ELEGOO Privacy Policy

Last Updated: July 9, 2024

ELEGOO Inc. and its affiliated companies (“ELEGOO”, “we,” “our” or “us”), are committed to protecting and preserving your privacy.

This Privacy Policy explains how we collect, use, and disclose your information through our platforms, mobile applications, customer support and other services (collectively referred to as “Services”), and applies to all Services except for those that are specifically covered by a separate Privacy Policy. The separate Privacy Policy will supersede this Privacy Policy and anything that is not specifically covered in that Privacy Policy shall be subject to the terms of this Privacy Policy.

By using our Services, you agree to the terms of this Privacy Policy, and you consent to the use of the information that you provide to us as set forth in this Privacy Policy. We do update this Privacy Policy from time to time so please review this Privacy Policy regularly. If we materially alter our Privacy Policy, we will let you know of such changes by posting a notice on our platforms. Your continued use of the platforms will be considered your agreement that your information may be used per the new policy. If you do not agree with the changes, then you should stop using the platforms, and you should let us know that you do not want your information used per the changes.

This Policy describes:

 

1. Information We Collect

In operating our platforms (including but not limited to our websites, application etc.), we may collect a variety of information, including:

• Account Information. Your ELEGOO account and related account details, including your country of residency, contact telephone number, email address, username, passwords, social media account and third-party avatar.

• Device Information. Details of your visits to our platforms or use of our mobile applications and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data, including your IP address, the date and time you accessed or left the platforms and which pages you viewed, Wi-Fi List Information, Mac address, CPU information, memory information, SD card information and operating system version. Some parts of our platforms use cookies and other technologies to collect this information about your general internet usage. See section below “How We Use Cookies” to learn more. We may also collect data in relation to your IoT devices, including device serial number, location of the device, device log, usage history and device status.

• Contact Information. We may need your contact information such as your name, email address, shipping address and telephone number when you place an order or contact us for customer service.

• Photo and Video. We may need to upload your personal photos and videos when dealing with certain issues and modifying personal information.

• Location. We may need your location information for installing, activating and managing your ELEGOO devices, Bluetooth connection, time zone setting, and obtain your latitude, longitude and altitude information for data analysis to provide better marketing promotion services.

• Other Information You Provide to Us. Details such as the time, topic and content of your communications with ELEGOO.

You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests you may have.

2. How We Collect Your Information

Here are the ways that we collect your information:

1. Directly Collected from You
   We may collect the following personal information that you provide to us directly, including your name, birthday, contact telephone number, email address, shipping address, passwords, social media account, location of your devices, your location information, your photos and videos.

2. Automatically Collected
   We may collect your devices’ information automatically within the necessary scope, including location information of the device, Wi-Fi List Information, Mac address, CPU information, memory information, SD card information and operating system version. See section below, “How We Use Cookies” for more information.

3. From the Third-Party Sources
   We collect and use information obtained from Facebook, Google, and other social media accounts you use to login to the Services (“Third-Party Accounts”), such as your name, your username, avatar, social media account and other details you may have on your Third-Party Account profile. We do not have access to your Third-Party Account passwords.

4. Devices Permission
   When you enable any permission(s) for access to your device, you authorize us to collect and use relevant personal information in order to provide you with corresponding Services. You can get your device permission list by contacting us as set forth in “Contact Us” below.
   You can also choose to change the scope of consent or withdraw your authorization at any time. After the authorization is withdrawn, we will no longer collect personal information related to these permissions, however, we will not be able to continue to provide you with corresponding Services.
   Please note that your decision to withdraw consent or authorization will not affect our previous collection and use of personal information based on your authorization. When we want to use the information collected prior to your withdrawal of your consent or authorization for purposes not specified in this Privacy Policy, we will ask for your prior consent, as required by applicable law(s).

By giving a telephone number to ELEGOO, you agree that a representative of ELEGOO can contact you at the number you provide, potentially using automated technology (including texts/SMS messaging) or a pre-recorded message. Your consent is not an obligation to receive any of our products and/or services.

3. How We Use Your Information

ELEGOO uses personal data to power our Services, process your transactions, communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent or as otherwise permitted or required by law.

ELEGOO may use your personal data for the following reasons:

• Performance of a contract: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ requests in anticipation of entering into a contract with them. For example, we handle personal data on this basis to allow you to use our Services.

• Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.

• Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. These legitimate interests include, but not limited to, operating our business and services; providing security for our platforms, products, software, or applications; marketing; receiving payments; preventing fraud; and knowing the customer to whom we are providing services.

• Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations (such as our obligation to share data with tax authorities), as required or permitted by law.

ELEGOO may use your personal data for the following purposes:

1. Provide Our Services
   We use your information to fulfil our agreements with you and provide you with our Services. We process your personal data as necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, including but not limited to:

• Account registration and management;

• Processing orders and payments, as well as enabling shipping and delivery services for goods;

• Sending emails, text messages, push notifications and in-app messages to market or advertise ELEGOO products, services, promotions, sweepstakes and events;

• Answering requests for customer or technical support;

• Communicating with you about your account, activities on our Services, and policy changes.

2. Administrative Purposes

We use your information for various administrative purposes, including but not limited to:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

• Measuring interest and engagement in our Services;

• Improving, upgrading or enhancing our Services;

• Developing new products and Services;

• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your rights under this policy;

• Debugging to identify and repair errors with our Services;

• Auditing relating to interactions, transactions and other compliance activities;

• Sharing information with third parties as needed to provide the Services;

• Enforcing our agreements and policies;

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Services and users is among the assets transferred.

• Complying with our legal obligations.

Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

1. Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent, as required by law.

2. Automated Decision-Making. We may engage in automated decision-making, including profiling. ELEGOO’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision-making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.

3. De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

4. Legal Obligations. We may process your personal information to comply with our legal obligation in certain circumstances including but not limited to:

• To law enforcement authorities, government or public agencies or officials, regulators, and/or any other person or entity with appropriate legal authority or justification for receipt of such information, if required or permitted to do so by law or legal process;

• When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity;

• When the information is required for the prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties, or for the enforcement of civil law claims.

4. How We Store Your Information

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as permitted or required by law.

5. Marketing Emails and Alerts

You may opt out of receiving marketing communications from ELEGOO at any time by clicking the “unsubscribe” link at the bottom of an email or following other specific instructions in the marketing communication. Once you opt out, you will no longer be notified of ELEGOO products, services, promotions and events until you subscribe again. You may still see ELEGOO ads on other platforms, but such ads are not displayed on the basis of your personal information collected by ELEGOO.

6. How We Disclose, Share and Transfer Your Information

1. Sharing of Your Information

We may share your personal data in the following cases:

1. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

2. Fulfilling legal obligations: We may share your personal information externally in accordance with laws and regulations or the mandatory requirements of government authorities.

3. Disclosures to Protect Us or Others: We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; protect your, our, or other individuals rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

4. Disclosure in the Event of Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. Sharing with our affiliates: Where permitted by law, we may share your information with our affiliates in order to provide you with ELEGOO Services. We will only share necessary personal information and subject to the purposes stated in this Privacy Policy. If the affiliated company wants to change the purpose of processing personal information, it will ask for your authorization again, as required by applicable law.

6. Sharing with authorized partners: Some of our Services will be provided by authorized partners only for the purposes stated in this policy. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and only share personal information necessary to provide services. Our partners are not authorized to use the shared personal information for any other purpose. Usually, our partners are:

   • Third-party service providers: Provide us with payment facilitation, package shipping, application development, electronic message processing and other services. Some of your personal information may be collected directly by third-party service providers and is subject to their privacy policies.

   • Advertising providers: We partner with third-party advertisers to assist us in business marketing, which includes using cookies and other technologies to deliver personalized advertising on third-party platforms.

   • Installers (including the dealer and the installer acting on behalf of dealer): The information collected is shared between us and partner installers so that the installers can provide services to users through ELEGOO’s platform. Some of your personal information may be collected directly by installers and is subject to their privacy policies.

   • Google API services: With your authorization, We use Google APIs to access device information, including the device name, device ID, and status data (e.g., temperature, humidity, and mode). This data is displayed in the app to provide users with real-time insights. Additionally, our app allows users to control these devices through Google APIs, enabling features like adjusting temperature, humidity, and mode directly from the app interface.

   • We use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. Transfer of Your Information

We may transfer your personal information to another company, organization or individual where we obtain your express consent, as required by law, or as otherwise permitted or required by law, or when a merger, acquisition or bankruptcy liquidation is involved, and if the transfer of personal information is involved, we will require a new holder of your companies and organizations with personal information continue to be bound by this Privacy Policy, otherwise we will require the company and organization to seek your authorization and consent again, as required by applicable law.

• International Data Transfers. We may transfer to, process, and store the data we collect about you in countries other than the country in which the data was originally collected, including the United States, European Union, China or other destinations. Those countries may not have the same data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in the Privacy Policy and comply with applicable legal requirements providing adequate protection for the international data transfer, including the Standard Contractual Clauses (“SCC”) approved by the European Union Commission.
  For users residing in Japan, you may use the Personal Information Protection Commission’s (“PPC”) report on foreign countries for more information on the relevant data protection law of the United States, EU and China.

7. Your Rights Related to Your Personal Data

If you are a resident of certain states and/or jurisdictions, you may have certain rights under applicable data privacy regulations including the rights to:

• Request access to your personal data
  You may have the right to obtain a copy of the personal data we hold about you and certain information relating to our processing of your personal data.

• Request correction of your personal data
  You may have the right to have your personal data corrected if it is inaccurate or incomplete. You can update your personal data at any time by logging into your account and updating your details directly, or by emailing us at info@elegoo.com.

• Request to delete your personal data
  You may request that ELEGOO delete your personal data. Note, however, that we may not always be able to comply with your deletion request for specific legal reasons of which you will be notified of, if applicable, at the time of your request.

• Request restriction on certain processing of your personal data
  You may request to restrict the processing of your personal data in certain scenarios.. Where the processing is restricted, we are allowed to retain sufficient information about you to ensure that the restriction is respected in the future.

• Request the transfer of your personal data
  You may request a digital copy of your personal data or request the transfer of your personal data to another company. Please note though that this right only applies to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you.

• Object to processing of your personal data for targeted advertising
  You may opt-out of our processing of your personal data for purposes of targeted advertising.

• Withdraw your consent
  You may withdraw your prior consent for the use of your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the services. Please note any use or disclosure of your personal data prior to your revocation of consent will not be subject to such withdrawal.

• Request human intervention for automated decision-making and profiling/opt-out of use of your data for automated decision-making and profiling
  You may request human intervention where we are carrying out automated decision-making or profiling when processing your personal data. This form of processing is permitted where it is necessary as part of our contract with you, provided that appropriate safeguards are in place, or your consent has been obtained, as required by law. You may also opt-out of such automated decision-making and profiling by notifying us at the email address below under “Contact Us.”
  We will try to respond to all legitimate, validated requests within one month or as otherwise required by law. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We may need to request specific information from you to help us confirm your identity in accordance with applicable law. This is a security measure to protect against personal data being disclosed to an unauthorized person.

• Right to lodge a complaint
  If you have any concerns or complaints regarding the way in which we process your data, please email us directly at info@elegoo.com. You also have the right to make a complaint to the data protection regulator in the United States (in accordance with the laws that apply to you as a resident of a particular state) or European Union data protection authorities or any other competent authority. Please do contact us first if possible so that we can assist you in the most efficient manner.

If you wish to exercise any of these rights, please email us at info@elegoo.com.

8. How We Use Cookies

Cookies are small text files that are sent to or accessed from your web browser or your device’s hard drive. Cookies typically contain the name of the domain (internet location) from which the cookies originated, the “lifetime” of the cookies (i.e., when it expires) and a randomly generated unique number or similar identifier. Cookies also may contain information about your device, such as user settings, browsing history, and activities conducted while using the Services.

Our Services use the following cookies:

• Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to use your Account. These cookies cannot be turned off.

• Analytical/performance cookies, which allow ELEGOO to recognize and count the number of visitors, learn how visitors navigate the Services, and improve the Services.

• Functionality cookies, which ELEGOO uses to recognize you when you return to the Services.

Additionally, our platforms also works with third-party products or services (“Service Providers”) to offer and present our Services to you. These Service Providers may include Google, Facebook, etc. and other Service Providers who help us track and analyze our platforms user activity, measure the effectiveness of our advertising and fundraising efforts, and support the optimization of our digital campaigns.

Our Service Providers may get more information about your activity on our platforms, including pages you visit, access times, visit duration, how you arrived at our platforms and your IP address. An IP address is a number that identifies a device connected to the internet. For most devices, the IP address changes on at least a weekly basis. Our Service Providers may also get device identifiers and specific information about the browser you use. In some cases, this information may be unique to you.

Additionally, our platforms uses pixels which are HTML code snippets that are loaded when a user visits a platforms or opens an email. It is useful for tracking user behavior and activity. With a tracking pixel, advertisers can get data for online marketing, web analysis or email marketing. If such data is analyzed in a particular way, the data collected through these pixels can be used for other purposes as well, for example retargeting/behavioral advertising.

For example, ELEGOO deploys the Facebook Pixel on our platforms. The Facebook Pixel may enable Facebook to match platforms visitors with their Facebook User Accounts. You can find out more about how Facebook collects and uses data by clicking here.

If you’d like to disable these tracking pixels, there are a number of ways in which you can prevent your data from being collected by tracking pixels:

• Set browser and email settings to be as restrictive as possible such that external graphics are only supported after permission, and HTML emails are not supported. Appropriate firewall settings can also do this.

• Some browser extensions can be used to make tracking pixels visible (e.g. PixelBlock, uBlock Origin, HTTPS Everywhere, etc.).

• For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational webpage here https://thenai.org/about-online-advertising/how-does-it-work/.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Most internet browsers accept cookies by default, but you can change your browser preferences to block or restrict cookies if you do not want your web browsing activity tracked. Please note that some cookies are necessary for our platforms to run and, as such, cannot be declined. However, such cookies do not collect any personal information. If you choose, you may use the Digital Advertising Alliance (DAA) WebChoices Tool to globally opt out of third-party tracking via platforms cookies.

There are also a variety of other tools publicly available to manage cookies and similar technologies that collect information related to your use of our platforms. To learn more about cookies and modifying your browser settings related to these cookies you can review guidance from the FTC.

We are not responsible for the effectiveness or compliance of third-party opt-out mechanisms or programs. Please note that if you remove your cookies or upgrade your browser after having opted out, you will need to opt out again. Your opt out is specific to the browser you are using and the device you use to access the platforms. Therefore, if you use multiple browsers or devices you will need to opt out on each browser or device. You can access the information on our platforms without enabling cookies in your browser, but disabling cookies may result in a diminished ability to take advantage of the services and related informational content on our platforms.

9. Security of Your Information

To secure your information, we have put in place commercially suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect through our Services. Nonetheless, the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically via our Services, and transmission of such data is therefore entirely at your own risk.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services.

10. Children’s Information, Users Only of Age of Majority

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

ELEGOO’s Services are not designed for children and we do not knowingly collect any personal information from children under the age of 16 in the European Union, or under age 14 in the United States (or other age as required by local law). If you think that your child provided this kind of information on our platforms, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

By using our Site, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user’s misrepresentation of age.

Parents or legal guardians of children under 18 cannot agree to these terms on their behalf.

If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

11. California Residents

The California Consumer Privacy Act of 2018 (“CCPA”) was amended by the California Privacy Rights Act of 2020 (“CPRA”) (collectively “the CCPA”) which took effect on January 1, 2023. As required by laws, covered businesses are required to comply with all express statutory requirements including those CCPA regulations currently in effect. Please note that any terms defined in the CCPA shall have the same meaning in this Section.

This section of our Privacy Policy only applies to our processing of personal information that is subject to the CCPA. The CCPA provides California residents with the right to know what categories of personal information ELEGOO collects and whether ELEGOO disclosed that personal information for a business purpose (e.g., to a service provider). See below for additional details:

Category of Personal Information Collected by ELEGOO	Category of Third-Party Information is Disclosed to for a Business Purpose
Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	Service providers Advertising networks Social networks
Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet platforms, application, or advertisement.	Service providers Advertising networks Government entities
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number or other financial information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.	Service providers Advertising networks Government entities
Geolocation data Physical location or movements.	Service providers Advertising networks Government entities

If you are a resident of California, you have the following rights under the CCPA:

• to know what categories of personal information we have collected and used, including how the personal information was collected;

• to know what categories of personal information are being sold or disclosed and if it is being sold or disclosed to third parties and a list of categories of information that are sold; or, if applicable: to know that your personal information has not been sold;

• to opt out of the sale of your personal information;

• to access your personal information, including the right to download or transfer personal information collected;

• to ask that your personal information be corrected.

• to ask that we limit our use of your sensitive personal information.

• to ask that your personal information be deleted;

• to ask that we not use your personal information for cross-context behavioral advertising; and

• to equal service and equal price for goods or services even if you exercise your rights under the CCPA.

We will not discriminate against you for exercising any of your CCPA rights. Unless allowed by the CCPA, we will not

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

If you are a California resident and you want to exercise any of your rights as set forth above, please contact us at info@elegoo.com.

For all requests, it is helpful to put the statement “California Privacy Rights” in the body of your request, describe the nature of your request, and supply your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response.

If you are a California resident, you may request to opt-out of the sale of, or sharing of for cross-context behavioral advertising.

Additionally, if you reside in California and have provided personal information to us, you may request information about our disclosure of certain categories of personal information to third parties for their direct marketing purposes under California’s Shine the Light law. Such requests must be submitted to us at info@elegoo.com.

12. Privacy Policies of Third-Party Websites/Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

13. European Union Residents

As applicable, for personal information of individuals that ELEGOO receives from the European Union, ELEGOO will handle such personal information in accordance with the European Union data protection laws. For personal information transferred from the European Union, ELEGOO utilizes the European Commission’s standard contractual clauses commonly known as “model clauses.” These model clauses are contract templates developed by the European Commission as a mechanism for contracting parties to legalize the cross-border transfer of personal data from Europe.

Please note that the model clauses will apply to the extent there is not another legal basis in place to validate the transfer of personal data from the European Union to the U.S.

Similarly, ELEGOO will comply with the United Kingdom’s Data Protection Act, as applicable.

14. Changes to Our Privacy Policy

We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

If at any time you find either this Agreement or the Privacy Policy unacceptable, you must immediately cease accessing the App and Websites. Unless ELEGOO obtains your express consent, any revised Privacy Policy will apply only to information collected by ELEGOO after the revised Privacy Policy takes effect, and not to information collected under any earlier versions of the Privacy Policy.

15. Accessibility Statement

We are committed to making sure that our platforms is accessible to everyone. To access this Privacy Policy in an alternative form, please email us at info@elegoo.com.

16. Contact Us

We welcome feedback and are happy to answer any questions you may have about your data. You may contact us electronically at: info@elegoo.com.