regulation (hereinafter the “GDPR”) and other applicable privacy laws. The GuanGu Tech entities responsible for the processing of personal data including several affiliated companies.

1. About this policy

The Privacy Policy (“Policy”) applies when you purchase and/or use the following products or services:

GuanGu Tech Websites (such as szguangu.com, GuanGu Store, jsguangu.com);

Other customer-supporting services provided by GuanGu Tech and/or its partners, including but not limited to customer support service (“GuanGu Services”).

For the purpose of this Policy, above products and services are collectively referred to as “GuanGu Tech Products and Services”. From time to time, we may develop new or offer additional services or products. Such new products and services will also be subject to this Policy, unless otherwise stated when they are launched by us.

Please note that this Policy is a legally binding agreement between you and GuanGu Tech. By using the GuanGu Products and Services, you acknowledge that you have read, understood, and agreed to the terms of this Policy. If you do not agree to the terms of this Policy, you must NOT use the GuanGu Products and Services.

To help explain things as clearly as possible, we’ve added definitions for Key Terms. And if you have any questions about this Policy, you can contact us at privacy@szguangu.com.

2. Personal Data We Collect

Personal Data refers to any type of information recorded electronically or otherwise relating to an identified or identifiable natural person, excluding information that has been anonymised. We may collect your Personal Data when you use GuanGu Tech Products and Services or interact with us. Different types of data will be collected, depending on the service you use and your interactions with us. In some cases, you can choose not to provide such data, but this may prevent us from providing you with corresponding products or services, or we might not be able to respond to or resolve any issue you raise.

For the avoidance of doubt, when providing you with GuanGu Tech Products and Services, we may also collect your personal data for statistics purpose, such as website visits, app downloads, and product sales volume, to understand how our products and services are used. The preceding statistics results do not constitute personal data.

We will collect and process your Personal Data through your purchase and/or use of the GuanGu Tech Products and Services only for the purposes described in Section 3 and this Policy. The following are some examples of Personal Data we may collect:

Personal Data that you provide to us:

Account Information. When you create a GuanGu Tech & GuanGu account (the “GuanGu Account”), we collect your personal data that we need to create your account and that enables you to use the GuanGu Tech Products and Service. This may include your email address, password, profile photo, profile name, User ID, user login token, social media links, loyalty and incentive program credits / rewards, and other information for account verification and use. If you actively confirm acceptance of GuanGu personalized recommendation, we will also collect your display name, username, gender, birthday, regions and countries, language and bio. Please note that the personal information of gender, birthday, regions and countries,and language will not be publicly disclosed, only visible to you.

Contact Information. When you purchase or request products or services from GuanGu Tech, we collect your personal data necessary for processing of your order. This may include your name, email address, order information, mobile phone number, physical address, ZIP/postal code, country, and other contact information if necessary. We may process your physical address either to deliver notices to you when required by law or to deliver physical goods which you have purchased or requested.

Payment Information. When you make a payment for our products or services, we will need to process your payment data. The exact personal data collected and used will vary depending on the payment method. This may include your name, mobile phone number, bank details, payment method type (credit or debit); if you use a debit or credit card, the card type, expiration date, and certain digits of your card number (Note: For security, we never collect or store your full card number); details of your payment history or other payment related information.

Transaction Information. When you purchase or request products or services from GuanGu Tech, we may also need to collect about your purchase record or transactions facilitated by us, including without limitation the details of your purchase history.

Job Application Information. When you apply for a job position at GuanGu Tech website, we may collect the job application information you provide (such as your CV, your first and last name, country, e-mail, and phone number).

Personal Data that that we collect when you use GuanGu Tech Products and Services:

When you use GuanGu Tech Products and Services, we will collect your device information and how you and your device interact with our products and services. Such information may include:

Usage Information. This may include your Internet or Network Activity Data, such as products and services interaction, IP addresses, or browsing information collected through Cookies (To learn more, please read our Cookie Policy);performance data and diagnostic data; and other usage data.

We may receive personal data about you from third-party sources, including:

Third-party Account Information. When you register or log in to GuanGu Tech’s online services using one of your existing Facebook, Apple, or Google accounts, we will collect your information from relevant third-party service providers to create your account. The service providers involved are Meta Platforms Ireland Limited., Apple Inc., and Google Ireland Ltd.

Google Analytics Statistics Data. We receive Google Analytics statistics data from Google Analytics. Google Analytics is a web analysis service provided by Google Ireland Ltd. (“Google”). The configuration of Google Analytics has been modified by us to the measurement only function, unless separate consent for further advertising features has been given. Google Analytics uses a specific form of cookie, which is stored on your computer and enables an analysis of your use of our website. To learn more, please read our Cookie Policy.

Airtable Form. We may collect user feedback through an Airtable form, which normally includes users’ email addresses and feedback content.

Other information we may receive from the third-party sources that provides the relevant services or supports.

3. How We Use Your Personal Data

In this Chapter, we set out:

our purpose for processing your personal data (“Purposes”);

our legal justifications (“Legal Basis”) under data protection law, for each purpose;

categories of personal data which we process for each purpose (“Categories”).

We use your personal data only on the legal basis permitted by applicable privacy laws. According to applicable local laws, we may use your personal data for the following purposes under one or some of the legal bases: your consent; necessary to perform/enter into a contract between you and us; necessary to protect the legitimate interests of you or others; necessary to fulfil legal obligations; and necessary to protect the legitimate interests of enterprises.

Where we process your personal data to fulfil a legitimate interest, then we have carried out a balancing test to consider whether our interests are overridden by your interests and rights. You can ask us for more information about this by using the contact details at the end of the Policy.

Register and maintain your GuanGu Account and enables you to use the GuanGu Products and Service

Legal Basis: The legal basis for personal data processing is necessary to perform/enter into a contract between you and us following from the General Terms of Use of the GuanGu Tech (hereinafter the “TOU”).

Categories and Purposes: In order to use and maintain the customer account – GuanGu Account, registration is required, during which we may process Account Information and other necessary data that you provide or subsequently add or modify in your GuanGu Account.

Use of the GuanGu Tech Websites

Legal Basis: The legal basis for personal data processing is necessary to perform a contract between you and us following from the TOU.

Categories and Purposes: We are committed to making the browsing experience on the GuanGu Tech websites as superior and user-friendly as possible. In this respect, we may process Account Information, Contact Information, Payment Information and Usage Information related to your visit and use to the GuanGu Tech Websites. For the use of the Cookies on GuanGu Tech Websites, please read our Cookie Policy.

Purchase of the GuanGu Products and Services

Legal Basis: The legal basis for personal data processing is necessary to perform/enter into a contract between you and us following from the TOU as well as performance of the related legal obligations.

Categories and Purposes: In order to successful process your purchase order and deliver the products or services you have requested, it is necessary for us to process your Account Information, Contact Information, Payment Information, and Transaction Information for the conclusion and performance of a contract.

Use of the GuanGu Devices, Apps and Services

Legal Basis: The legal basis for personal data processing is necessary to perform a contract between you and us following from the TOU and this Policy as well as performance of the related legal obligations.

Use of the GuanGu services

Legal Basis: The legal basis for personal data processing is necessary to perform a contract between you and us following from the Terms of Use of jsguangu.com and also the TOU.

Provision of technical and customer support services

Provide individualized or personalized user experience and content

Legal Basis: If you have given us your consent, we process the data mentioned below based on your consent otherwise our legitimate interests.

Marketing or advertising and other commercial activities

Legal Basis: If you have given us your consent, we process the data mentioned below based on your consent otherwise our legitimate interests.

Security, Fraud, and Abuse Prevention

Legal Basis: The legal basis for personal data processing are necessary to perform a contract between you and us following from the TOU, the “Terms of Use of jsguangu.com” and this Policy, performance of the related legal obligations and the Legitimate Interest of our customers and enterprises.

Categories and Purposes: In order to keep the GuanGu Tech Products and Service secure and to detect and prevent fraud, and improve our loss prevention and anti-fraud programs, we will process the Fraud and Abuse Prevention Information.

Recruitment

Legal Basis: The legal basis for personal data processing is your consent.

Categories and Purposes: To assess your application for the job offered, we will communicate with you within the recruitment process. Based on your consent will ask you about your experience during the recruitment process. In this respect, we will process the Job Application Data.

Comply with Applicable Local Laws/Regulations

4.Your Privacy Rights

We protect your rights over your personal data in accordance with GDPR and other applicable laws.

Some of these rights apply generally, while others will only apply in certain circumstances due to the applicable laws differences. Depending on the scenario, these rights may be subject to some limitations. We will be responsible for responding to your request within the relevant periods provided by law.

Below we have listed your rights regarding your personal data, including a description of the right (“Right”), and instructions on how to exercise the right (“How to exercise”). For each right, we also specify the circumstances in which it applies, which may include the required Legal Basis.

Be Informed (Art. 13/14 GDPR)

Right： Be informed of the personal data we process about you and how we process it.

How to exercise: You will be informed of the personal data we process about you and how we process it through this Policy, information provided to you when you use GuanGu Tech Products and Services, or by contacting us at privacy@szguangu.com.

Right of Access (Art. 15 GDPR)

Right：Request access to the personal data we process about you.

How to exercise: You may request access and a copy of your personal data from GuanGu Tech by contacting us at privacy@szguangu.com.

When you download your data, you will receive the information about your data that GuanGu Tech has to provide under Article 15 of the GDPR.

Right of Rectification (Art. 16 GDPR)

Right：You may request that we amend or update your personal data where it’s inaccurate or incomplete.

How to exercise：You can edit your Account data by contacting us at privacy@szguangu.com.

Right of Erasure (“Right to be Forgotten”) (Art. 17 GDPR)

Right：You may request us to erase certain of your personal data.

For example, you can ask us to erase the personal data:

which is no longer needed by us in relation to the purpose for which they were collected or otherwise processed;which we have been processing based on the legal basis of consent, provided that you withdraw your consent;

Which has been unlawfully processed by us (if any);

which you have objected to process (see Section 6 “Object” in Chapter 4 Your Privacy Rights below); or in other scenarios stipulated by law.In certain situations, GuanGu Tech is unable to delete your personal data in responding to your requests, including:

when such personal data is still necessary to be processed to achieve the purpose we collected it for;

GuanGu Tech’s interest in using the data overrides your interest in having it deleted (e.g., when we need to process the personal data to protect our services from fraud);

GuanGu Tech has a legal obligation to keep relevant personal data; or GuanGu Tech needs the personal data to establish, exercise or defend itself from a legal claim (e.g., when there’s an unresolved dispute relating to your account).

How to exercise：You can request to delete your Personal Data by contacting us at privacy@szguangu.com.

Right of Restriction (Art. 18 GDPR)

Right：You may request restrictions on processing your personal data where:

You are challenging the accuracy of the information;

The information has been unlawfully processed, but you are opposing the deletion of that information;

We no longer need your information for a specific purpose, but such information is required by the data subject for the establishment, exercise or defense of legal claims; or

You have objected to our processing and we are assessing your objection request (See Section “Right to Object” in Chapter 4 Your Privacy Rights below).

You may request us to stop processing your personal data temporarily or permanently.

How to exercise：you can exercise your right to restriction by contacting us at privacy@szguangu.com.

Right to Object (Art. 21 GDPR)

Right：You may object to our processing of your personal data in certain circumstances. This right applies when we are performing a task in the public interest, pursuing our legitimate interests or those of a third party or when you object to processing of your personal data for direct marketing purpose.

How to exercise：You may use controls on the GuanGu Tech Services to switch off or adjust some features which process your personal data. See the end of this section on how you can control tailored advertising, or contact us at privacy@szguangu.com.

Right of Portability (Art. 20 GDPR)

Right：You may request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service, when we are processing your personal data on the Legal Basis of consent or performance of contract. GuanGu Tech will try to respond to your request to the extent possible.

How to exercise：for information about how to exercise the right to portability, please See Section “Right of Access” above.

Not Be Subject to Automated Decision Making (Art. 22 GDPR)

Right：You have the right not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

How to exercise：GuanGu  does not engage in this type of automated decision-making so far when providing the GuanGu Products and Service.

Withdrawal of Consent (Art. 7 GDPR)

Right：You have the right to withdraw your consent from us on processing your personal data. You can implement your right of withdrawing your consent when GuanGu is processing your personal data on the Legal Basis of consent.

How to exercise：You can adjust the relevant control on GuanGu, or contact us at privacy@szguangu.com.

Right to Lodge a Complaint (Art. 77 GDPR)

Right：You may contact the European Data Protection Board (“EDPB”) for Privacy Protection or your local data protection authority about any questions or concerns regarding your personal data.

How to exercise：You can find the EDPB’s details here. You can also go to the website of your local data protection authority to lodge a complaint.

When you want to implement your rights mentioned above, we kindly ask you to:

Submit requests through the channels we provided above.

Provide sufficient information for us to verify the identities (to ensure those who initiate the requests are the data subjects themselves or those authorised by them).

Ensure that the requests are specific and feasible.

We will make every effort to respond within one month upon receiving a request to access personal data. This period may be extended if necessary, depending on the number of requests and their complexity. If the request period is to be extended, we will notify you of the situation and reason for delay. In the event of any time conflict between this section and local laws/regulations, the latter shall prevail.

After a request is submitted, we will review your request and decides whether to accept your request.

We may reject your request in the following circumstances:

Applicable laws do not grant relevant rights to data subjects;

The identity of the requester cannot be verified;

The request cannot be verified or is out of scope, especially when requests are sent repeatedly;

The requested information is related to the compensation that we will make or receive as a result of an ongoing dispute, and the disclosure of such information is likely to damage our interests;

Other situations stipulated by laws.

If we reject a request from a data subject, we will provide a formal explanation to you.

If none of the situations described in section above occurs, we will honor the request. To increase the likelihood that the request will be accepted, please provide information which is as detailed as possible when submitting your request, such as the request type, specific content, information about the data subject (such as the account name you use for GuanGu Tech Products and Services), and time frame in which the information was generated or processed.

Typically, we will not provide the following information:

Information about others: Requests from data subjects may involve other individuals besides the data subject. We will not provide such information, unless authorized by the relevant individuals.

Repeated requests: If the data subject initiates the same or similar requests related to one data subject for multiple times, and the required information has not changed since the last time we provided such information, we will not provide the copy of such information repeatedly in most cases. Additionally, we have no obligation to provide information that has been publicly available.

Special Information: We will not disclose any Special Information in response to requests for accessing personal data. For the purpose of this Policy, Special Information refers to any confidential information of GuanGu  (such as attorney/client communication), and information that actually constitutes legal opinion (irrespective of whether it is related to the lawsuit itself or related to information from court proceedings).

5. Sharing Your Personal Data

This Chapter sets out who receives personal data which is collected or generated through your use of the GuanGu Tech Products and Services from GuanGu .

Publicly Available Information

The following personal data will always be publicly available on the GuanGu Tech Websites, GuanGu Apps and GuanGu (collectively “GuanGu Platforms”) (except to any user you have blocked):

your profile name;

your profile photo;

content you post on the GuanGu  Platforms and any associated titles, details, descriptions and images;

who you are following on GuanGu;

who is following you on GuanGu;

your social media links on GuanGu;

You can share certain personal data to third party platforms, like social media or messaging platforms. This includes:

your profile information;

any content you post on GuanGu Tech Platforms and details about that content.

To ensure smooth user experience, GuanGu Products and Services may contain links to third-party websites, products, and services. We do not have control over third-party websites, products, and services, but you can choose whether to access these links or share personal data on third party platforms. GuanGu also has no control over the privacy or data protection policies of the third parties, as such third parties are not bound by this Policy. Before sharing or submitting personal data to third parties, please read and refer to their privacy or data protection policies.

Nevertheless, when you purchase our products through GuanGu Tech Partners’ online or offline channels, GuanGu Tech is still the data controller regarding processing some of your personal data, including without limitation the Account Information, Device Information, App information, or Usage Information for the purposes described in Section 3 (How We Use Your Personal Data).

When you require GuanGu Tech Partners to provide customer support service, we may share the personal data we collect from you to GuanGu Tech Partners for the purpose of responding to your requests. For such personal data, GuanGu Tech, as the data controller, will ensure that GuanGu Tech Partners will only process them as per GuanGu Tech’s instruction.

Service Providers or Partners. We engage service providers or partners to manage or support certain aspects of our business operations or GuanGu Tech Products and Services on our behalf. These service providers or partners may be located in the CN or other countries/regions, and they may provide services such as payment service, customer support, order fulfillment, product delivery, advertising and marketing activities, personalized services, technical services, data hosting, or customer satisfaction surveys. More information about our service providers or partners can be found here.

If the above technical service providers or partners process your data outside the European Economic Area (“EEA”) and this means that your data may be transmitted to a country/region with a lower data protection standard than the European Union, GuanGu Tech will take all reasonable steps to ensure equivalent data protection level for such personal data.

Other Conditions as Required by Applicable Law

GuanGu Tech may disclose your personal information with or without further consent when permitted or required by applicable laws or regulations.

6. Data Retention

We keep your personal data only for the period necessary to provide you with GuanGu Tech Products and Services and for achieving GuanGu Tech’s legitimate and essential business purposes, such as making data-driven business decisions about new features and offerings, complying with our legal obligations, or resolving disputes.

Below we provide some of the categories of our retention periods:

Data Retained until You Remove It. It’s your right to request that we delete certain of your personal data. See Section 4 “Erasure” in Chapter 4 Your Privacy Rights for more information.

Data that Expires after a Specific Period of Time. We have set certain retention periods so that some data expires or will be deleted after a specific period of time.

Data Retained until Your GuanGu Account is Deleted. We keep some data until your GuanGu Tech account is deleted. When your GuanGu Tech account is deleted, your data will be deleted or be anonymized.

Data Retained for Extended Time Periods for Limited Purposes. After your account is deleted, we may keep some data for a longer time period but for very limited purposes, such as fulfilling legal obligation.

7. Transfer to Other Countries

Due to the global nature of our business, GuanGu Tech shares personal data internationally with GuanGu Tech affiliated companies, subcontractors and partners when carrying out the data processing activities described in this Policy.

Whenever we transfer personal data internationally, we will make sure that the data transfer complies with applicable law. We also ensure the personal data benefits from an adequate level of data protection when transferring your information outside of the EEA, the UK, or Switzerland by relying on:

Adequacy Decisions. This applies when we transfer personal data to countries outside of the European Economic Area (“EEA”) which have adequate laws to protect personal data, as determined by the European Commission under Article 45 GDPR (or equivalent decisions under other laws). For example, we transfer the personal data described in Chapter 2 Information We Collect to vendors based in Switzerland and Republic of Korea.

Standard Contractual Clauses (“SCCs”). The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA to countries without an adequacy decision. These (and their approved equivalent for the UK and Switzerland) are called SCCs. For example, we use SCCs to transfer the personal data described in Chapter 2 Information We Collect to our data hosting provider located in the Malaysia. You can exercise your rights under the Standard Contractual Clauses by contacting us at privacy@szguangu.com.

For a copy of these adequacy decisions or standard contractual clauses, please contact us via the details provided in Chapter 11 Our Contact Information below.

8.Data Security

We’re committed to protecting our users’ personal data. We, with our best efforts, use certain physical, organizational, and technical security measures that are designed to improve the integrity and security of personal data that we collect and maintain. We use cryptographic technologies to ensure the confidentiality of data transmission and storage, and implement reliable protection mechanisms to protect data from attacks. We deploy access control mechanisms to prevent unauthorized to your personal data. In addition, we limit the number of authorised personnel and implement hierarchical permission management based on service requirements and personnel levels. Access to personal data will be logged and reviewed by authorised personnel on a regular basis. (You can find more information about our security measures at https://www.jsguangu.com/).

However, please be aware that no security measures are perfect or impenetrable and no system is ever completely secure thus we cannot and do not guarantee that your personal data will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational security measures.

If other individuals have access to your GuanGu Account, then they may access your personal data, controls and the service available in your account. For example, you may allow someone to use your account on a shared device. It’s your responsibility to only allow individuals to use your account where you’re comfortable sharing your personal data with them. Anyone else’s use of your GuanGu Account may impact your personalized settings and be included in your data records. To protect your user account and privacy, we encourage you to:

use a strong password which you only use for your GuanGu Account;

never share your password with anyone else;

limit access to your own computer and browser; andlog out each time you finish using the GuanGu Tech Products and Service in a shared or public environment.

9.Children

GuanGu Tech Products and Services are not intended for children under 16 years of age. We will not knowingly collect any personal data from children under 16 when providing GuanGu Tech Products and Services.

If you are under 16 years old, please do not provide any of your personal data to us. If we have collected personal data from a child under 16, we will delete relevant personal data in a timely manner after we realize it. If you believe we might have collected personal data from a child under 16, please contact us at privacy@szguangu.com.

10.Changes to this Policy

We change this Policy from time to time. We will not reduce your rights under this Policy without your explicit consent. If we make material changes on how we process your personal data, we will notify you by sending an email to the email address you provide or through a notice on the home page of our website. You may find the date when the Policy is last updated at the top of the page. You are responsible for ensuring we have an up-to-date active email address from you. Please also visit our website and read this Policy regularly to check any changes.

11.Our Contact Information

For any questions, requests or concerns about this Policy, please contact us by sending an email to privacy@szguangu.com, or by mailing to us at the following postal address:

Suzhou Guangu Technology Co., Ltd

Address: Building 4, No. 3233, Zixu Road, Xukou Town, Wuzhong District, Suzhou City, Jiangsu Province(215500).

12. Final provisions

This Policy forms an integral part of the General Terms of Use of GuanGu Tech.