Privacy Policy

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 account:

•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 user preferences. If you prefer not to provide such information, the use of our services and products will not be affected.

•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 collected 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 shows, industry events and other functions. The information we may collect at these events includes, but not 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 to, IP addresses, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors.

Certain data we collect may be defined as personal data under applicable data protection law (“Personal Data”).

To enable us to provide our services and products to users, users need to provide certain categories of data (which may include Personal Data), such as user name, address, phone number, and email address. If certain data is required, we will let you know at the time of collection. In the event that users do not provide sufficient data marked as necessary, we may not be able to complete the registration process or provide certain products or services.

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 and 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 delivery services;

•assessing account security and transaction risks of members, detecting and preventing fraud and other security incidents;

•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 improve 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, including across browsers and devices, in accordance with applicable laws. Cookies or other similar technologies 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 to sending you communications for marketing purposes;

We may alsouse your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

We may disclose and transfer your Personal Data to our partners and to service providers engaged by us to assist us to provide services to you or who otherwise process Personal Data for purposes described in this Privacy Policy or notified to you when we collect your Personal Data. Examples of these partners 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 when visiting our Site. These marketing platforms may combine information they collect on our Site with data 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 by their own privacy policies, not this Privacy Policy;

•payment service providers to assist with payment for transactions. 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, including return and exchange of products;

•cloud computing service providers to provide cloud storage services;

These service providers must abide by our data privacy and security requirements and are only permitted to use your Personal Data in connection with the purposes specified above, and not for their own purposes.

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 our 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, government 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 products and services which we do not offer. We offer you access to these other parties and their websites either 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. This Privacy Policy does not apply to these third party sites or co-branded sites. The privacy policies of those other parties may differ from ours, and we have no control over the information that you submit to those third parties. You should read the relevant privacy policy for those third party sites and co-branded sites before responding to any offers, products or services advertised by those parties

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.

If you have any questions regarding this Privacy Policy or if you wish to access or correct your Personal Data as a user of XPPen .com, you may send your request to promotion@xp-pen.com.

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.

Cookies

To ensure our website works correctly, we may at times place a small piece of data known as a cookie on your computer or mobile device. A cookie is a text file stored by a web server on a computer or mobile device. The content of a cookie can be retrieved or read only by the server that creates the cookie. The text in a cookie often consists of identifiers, site names, and some numbers and characters. Cookies are unique to the browsers or mobile applications you use, and enable websites to store data such as your preferences or items in your shopping cart.

Like many other websites or Internet service providers, XPPen uses cookies to improve user experience. Session cookies are deleted after each visit, while persistent cookies remain in place across multiple visits. Cookies allow websites to remember your settings such as language, font size on your computer or mobile device, or other browser preferences. This means that a user does not need to reset preferences 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 website you are already logged in to and then return to the original website, it will not recognize you and you must log in again.

XPPen will not use cookies for any purposes not stated in this Policy. You can manage or delete cookies based on your own preferences. For details, visit AboutCookies.org. You can clear all the cookies stored on your computer, and most web browsers provide the option of blocking cookies. However, by doing so, 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 media and single sign-on.

•Social Media

Our websites include social media features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our websites. Your interactions with these Features are governed by the privacy policy of the company providing it.

•Single Sign-On

Depending on your jurisdiction, you may be able to log in to our website using sign-on services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the 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 information about your activities on this website to your profile page to share with others within your network.

By using our website, you consent to the use of cookies, social media and single sign-on as

described above.

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 parent or guardian have reasons to believe that a minor has provided XPPen with personal information without their prior consent, please contact us to ensure that the personal information is removed and the minor unsubscribes from any of the applicable XPPen services.

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.

We keep our Privacy Policy under regular review and may update this privacy policy to reflect changes to our information practices. If we make material changes to our Privacy Policy, we will 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.

Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or 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 any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal information from you or when we wish to use or disclose your personal information for new purposes.

This section of the Privacy Policy applies only if you use our Site or services covered by this Privacy Policy from a country that is a Member State of the European Union, and supplements the information in this Privacy Policy.

Legal Basis for Data Processing

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our 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 measures to ensure your Personal Data will remain protected in accordance with this Privacy Policy.

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.

If you have any requests, questions or concerns about our use of your Personal Data and this Privacy Policy, please contact us at promotion@xp-pen.com.