Shenzhen SmartDevil Digital Technology Co., Ltd. is committed to protecting and respecting your privacy. This privacy policy discloses the personal privacy practices for (Shenzhen SmartDevil Digital Technology Co., Ltd.) the website at www.smartdevil.com ( "SmartDevil") – what information we collect and process through SmartDevil. By using SmartDevil website, you are consenting to the practices described in this Privacy Policy.While we take reasonable steps to protect your personal information once it is in our possession, SmartDevil cannot ensure or warrant the security of any information you transmit to us before it reaches us, and you do so at your own risk. You are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you are online.

1. Collection, Use and Disclosure of Information

In certain circumstances, SmartDevil may collect personal information about you.

1.1 Collection of Information

1.1.1 Information That You Provide to SmartDevil

If you provide it to us, we may collect and process the following data about you:

● contact information: name; address; phone number; email address;

● purchase  information:delivery address;

● information about your purchases: the goods purchased and how many;

● information about and/or to support complaints made in connection with the SmartDevil or goods and/or services purchased via SmartDevil;

● Your account for identification verification in certain circumstances, when you apply for after-sales services.

● A copy of any correspondence with us, including any verification information we ask for, if you contact us for any reason (such as our customer service department chat service, telephone or email).

● Details of transactions and communications over the SmartDevil, including the types and specifications of the goods sold and purchased, pricing and delivery information, any dispute records, communications between you and SmartDevil.

1.1.2 Information That We Collect Automatically

With regard to each of your visits to SmartDevil we will automatically collect the following information:

● Details of SmartDevil buying and browsing activities, for these purposes we will automatically collect information from your device. In some jurisdictions, including countries in the European Economic Area and the UK, this information may be considered as personal information under applicable data protection laws. Specifically, this collected information may include IP addresses, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location), browsing patterns and details of how you have interacted with our SmartDevil and the goods and services available on it.

● In addition, we gather information of the visitors to the SmartDevil, including browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Some of this information may be collected using cookies and similar tracking technology, as explained further under the section 5. COOKIES  below. Where we are required by applicable law, we will seek your prior consent to the collection of information using cookies and similar tracking technologies. We also may derive or collect inferences about you based on your buying and browsing activity information and other information we have collected about you.

1.1.3 Information That We Receive From Third Parties

● We collect personal information of you from third parties including our related companies, our business partners (eg. Gleam), your representatives and public sources.Social media platforms if you choose to register for a SmartDevil account via a social media account. Exactly what information we receive will depend on your privacy settings with the applicable platform, but would typically include basic public profile information such as:Your social media user name, nickname.

● Your social media profile picture

● Name

● Email

● Social account：Facebook, Twitter, Instagram, Youtube

● Country

● Payment information：Credit card numbers or similar payment / transaction accounts that you intend to purchase with.

1.2 Use of Personal Information

We collect and use your personal information for the following purposes:

● provide, administer including providing log-in IDs and setting up payment / transaction accounts;

● process payments and refunds；

● improve and personalize the SmartDevil website and our products including sending and serving tailored marketing and advertising that we believe will be of interest to you based on the ways in which you use the SmartDevil, your browsing records, and order history;

● maintain and update our records, verify your identity and protect our lawful interests；

● providing customer service support, such as responding to your queries, feedback and managing claims and/or disputes；

● providing/supporting general SmartDevil services, facilitating communication between Buyers and SmartDevil, processing transactions and payments, providing delivery services;

● providing relevant membership benefits, including membership offers and coupons, exclusive member prices;

● verifying your identity and purchases in connection with product warranty or other after-sales claims;

● conducting research and analytics to ensure the security of our SmartDevil, to improve the content and layout of the SmartDevil, and to improve our product offerings and services;

Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests (see section 5. COOKIES below for more information).

We may also use the anonymous click stream data to help our advertisers deliver better-targeted advertisements. We offer a number of free newsletters to share content information about our site with interested users. There may be cases in which some of your personal information may be used by SmartDevil with your consent on an ongoing basis to target e-commerce promotions and telemarketing activities unless you opt out or we are prevented by law.  For example, when you register as a user or check out as a guest on SmartDevil's website, we may use your personal information to send you marketing and/or promotional materials from time to time.

We may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you if and where this is permitted by applicable data protection laws. We may not be able to do above things without your personal information. 

Users may elect to stop receiving marketing communications at any time by following the simple instructions at the bottom of the newsletter or communication or by contacting us as set out below.

1.3 Disclosure or Sharing of Personal Information

We may exchange personal information with third party service providers who assist us with payment, marketing, data processing, IT, archival, auditing, accounting, customer contact, legal, business consulting, banking, delivery, data analysis, document management, research, investigation, insurance, website and other services. Some of these third parties may be located in USA, EU countries and other countries. We disclose personal information with the following categories of recipients:

● SmartDevil group entities and affiliated companies and/or their designated service providers that work with us to provide processing services such as software, tools, systems and messaging services for purposes described in this Privacy Policy;

● our business partners where you have consented to receiving such information from them if required by applicable data protection lawsmarketing and advertising partners, such as Google, Facebook, and providers of analytics services relating to users’ behaviors, so that they may tailor the content you see when visiting our SmartDevil for analytics and/or advertising purposes. These partners may combine information they collect from SmartDevil with the data they collect from their platforms and data they collect from other websites or through other sources to conduct targeted advertising. The processing activities of these third party marketing platforms are governed by their own privacy policies;

● payment service providers that provide payment processing services. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy;

● logistics partners for providing delivery services for Buyers and Sellers, including return and exchange of products, and warehousing services for Sellers;

● customs agents for customs clearances purposes, where applicable to support Buyers with international sales/purchases;

● cloud computing or other hosting service providers to provide cloud storage services;

● warranty service providers to provide product warranty services where requested by a Buyer;

● customer service support providers to provide after-sale services or other customer service support;

● To our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations where we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person; or as otherwise required or permitted by applicable laws;

● To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy;

● To any other person with your consent to the disclosure.

2. Retention

We will retain your personal information in following ways：

● Retention in case of queries. We may retain your data for a reasonable period after you have enquired.

● Retention in accordance with legal and regulatory requirements. We will retain your data for as long as we have an ongoing legitimate business need to do so, to provide services or products to you, as required or permitted by applicable laws.

How long your data is kept for will also depend on how you use our website (for example if you are logged in as a member or you are visiting our website as a guest) and what the information you provide to us is used for. For example, if you are a registered member, certain data will be retained for a length of time following termination or deletion of your account, in order to comply with applicable laws or in case of disputes.

3. information Transaction

We share information globally, both internally within the SmartDevil affiliates, and externally with our partners and with those you connect and share with around the world in accordance with this policy. Your information may, for example, be transferred or transmitted to, or stored and processed in the United States or other countries outside of where you live for the purposes as described in this policy. These data transfers are necessary to provide the services set forth in the SmartDevil and to globally operate and provide our Products to you. We utilize standard contractual clauses, rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the United States and other countries.

4. Rights Regarding personal Information

Under applicable laws, you may have rights of access to personal information held by us and other rights. If you are a Visitor from the European Union, please refer to section 9. VISITORS FROM THE EUROPEAN UNION below for more information. If you are a Visitor from California, please refer to section 9 .VISITORS FROM CALIFORNIA below.

5. Cookies

5.1 What are the cookies

A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information such as a member ID that the site uses to track the pages you've visited. Generally, cookies work by assigning a unique number to the user that has no meaning outside the assigning site.

5.2 Types of cookies we collect

See the Section1. of this Privacy Policy for more information about the types of information we collect.

5.3 Why we use cookies

We use cookies, pixels, and other technologies (collectively, "cookies") to recognize you, learn more about your interests, keep your tracks and provide you with essential features and services and for additional purposes, including:

● Recognizingyou when you sign-in. This allows us to provide you with product recommendations, display personalized content, recognize you, and provide other customized features and services.

● Keeping track of your specified preferences. This allows us to honor your preferences, such as whether or not you would like to see interest-based ads.

● Keeping track of items stored in your shopping cart.

● Conducting research and diagnostics to improve SmartDevil's content, products, and services.

● Improving security.

● Delivering content, including ads, relevant to your interests on SmartDevil sites and third-party sites

● This allows us to measure and analyze the performance of our services.

5.4 Other tracking technologies

In some cases third parties may use cookies and other technologies such as web beacons and JavaScript on the SmartDevil website in connection with online services like banner advertising, website analytics and surveys. This may allow them to collect information about your use of our website (including your computer's IP address) which they may store in the United States or other countries. The use of these technologies allows them to deliver customized advertising content, measure the effectiveness of their advertising, evaluate users use of the SmartDevil website and other websites and provide other services relating to website activity and internet usage. Those third parties may also transfer the information they collect to others where required to do so by law, or where those others process the information on their behalf. The services we may use from time to time include Google Analytics, Hubspot:

This website uses Google Analytics service，an internet analytics service provided by Google, Inc. (“Google”). Google Analytics uses "cookies", which are text files saved on your computer, to help the website analyze how you use the site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. If this website anonymizes IP addresses, your IP address will be truncated by Google within a EU member state or other EEA state before being transmitted to the US. Only in exceptional situations will your full IP address be transmitted to Google servers in the United States and truncated there. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google. Please note that on this website, Google Analytics is supplemented by "gat. _ anonymize Ip ();" to ensure anonymized collection of IP addresses (IP masking) For more information on Google Analytics, visit Google’s information page.

Hubspot provides a customer relationship management tool that enables us to collect Customer Personal Data and Program information and Program History to onboard and manage customers so that we may provide the Services. Hubspot is self-certified under the US-EU Data Privacy Shield and is subject to a Data Processing Addendum with us with EU Standard Contractual Clauses so that processing may take place in the United States.  Please refer to Hubspot’s Privacy Policy for more information. HubSpot Analytics uses cookies and beacons to track how long Customers and potential Customers are on our Site, what marketing pages they visit, what marketing offers they respond to, and a visitor’s identity in order for us to improve our customer education material, set up accounts, and provide the Services.  For a description of all HubSpot cookies you can read about them on their site and check out Hubspot Cookie Policy.

Users should be aware that SmartDevil cannot control the use of cookies or the resulting information by advertisers or third parties hosting data for SmartDevil. You can find more details in the privacy policies of those third parties’ services on their own websites, including information on how to opt out of certain conduct.

5.5 How can you control cookies

You can determine if and how a cookie will be accepted by configuring the privacy setting of the browser you are using to access the SmartDevil or the “privacy setting” of your device.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You have the right to decide whether to accept or reject cookies. For instructions on how opt out of Google Analytics.

By using this website, you consent to the processing of data about you by Hubspot in the manner and for the purposes set out above. You have the right to decide whether to accept or reject cookies. For instructions on how opt out of Hubspot.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies maybe necessary to provide the you with certain features (e.g., customized delivery of information) available on the SmartDevil website. 

6. Chidren’s privacy

SmartDevil does not sell products for purchase by children. We sell children's products for purchase by adults. If you are under 18, you may use SmartDevil Services only with the involvement of a parent or guardian. We do not knowingly collect personal information from children under the age of 13 without the consent of the child's parent or guardian. If a child has provided us with personal information without parental or guardian consent, the parent or guardian should contact consult@smart-devil.com to remove the information.

7. Security Measures

SmartDevil utilizes a variety of security measures to maintain the safety of your personal information. All user contact information is contained behind a "firewall" and only accessible by a limited number of employees who have special access rights to production systems. We only store personal information in electronic form.

Credit card numbers are not stored in our systems in accordance with the highest of PCI-DSS standards. When purchasing from SmartDevil your financial details are verified and processed by Paypal or 2checkout（is now Verifone). Please refer to their privacy policy:

Your personal information of your account is protected by your password. If you choose to modify your personal information, you may do so by visiting the SmartDevil member account page. You will be required to submit a valid member ID and password for authentication before you will be able to modify your file. Because password information has been encrypted, it is completely invisible, including to our customer service team. We also recommend that you do not divulge your password to anyone.

No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we use appropriate technical and organizational measures to protect the information we hold for you, we cannot guarantee the security of any information you transmit over the internet.

8. Changes to This Privacy Policy

You should check our website frequently to see recent changes of Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.

9. Visitors From The European Union

This section applies if you are based in the European Economic Area (which for the purposes of this Privacy Policy shall include the UK in the event of the UK’s departure from the European Union) (“EEA”). The data controller of your personal information is (Shenzhen ShanMo Digital Technology Co., Ltd.) Private Limited.Personal data of European data subjects is first processed in Ireland and transferred for storage in the US and Canada in accordance with the GDPR. Personal data of non-European residents is processed and stored in the US and Canada. For contact details, please see section 11. CONTACT US below.

9.1 Legal Basis for Data Processing

We process personal information for the purposes set out in this Privacy Policy. Our legal basis to process for processing your personal information will depend on the personal information concerned and the specific context in which we collect it but will include where it is:

● necessary for the performance of contract between you and SmartDevil;

● necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement);

● necessary for our legitimate interests and not overridden by your rights; and/or where it is based on your consent.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our website and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our website and our services, undertaking marketing. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). In some instances, you may be required to provide us with personal information for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our website.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under section 11. CONTACT US below.

9.2 International Transfers of personal information

In connection with providing the services through our SmartDevil, we will transfer your personal information to countries outside of the EEA (including to the United States, Russia and China). （see section 3 INFORMATION TRANSACTION)

9.3 Your Rights

You have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided under section 11. CONTACT US below:

● The right to access, correct, update or request deletion of your personal information.

● The right to object to processing of your personal information when it is based on our legitimate interests.

● The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.

● The right to opt-out of newsletters emails we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing e-mails we send you.

● If we have collected and process your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent

● The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

● We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

● If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected.

10. VISITORS FROM CALIFORNIA

This California Consumer Privacy Act（"CCPA"） disclosure page ("Disclosure") supplements the Privacy Policy and is effective as of January 1, 2021. Please note that these disclosures do not apply to information that is not processed under the CCPA.

During the preceding 12 months, we have collected, used, and/or disclosed the categories of personal information described in Section 1 of our Privacy Policy.

We share personal information in the ways described in our Privacy Policy, including by allowing third parties that provide us analytics and advertising services to collect information through cookies and other similar technologies. We do not treat this as a sale of personal information for purposes of state law, although you do have the choices that we describe to you in this Privacy Policy.

You have the right to request that we disclose information about our collection and use of personal information and to request access to your personal information. You also have the right to request that we delete personal information in certain circumstances. We will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law.

To exercise your rights, you or your authorized agent may contact us using the contact details provided under section 11. CONTACT US below. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of the websites.

11. Contact Us

Email: consult@smart-devil.com

We aim to ensure that our privacy policy continually meets all legal requirements in order to maintain and honor your privacy.

Please contact us as set out below if you have any questions about this privacy policy, the practices of SmartDevil with respect to personal information, or if you have any queries or concerns about your dealings with the SmartDevil website or our handling of your information. If you express any concerns that we have interfered with your privacy we will promptly respond to let you know who will be handling your matter and when you can expect a response.

You can also contact us as set out below if you wish to access or correct any personal information we hold about you. We may need to verify you identity. If we deny any request to access or correct personal information, we will provide our reasons. Where we decide not to make a requested correction to your personal information, you may ask us to note your request with the information.