Table of Contents
A. COLLECTION OF INFORMATION.
B. USE OF PERSONAL DATA.
C. DISCLOSURE OF PERSONAL DATA.
D. RIGHTS REGARDING PERSONAL DATA.
G. SECURITY MEASURES.
I. VISITORS FROM THE EUROPEAN UNION
Legal Basis for Data Processing.
International Transfers of Personal Data.
J. HOW TO CONTACT US.
XPPen.com ("Site", “we”, or “us”) recognizes the importance of privacy as well as the importance
and services provided by us and sets out how we collect, use and disclose information in
through mobile applications or mobile-optimized websites.
A. COLLECTION OF INFORMATION
Your privacy is important to us and we have taken steps to ensure that we do not collect more
information from you than is necessary for us to provide you with our services and to protect your
•Information including user name, address, phone number, and email address, will be collected at the
time of user registration on the Site. If you are registering an XPPen account through social media
platforms such as facebook , we may collect your account name and profile photo at those platforms.
•If you choose to answer our supplemental questionnaires for registered members, we may also collect
marital status, nationality, gender, date and/or year of birth, annual income, monthly spending and
If you prefer not to provide such information, the use of our services and products will not be
•If you contact our customer service, we may record your conversation with us and collect additional
information to verify your identity.
•We record details of users’ activities on the Site. Information relating to such transactions
(including, but not limited to, the types and specifications of the goods, pricing and delivery
information, any dispute records and any information disclosed in any discussion forum) may be
when transactions are conducted on or facilitated through the Site.
•From time to time, we collect information about our users and prospective users during trade
industry events and other functions. The information we may collect at these events includes, but
limited to, user name, address, phone number and email address.
•We record users’ buying and browsing activities on our platform including but not limited to IP
addresses, browsing patterns, buyer behavioral patterns and equipment information. In addition, we
gather statistical information about the Site and visitors to the Site including, but not limited
addresses, browser software, operating system, software and hardware attributes, pages viewed,
sessions and unique visitors.
Certain data we collect may be defined as personal data under applicable data protection law
To enable us to provide our services and products to users, users need to provide certain categories
data (which may include Personal Data), such as user name, address, phone number, and email address.
certain data is required, we will let you know at the time of collection. In the event that users do
provide sufficient data marked as necessary, we may not be able to complete the registration process
provide certain products or services.
B. USE OF PERSONAL DATA
We collect and use your Personal Data for the following purposes:
•verifying your identity;
•verifying your eligibility to register as a user of the Site;
•processing your registration as a user, providing you with a log-in ID for the Site and maintaining
managing your registration;
•providing you with customer service and responding to your queries, feedback, claims or disputes;
•facilitating communication between us on the Site, processing your purchase orders, and providing
•assessing account security and transaction risks of members, detecting and preventing fraud and
•personalizing our communication with you based on your browsing records, equipment information we
collected and your order history, and performing research or statistical analysis in order to
the content and layout of the Site, and to improve our product offerings and services;
•identifying, developing and marketing products and services that we believe you will value,
across browsers and devices, in accordance with applicable laws. Cookies or other similar
may be used to provide you with advertising based upon your browsing activities and interests (see
section E. COOKIES below). Where we are required by applicable law, we will seek your consent prior
sending you communications for marketing purposes;
We may alsouse your Personal Data for other purposes that are not incompatible with the purposes we
disclosed to you (such as archiving purposes in the public interest, scientific or historical
purposes, or statistical purposes) if and where this is permitted by applicable data protection
C. DISCLOSURE OF PERSONAL DATA
We may disclose and transfer your Personal Data to our partners and to service providers engaged by
to assist us to provide services to you or who otherwise process Personal Data for purposes
or service providers include:
•marketing platforms, such as, but not limited to, Google, Twitter, Facebook and Instagram, and
providers of analytics services relating to users’ behavior, in order to tailor the content you see
visiting our Site. These marketing platforms may combine information they collect on our Site with
on their platforms and data they collect from other websites or through other sources in order to
conduct targeted advertising. The activities of these third party marketing platforms are governed
•payment service providers to assist with payment for transactions. The activities of payment
•logistics partners for providing delivery services for buyers, including return and exchange of
•cloud computing service providers to provide cloud storage services;
These service providers must abide by our data privacy and security requirements and are only
to use your Personal Data in connection with the purposes specified above, and not for their own
For the purposes specified above, we may share your Personal Data with affiliated companies in the
XPPen company and/or their designated service providers.
When we believe it is necessary to comply with applicable laws or to exercise, establish or defend
legal rights or protect your vital interests or those of any other person, we may also disclose and
transfer your Personal Data to our professional advisers, law enforcement agencies, insurers,
and regulatory and other organizations, or as otherwise required or permitted by applicable laws.
We may also disclose your Personal Data to any other person with your consent to the disclosure.
We may provide aggregated or anonymized data to third parties, but when we do so, the information we
share is in a de-identified format that does not personally identify you.
We have established relationships with other parties and websites to offer you the benefit of
and services which we do not offer. We offer you access to these other parties and their websites
through the use of hyperlinks to these sites from our Site or through offering "co-branded" sites in
which both we and other parties share the same uniform resource locator (URL), domain name or pages
within a domain name on the Internet. In some cases you may be required to submit Personal Data to
register or apply for products or services provided by such third parties or co-branded partners.
those other parties may differ from ours, and we have no control over the information that you
co-branded sites before responding to any offers, products or services advertised by those parties
D. RIGHTS REGARDING PERSONAL DATA
Under the applicable laws, you may have the rights of access to Personal Data held by us and other
rights. If you are a Visitor from the European Union, please refer to section I. VISITORS FROM THE
EUROPEAN UNION below for more information.
Personal Data as a user of XPPen .com, you may send your request to firstname.lastname@example.org.
If and to the extent permitted by applicable law, we may charge you a fee for the processing of any
request you make regarding your Personal Data.
E. Cookies & Similar Technologies
To ensure our website works correctly, we may at times place a small piece of data known as a cookie
your computer or mobile device. A cookie is a text file stored by a web server on a computer or
device. The content of a cookie can be retrieved or read only by the server that creates the cookie.
text in a cookie often consists of identifiers, site names, and some numbers and characters. Cookies
unique to the browsers or mobile applications you use, and enable websites to store data such as
preferences or items in your shopping cart.
Session cookies are deleted after each visit, while persistent cookies remain in place across
visits. Cookies allow websites to remember your settings such as language, font size on your
mobile device, or other browser preferences. This means that a user does not need to reset
for every visit. On the contrary, if cookies are not used, websites will treat you as a new visitor
every time you load a web page. For example, if you are redirected to another web page from a
you are already logged in to and then return to the original website, it will not recognize you and
must log in again.
based on your own preferences. For details, visit AboutCookies.org. You can clear all the cookies
on your computer, and most web browsers provide the option of blocking cookies. However, by doing
you have to change the user settings every time you visit our website.
Social Media and Single Sign-On
In addition to cookies, we may also use other similar technologies on our websites such as social
and single sign-on.
Our websites include social media features, such as the Facebook Like button and Widgets, such as
Share this button or interactive mini-programs that run on our site. These features may collect your
address, which page you are visiting on our site, and may set a cookie to enable the Feature to
properly. Social media features and Widgets are either hosted by a third party or hosted directly on
Depending on your jurisdiction, you may be able to log in to our website using sign-on services such
Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you
option to share certain personal information (such as your name and email address) with us, and to
pre-populate our sign up form. Services like Facebook Connect give you the option to post
about your activities on this website to your profile page to share with others within your network.
We consider it the responsibility of parents to monitor their children’s use of our products and
services. Nevertheless, it is our policy not to require personal information from minors or offer to
send any promotional materials to persons in that category.
XPPen does not seek or intend to seek to receive any personal information from minors. Should a
or guardian have reasons to believe that a minor has provided XPPen with personal information
their prior consent, please contact us to ensure that the personal information is removed and the
unsubscribes from any of the applicable XPPen services.
G. SECURITY MEASURES
We employ commercially reasonable security methods to prevent unauthorized access to the Site, to
maintain data accuracy and to ensure the correct use of the information we hold.
For registered users of the Site, some of your information can be viewed and edited through your
account, which is protected by a password. We recommend that you do not divulge your password to
anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an
unsolicited email. If you share a computer with others, you should not choose to save your log-in
information (e.g., user ID and password) on that shared computer. Remember to sign out of your
account and close your browser window when you have finished your session.
No data transmission over the internet or any wireless network can be guaranteed to be perfectly
secure. As a result, while we try to protect the information we hold for you, we cannot guarantee
the security of any information you transmit to us and you do so at your own risk.
notify you by email (sent to the e-mail address specified in your account) or post the changes on
all the XPPen websites , so that you may be aware of the information we collect and how we use it.
on the website. We encourage you to periodically review this page for the latest information on our
privacy practices. Your continued use of products and services on the websites, mobile phones and/or
consent before we collect more personal information from you or when we wish to use or disclose your
personal information for new purposes.
I. VISITORS FROM THE EUROPEAN UNION
Legal Basis for Data Processing
legal basis to process Personal Data will depend on the Personal Data concerned and the specific
context in which we collect it. However, we will normally collect and process Personal Data about
you only where it is: necessary for the performance of any contract between us (for example, to
provide you with the services you request and to identify and authenticate you so you may use the
Site); 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 Data in reliance on our legitimate interests (or those of any
third party), this interest will normally be to operate our Site 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
Site and our services, undertaking marketing, or for the purposes of ensuring the security of our
Site and services and detecting or preventing illegal activities such as fraud.
If we ask you to provide Personal Data 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 Data is mandatory or not (as well as of the possible consequences if you do not
provide your Personal Data). In some instances, you may be required to provide us with Personal Data
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 Site.
We retain your Personal Data as long as we have an ongoing legitimate business need to do so for
example to provide services or products to you, or as required or permitted by applicable laws, such
as tax and accounting laws. When we have no ongoing legitimate business need to process your
Personal Data, we will either delete or anonymise it or, if this is not possible (for example,
because your Personal Data has been stored in backup archives), then we will securely store your
Personal Data and isolate it from any further processing until deletion is possible.
If you have questions about or need further information concerning the legal basis on which we
collect and use your Personal Data, please contact us using the contact details provided under
section J. HOW TO CONTACT US below.
International Transfers of Personal Data
Our business may require us to transfer your Personal Data to countries outside of the European
Economic Area (“EEA”), including to countries that may not provide the same level of data protection
as your home country such as the United States and China. We take appropriate steps to ensure that
recipients of your Personal Data are bound to duties of confidentiality and we implement appropriate
If you are a resident of the European Economic Area, you have the following data protection rights,
which you can exercise at any time by contacting us using the contact details provided under section
J. HOW TO CONTACT US below:
•The right to access, correct, update or request deletion of your Personal Data.
•The right to object to processing of your personal information when it is based on our legitimate
interests, and separately the right to object to direct marketing.
•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 marketing communications we send you at any time. You can exercise this
right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To
opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact
us using the contact details provided under section J. HOW TO CONTACT US below.
•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.
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.
J. HOW TO CONTACT US
If you have any requests, questions or concerns about our use of your Personal Data and this Privacy
Policy, please contact us at email@example.com.