Privacy Notice
Last Updated: 03.08.2026
This Privacy Notice is issued by Hunan Meizhu Smart Home Co., Ltd and its affiliates (together, “Meizhu”, “we”, “us”, and “our”). It is addressed to individuals outside our organization with whom we interact, including customers, visitors to our Sites, and recipients of any of our other products or services, personnel of corporate customers and vendors (together, “you”). Defined terms used in this Privacy Notice are explained in Section 15 below.
This Privacy Notice applies to all of Hunan Meizhu Smart Home Co., Ltd’s brands, including Uncle Brown, as well as any website that references or links to this Privacy Notice.
We may update this Privacy Notice to reflect changes to our information practices. All changes shall be effective from the date of publication unless otherwise provided. We encourage you to periodically review this page for the latest information on our privacy practices.
List of Contents
- 1. Collection of Personal Data
- 2. Creation of Personal Data
- 3. Categories of Personal Data We Collect and Process
- 4. Purposes of Processing
- 5. Legal Basis for Processing
- 6. Disclosure of Personal Data
- 7. Data Retention
- 8. Your Privacy Rights
- 9. Direct Marketing
- 10. Details of Controllers
- 11. Business Information and Links to Other Websites
- 12. Cookies, Analytics and Tailored Advertising
- 13. Contact Us
- 14. Supplemental Terms – Jurisdiction-Specific
- 15. Definitions
- Annex I – Details of Processing
1. Collection of Personal Data
Depending on how you use our Sites, products, or services, we may collect or obtain Personal Data about you from the following sources:
- Data you provide to us: We obtain Personal Data when you provide that data to us (e.g., when you register an account with us, when you contact us via email, telephone, or by any other means, or when you provide us with your business card).
- Account creation details: We collect or obtain Personal Data when you register or create an account to use any of our Sites.
- Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., when we provide a service to you).
- Site data: We collect or obtain Personal Data when you visit or use any of our Sites, or use any features or resources available on or through our Sites.
- Content and advertising information: If you interact with any third-party content or advertising on our Sites (including third-party plugins and cookies), we allow the relevant third-party providers to collect your Personal Data relating to your interaction with that content or advertising, and we receive some or all of this Personal Data from the relevant third-party provider relating to your interaction with that content or advertising.
- Data you make public: We may collect the Personal Data content you publish, or otherwise manifestly make public, including comments you make about us, through our Sites and other platforms, your social media, or any other publicly available platforms.
- Third-party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., single sign-on providers and other authentication services you use to connect to our services, third-party providers of integrated services, your employer, other Meizhu customers, business partners, Processors, and law enforcement authorities).
- Data automatically collected: our third-party partners and we automatically collect information you provide to us and information about how you access and use our Sites, products, or other services when you visit our services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.
For more information on which data we collect, please also refer to the table in Annex I.
2. Creation of Personal Data
We also create Personal Data records about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also link Personal Data collected from any of our Sites, products, or services, including where that data is collected from different devices.
3. Categories of Personal Data We Collect and Process
When you first register for an unclebrownusa.com account, we may collect the following categories of Personal Data about you: username and password, email addresses, and/or phone numbers.
When using our Sites, products, or services, we may also collect and/or process the following categories of Personal Data about you:
- Contact information: including your first and last name, preferred name, phone number, email address, mailing address, and communication preferences, all of which you have voluntarily provided.
- Account information: including first and last name, date of birth/age, alias, country, language preferences, and communication preferences, email address, phone number, employer and avatar, all of which you have voluntarily provided, along with account credentials or one-time passcodes, single sign-on authentication tokens, loyalty and incentive program credits/rewards, the products or services you are interested in, purchased or have otherwise used.
- Transaction information: including records of purchases and prices, consignee’s first and last name, shipping address and contact information, shipment tracking details, details of returns, and warranty details, when you place orders on our Sites.
- Payment details, such as invoice/payment records, payment amount, payment date, billing address, and payment method, are collected when you place orders on our Sites. Please note that we use third-party payment providers, including Shop Pay, Stripe, Amazon Pay, PayPal, and Google Pay, to process payments made to us. We do not receive or retain any personally identifiable financial information, such as payment card numbers; rather, all such information is provided directly by you to our third-party payment providers. The payment provider’s use of your data is governed by their privacy policy.
- Information about your mobile, device and network: including mobile name, mobile brand, mobile model, operating system, IP address, browser type, device type, device name, device serial numbers, device MAC address, wifi ssid, the list of installed application, and unique identifiers associated with your device or your network (including, for example, user ID, UUID (Universal Unique Identifier), Open UDID, station IP, session ID, device ID, Android ID, IDFA, or a persistent device identifier or advertising ID).
- Information about the way individuals use our services and interact with us: including click records, the site from which you came, the site to which you are going when you leave our services, how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, the communications you have through our services, and the content, links and ads you interact with, and the record of your interactions, including browsing, liking, downloading, adding to favorites, commenting and sharing content). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that individuals take on our services, which may record your actions down to the level of mouse movements, scrolling, clicks, and keystroke activity on our services.
- Information about your location, including general geographic location that our third-party providers or we may derive from your IP address.
- Event, contest, promotion, and survey information: including information provided when you sign up for an event, enter a contest or promotion, complete a survey, or submit a testimonial.
- Community interaction information: including any photographs, images, 3D design files, or other files you upload, as well as any posts, comments, or messages you share within the community forums on our website. This may also encompass your username, profile picture, and any public activity related to the community services, such as likes, follows, and shared content.
- Feedback and support information: including the contents of custom messages sent through the forms, email addresses, or other contact information we make available to customers, as well as photographs and videos submitted or recordings of calls with us (where permitted by law), and any comments, views, and opinions that you publicly post about us on social media platforms or our Sites.
- Sensitive personal information: When you use our Sites, products, or services, we may collect your sensitive personal information, with your explicit consent, to provide specific features.
To collect some of the Personal Data set forth above, we may need to request permission to access such Personal Data through your mobile device. You are in control of the permissions you grant us, and you may change your permission settings at any time in the settings dashboard of your device. Note that revoking permissions may affect the provision and performance of our Sites, products, and services.
4. Purposes of Processing
We may use the Personal Data we collect for the following purposes, subject to applicable law:
- Fulfill our contractual obligations to deliver Sites, products, services, and promotions you have requested, including facilitating your messages to other users or groups and for account and contract management (including sales, finance, vendor engagement, customer support, and customer preferences).
- Manage our organization and its day-to-day operations.
- Communicate with individuals, including in person, through our Sites, products and services, or via direct mail, email, text message, push notification, social media, and/or telephone and video calls, about our Sites, products and services, and other relevant matters.
- Facilitate the relationship we have with individuals and, where applicable, the companies they represent.
- Review our business performance.
- Market our Sites, products, and services to businesses and individuals, including in person, through our Sites, products, and services, and email, direct mail, phone or video call, text message, push notification, social media, or online advertising. This may include targeted advertising and retargeting.
- Administer, improve, and personalize our Sites, products, and services, including by displaying content, features, and advertising tailored to an individual’s interests, recognizing an individual and remembering their information when they return to our Services, and analyzing our customer base.
- Process payment for paid products and features on our Sites and other services.
- Conduct market research and engage with users to obtain their views on our Sites, products, and services.
- Opportunity tracking, conversion, and lead generation.
- Test, enhance, update, diagnose, or fix technology problems.
- Help maintain the safety, security, and integrity of our property, products and services, technology assets, a nd business, and our users (including communicating with users about product recalls and product safety advisory notices).
- Enforce our contractual rights, including, without limitation, and to the extent applicable, the Terms of Service, General Terms and Conditions, any addendum thereto, or other applicable terms.
- Resolve disputes, carry out our obligations, and enforce our rights, and protect our business interests and the interests and rights of third parties.
- Detect, prevent, investigate, or provide notice of breach of policies or terms, fraud, threats of harm, or unlawful or criminal activity.
- Enable functions of our Sites, products, and services, including creating profiles, using our online shop, rating products, and administering loyalty and incentive programs.
- Display certain functionalities of our Sites, products, and services in connection with third parties, such as the trusted shop banner, shipment tracking, or product videos.
- Enable you to use certain functionalities of our Sites, products, and services.
- Offer discounts to certain groups.
- Decide whether to enter into a business partnership, such as the affiliate program or the merchant program.
- Facilitate business transactions and reorganizations impacting the structure of our business.
- Comply with legal and regulatory obligations.
- Fulfill any other purpose for which you provide your data, or for which you have otherwise consented.
You can find more information about how we Process your Data in the table in Annex I.
5. Legal bases for Processing
The legal bases on which we rely for the processing of Personal Data are as follows:
- Perform our contractual services or before entering into a contract with you: If you order products or services from us or if you contact us to request our products or services, we use your Personal Data to provide you with these products or services, including for account and contract management, to facilitate user benefits and services, including customer support and process payment for our products and services or with information that may be relevant for you to decide on whether you want to order our products and services.
- Justified by our legitimate interests: The usage of your Personal Data may also be necessary for our business interests. For example, we may use some of your Personal Data to update and monitor the services, or diagnose or fix technology problems; help maintain the safety, security and integrity of our property and services, technology assets and business; enforce our terms, resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties; and prevent, investigate or provide notice of fraud or unlawful or criminal activity.
- Consent: In some cases, we may ask you to grant us separate consent to use your Data. In this case, you can revoke your consent at any time with effect for the future.
- Compliance with legal obligations: We are obligated to collect or retain certain Personal Data because of legal requirements, for example, tax or commercial laws, or we may be required by law enforcement to provide Personal Data on request.
You can find more information on the legal bases in the table in Annex I.
6. Disclosure of Personal Data
We may also share, transmit, disclose, grant access to, make available, and provide Personal Data with and to third parties, as described below.
- You and, where appropriate, your appointed representatives.
- As required by law, we may disclose Personal Data to third parties, such as legal advisors and law enforcement agencies, regulators, other authorities, and other third parties for legal reasons if we reasonably believe in good faith that such action is necessary:
- In connection with the establishment, exercise, or defense of legal claims;
- To comply with laws or to respond to lawful requests and legal process;
- To protect our rights and property and the rights, personal safety, and property of others, including to enforce our agreements and policies;
- To detect, suppress, or prevent fraud or other criminal activity;
- As otherwise required by applicable law.
- Third-party Processors: We share Personal Data with third-party contractors and service providers, subject to reasonable confidentiality terms. such as email service providers, marketing/advertising service providers, call service providers, video shopping support and showroom service providers, text message service providers, venue operators, payment services providers, shipping companies, and postal carriers, subject to the requirements noted below in this Section (6). These Processors support us in processing the types of Personal Data described above in Sections (1) – (3), and for the purposes described in Section (4). They are only authorized to process that information as necessary and as directed by us.
- Advertising networks and partners: To efficiently market our products and services to you, including to deliver advertising and personalize content on our Sites, products and services, on other websites and services, and across other devices, we may share Personal Data with advertising networks and partners. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and similar technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. For more information about how these technologies work and certain choices you may have about these technologies, please refer to Section (12) below.
- Business and marketing partners: We may also disclose Personal Data with other business and marketing partners with whom we jointly offer products or services or who are part of our partner program. We may obtain your consent where required by applicable law.
- Independent advisors: We may disclose Personal Data to our independent advisors, such as accountants, auditors, consultants, lawyers, and other outside professional advisors to Meizhu, subject to binding contractual or statutory obligations or statutory confidentiality.
- Corporate transactions: if Uncle Brown is involved in a corporate business transaction, such as a merger, acquisition, or sale of all or a portion of our company assets, we may disclose Personal Data to a third party during negotiation of, in connection with, or as an asset in such a corporate business transaction. If Uncle Brown completes such a corporate business transaction, you will be notified via email and/or a prominent notice on our website of any change in ownership, use of your Personal Data, and choices you may have regarding your Personal Data. Personal Data may also be disclosed in the event of insolvency, bankruptcy, or receivership.
- Other Disclosures: We may also disclose your Personal Data to any other third party or publicly with your prior consent or direction.
If we engage a third-party Processor to Process your Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data by our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law. Please note that third parties and business partners may process your Data according to their privacy policies and terms of service.
7. Data Retention
We have implemented processes designed to ensure that your Personal Data is only processed for the minimum period necessary for the purposes set out in this Privacy Notice. The criteria for determining the duration for which we will retain your Data are as follows:
- We will retain Personal Data in a form that permits identification only for as long as:
- (a) We maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed);
- (b) Your Data are necessary in connection with the lawful purposes set out in this Privacy Notice, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between you and us, and we have a legitimate interest in Processing those Personal Data to operate our business and fulfil our obligations under that contract; or where we have a legal obligation to retain your Data).
- The duration of:
- (a) Any applicable limitation period under applicable law (i.e., either any statutory retention periods as required by the law of the applicable region, or any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Data are relevant);
- (b) An additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that is relevant to that claim).
- In addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Data to storage of, and maintaining the security of, that data, except to the extent that that data needs to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2), and (3) above, each to the extent applicable, have concluded, we will either:
- Permanently delete or destroy the Relevant Personal Data;
- Anonymize or de-identify the Relevant Personal Data.
8. Your Privacy Rights
Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:
- The right not to provide your Data to us (however, please note that we may be unable to provide you with the full benefit of our services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details).
- The right to request access to, or copies of, your Relevant Personal Data, together with additional information, such as information regarding the nature, Processing, and disclosure of that Relevant Personal Data.
- The right to request rectification of any inaccuracies or incompleteness in your Relevant Personal Data.
- The right to request, on legitimate grounds, restriction of the Processing of your Relevant Personal Data (limiting the purposes for which we process your Data).
- The right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable.
- The right to request the deletion or removal of your Relevant Personal Data where there is no other legal basis for us to keep using it. Please note that we may not be able to immediately remove the information from the backup system due to applicable laws and regulations or technological limitations. If this is the case, we will isolate your Relevant Personal Data from any further processing until the backup can be deleted or anonymized/deidentified.
- Where we process your Relevant Personal Data based on your consent, the right to withdraw that consent at any time (noting that such withdrawal does not affect the lawfulness of any Processing performed before the date on which we receive notice of such withdrawal).
- Under the GDPR, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:
- The right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR.
- The right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.
- The right to lodge complaints regarding the Processing of your Relevant Personal Data with a competent Data Protection Authority. However, we encourage you to first contact us so that we can together solve any concerns you may have.
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Notice, or our Processing of your Personal Data, please use the contact details provided in Section (13) below. Please note that:
- In some cases, it will be necessary to provide evidence of your identity before we can give effect to these rights.
- Where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law), we will investigate your request reasonably promptly, before deciding what action to take.
9. Direct Marketing
We Process Personal Data to contact you via email, telephone, direct mail, or other communication formats to provide you with information regarding Sites, products, and services that may be of interest to you. If we provide Sites, products, or services to you, we may send or display information to you regarding our Sites, products, or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law. Please note that we may track your opening and clicking behavior.
You may unsubscribe from specific promotional email campaigns at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. After you unsubscribe, we will not send you further promotional emails in connection with the email campaigns you have unsubscribed from, but in some circumstances, we will continue to contact you to the extent necessary for providing any Sites, products, or services you have requested or in connection with any email campaigns to which you remain subscribed.
You may unsubscribe from specific promotional text campaigns at any time by replying STOP via text message to any of the promotional text communications we send about the specific campaign you would like to opt out of. After you unsubscribe, we will not send you further promotional text messages in connection with the text campaigns you have unsubscribed from, but in some circumstances, we will continue to contact you to the extent necessary for providing any Sites, products, or services you have requested or in connection with any text campaigns to which you remain subscribed.
10. Details of Controllers
For this Privacy Notice, the relevant joint Controllers are:
Controller entity: Hunan Meizhu Smart Home Co.,Ltd
Contact details: Room2311, Bldg F1F2, Lugu Yuyuan, 27 Wenxuan Road, Hi-tech Zone, Changsha City, Hunan Province, China
For general enquiries or to exercise any of the rights set out in this Privacy Notice, please contact info@unclebrownusa.com.
Concerning the Processing of Personal Data through our Site, the entities mentioned above can both access your Personal Data and decide on the means and purposes of the Processing. Notwithstanding your ability to contact Meizhu at info@unclebrownusa.com for all data protection-related matters, Hunan Meizhu Smart Home Co., Ltd. offers to take care of all matters relating to your Data. To this end, you may send any concerns, including requests to exercise your rights under Section (8) of this Privacy Notice, to Uncle Brown Innovations Technology Co., Ltd. at the contact information provided above or in Section (13).
11. Business Information and Links to Other Websites
Business information – In the course of using our Sites, products, and services, we may ask you to provide business information related to the company where you work. Business information may include information about your company’s practices, policies, processes, and supporting documentation. This business information is stored on Meizhu systems, and we use it to provide the solutions you have contracted us to provide, and by the terms and conditions outlined in agreements between Meizhu and your company.
Links to other websites – This Privacy Notice applies only to Meizhu practices, technologies, and services. Our online properties may include links to websites and online services that are operated by other companies not under the control or direction of Meizhu. If you provide or submit Personal Data to those websites or online services, the privacy policies on those websites or online services apply to your Data. We encourage you to carefully read the privacy policies of any website you visit.
12. Cookies, Analytics, and Tailored Advertising
Meizhu and its third-party partners and providers use cookies and similar technologies to automatically collect certain Personal Data when you visit or interact with our Sites and services to enhance navigation, analyze trends, administer the Sites, track users’ movements around the Sites, gather demographic information about our user base as a whole, and assist with our marketing efforts and customer service. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Sites and services.
Our Sites provide you the ability to adjust your preferences regarding our use of cookies and similar technologies by clicking the “Cookie Settings” link in the footer of our Sites. These cookie preference manager tools are website, device, and browser specific, so you will need to change your preferences on each device and browser you use when interacting with the specific Site you are visiting. You can also stop all collection of information via our web services by not using our Sites and services.
You may also be able to utilize third-party tools and features to further restrict our use of cookies and similar technologies. For example, cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. In addition, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device or internet browser. You may also exercise choice regarding the use of cookies from Google Analytics by going to https://support.google.com/analytics/answer/181881?hl=en to download the Google Analytics Opt-out Browser Add-on. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website here: https://policies.google.com/technologies/partner-sites.
You may also opt out of targeted advertising by companies that participate in the Digital Advertising Alliance (“DAA”) AdChoices Program by visiting optout.aboutads.info. For more information on the DAA AdChoices Program, please visit www.youradchoices.com. In addition, the Network Advertising Initiative (“NAI”) has developed a tool that allows consumers to opt out of certain tailored advertising delivered by NAI members’ advertising networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see https://optout.networkadvertising.org/.
13. Contact US
If you have questions or concerns with respect to our Privacy Notice or privacy practices, you may contact us at info@unclebrownusa.com.
14. Supplemental Terms – Jurisdiction-Specific
The following disclosures supplement the information contained in the main body of our Privacy Notice by providing additional information about our Personal Data processing practices relating to individual residents of certain states in the United States, including the states of California, Nevada, Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia in the United States. For a detailed description of how we collect, use, disclose, and otherwise process Personal Data, please read the main body of our Privacy Notice.
Collection and Use of Personal Data
As described in more detail in Section (3) above, we collect, and have collected in the preceding 12 months, the following categories of Personal Data:
- Identifiers, such as first and last name, preferred name, phone number, email address, user ID, and online identifiers.
- Customer records, such as contact information, address book information, and account information.
- Protected classification characteristics, such as age, gender, and health status.
- Commercial information, such as records of purchases and prices, shipping address and contact information, details of returns, and consumer histories and tendencies.
- Internet/network information, such as the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network.
- Professional / employment information, such as employer and job title.
- Sensitive personal data, such as account credentials (as further described below).
- Other Personal Data, such as your communication preferences, entertainment preferences, home configuration (for our home-related services), participation in our loyalty and incentive programs, and any other Personal Data you choose to share in custom messages sent through the forms, email addresses, or other contact information we make available to customers.
- Inferences, including consumer preferences, predispositions, and characteristics.
As described in Section (1) above, we collect this Personal Data directly from you, automatically when you interact with our Sites, products, or other services, from third parties, and public third-party platforms such as social media websites.
We collect Personal Data from and about you for a variety of purposes. For example, we use Personal Data to communicate with you; to facilitate, process, and fulfill orders you place with us or the services you request; to conduct surveys, sweepstakes, contests and other promotions; to analyze and improve the use of our Sites and Applications; to deliver marketing communications and personalized and non-personalized advertising; and to facilitate our customer services. For more information about our use of Personal Data, please refer to Section (4) above.
Sensitive Personal Data
The following Personal Data elements we collect or are otherwise processed in connection with our Sites, products, or services may be classified as “sensitive” under certain privacy laws (“Sensitive Personal Data”):
- Account credentials.
- Payment card information (collected and processed solely by our third-party payment providers; Meizhu does not have access to this data).
We only use or disclose Sensitive Personal Data where reasonably necessary and proportionate, and where permitted by law, to perform services you have requested, verifying and improving the services we provide, detecting security incidents, fraud, and other illegal actions, ensuring the physical safety of natural persons, performing services on behalf of the business, or short-term transient use. We only collect and process Sensitive Personal Data without the purpose of inferring characteristics about the relevant individual, and we do not sell Sensitive Personal Data or process or otherwise share Sensitive Personal Data for targeted advertising (as further described below).
However, depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or withdraw your consent for our processing of Sensitive Personal Data (as described in the Your Additional U.S. Privacy Choices section below).
Deidentified Information
We may at times receive or process Personal Data to create deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.
Keep Your Information Safe and Secure
We work hard to protect you and Meizhu from unauthorized access, alteration, disclosure, or destruction of information we hold, including:
- We use encryption to keep your data private while in transit.
- We offer a range of security features, like Safe Browsing, Security Checkup, and 2-Step Verification, to help you protect your account.
- We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems.
- We restrict access to personal information to Meizhu employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations.
Personal Data Disclosures, Sales, and Targeted Advertising
We may disclose the categories of Personal Data above to the following categories of third parties: Processors, ad networks and advertising partners, business and marketing partners, third-party providers with services integrating with our services, individuals you choose to share Personal Data with, and certain third parties where you have provided consent or where otherwise required or permitted by law. Please see Section (6) for more details. Please be aware that we will not transfer your Sensitive Personal Data to any third parties, including advertising platforms, data brokers, or information resellers, for purposes other than providing or improving the use case or features of our Sites, Applications, products, or services, without your consent.
Our disclosure or making available of identifiers, customer records, commercial information, internet/network information, and inferences to ad networks and advertising partners may qualify as the sale of Personal Data or the sharing or processing of Personal Data to display advertisements that are selected based on Personal Data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”) under certain privacy laws. Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt out of the sale of Personal Data or the processing of Personal Data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below). Please note we do not sell the Personal Data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes. In addition, we do not sell Sensitive Personal Data, and we do not process or otherwise share Sensitive Personal Data for targeted advertising. Automated Decision-Making and Profiling We do not conduct automated processing of Personal Data to evaluate, analyze, or predict an individual’s aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide the right to exercise control over such forms of automated decision-making and profiling. Your Additional U.S. Privacy Choices Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
- Right to Know. The right to confirm whether we are processing Personal Data about you and, under California and Oregon law only, to obtain certain personalized details about the Personal Data we have collected about you, including:
- The categories of Personal Data collected;
- The categories of sources of the Personal Data;
- The purposes for which the Personal Data were collected;
- The categories of Personal Data disclosed to third parties (if any), and the categories of recipients to whom this Personal Data were disclosed (or, for Oregon residents only, a list of the specific third parties to whom personal data have been disclosed);
- The categories of Personal Data shared for targeted advertising purposes (if any), and the categories of recipients to whom the Personal Data were disclosed for these purposes;
- The categories of Personal Data sold (if any) and the categories of third parties to whom the Personal Data were sold.
- Right to Access & Portability. The right to obtain access to the Personal Data we have collected about you and, where required by law, the right to obtain a copy of the Personal Data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
- Right to Correction. The right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data.
- Right to Control Over Sensitive Personal Data. The right to exercise control over our collection and processing of certain Sensitive Personal Data.
- Right to Opt-Out of Targeted Advertising. The right to direct us not to use or share Personal Data for certain targeted advertising purposes.
- Right to Opt-Out of Sales. The right to direct us not to sell Personal Data to third parties.
- Right to Deletion. The right to have us delete Personal Data we maintain about you (subject to certain exceptions).
Depending on your state of residency, you may also have the right not to receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate, or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
Submitting Privacy Rights Requests
Please submit a request specifying the right you wish to exercise by sending us an email at the following address: info@unclebrownusa.com.
To exercise your right to opt out as it relates to the use of cookies and similar technologies that involve the sale of Personal Data or the use of Personal Data for targeted advertising purposes, please click the “Cookie Settings” link in the footer of the website and adjust your preferences accordingly. If you are visiting our Sites with the Global Privacy Control enabled, any cookies that constitute sales or are used for targeted advertising should already be turned off automatically in our cookie preference manager. Please note this opt-out tool is website, device, and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, you can also opt out of cookie-based sales by businesses that participate in the Digital Advertising Alliance’s CCPA Opt-Out Tool by visiting https://www.privacyrights.info/. Lastly, you may follow the other steps outlined in Section (13) above to further exercise control over cookies and similar technologies.
Before processing your request to exercise certain rights (including the Right to Know, Access & Portability, Correction, and Deletion), we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, we will generally either require the successful authentication of your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests submitted through our email address to include the requester’s name and email address, their relationship with Meizhu, the brands relevant to the request, and the data subject’s email address, state/ country/ zip, and any comments relating to the request.
In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.
Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above, where we can verify the authorized agent’s authority to act on your behalf. To verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request.
Financial Incentives and Loyalty Programs
We offer various financial incentives to our customers, including:
- Discounts, coupons, and special offers via email when signing up for our email lists or creating an account;
- Rewards when referring a friend who purchases our products or services;
- Loyalty programs, where customers earn/redeem rewards based on their past transactions with us.
To obtain access to certain of these programs and other offerings, we may ask to collect your Personal Data, including name, contact information, professional information, account information, and transaction information. We consider the value of these programs and other offerings to be reasonably related to the value of the Personal Data to our business, based on our reasonable but sole determination. We estimate the value of the Personal Data by considering the expense incurred by the business related to the collection, storage, and retention of the Personal Data in the context of the financial incentive program and the expenses related to the provision of the financial incentive. The terms applicable to each program and other offering are provided at the time an eligible customer is offered an opportunity to participate. Interested customers can opt in to these programs and offerings by following the instructions presented at the time the offer is made. Participating customers may withdraw from our programs and other offerings at any time by unsubscribing from our emails (for email-based incentives), closing their accounts (for loyalty and reward program incentives), following the instructions provided in connection with each offering, or by emailing us at info@unclebrownusa.com.
15. Definitions
- “California Resident” means (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the state for a temporary or transitory purpose.
- “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Privacy Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
- “Controller” means the entity that decides how and why Personal Data is processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
- “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
- “GDPR” means the General Data Protection Regulation (EU) 2016/679.
- “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
- “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- ““Relevant Personal Data” means Personal Data in respect of which we are the Controller.
- Processor” means any person or entity that processes Personal Data on behalf of the Controller (other than employees of the Controller).
- “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
- “Sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Data by the business to another business or a third party for monetary or other valuable consideration. Depending on applicable law, a business does not sell Personal Data when, for example:
- A consumer uses or directs the business to intentionally disclose Personal Data or uses the business to intentionally interact with a third party, subject to certain limitations;
- The business uses or shares an identifier for a consumer who has opted out of the sale of the consumer’s Personal Data to alert third parties that the consumer has opted out of the sale of the consumer’s Personal Data;
- The business uses or shares with a Processor Personal Data of a consumer that is necessary to perform a business purpose. subject to certain limitations;
- The business transfers to a third party the Personal Data of a consumer as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business, subject to certain limitations.
- “Site” means any website operated, or maintained, by us or on our behalf.
Annex I – Details of Processing
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To provide account login services | The Processing is necessary for entering into or performing a contract with you |
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The Processing is necessary for entering into or performing a contract with you. |
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The Processing is based on your consent. |
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The Processing is necessary for entering or performing a contract with you. |
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Our legitimate interests, namely, communicating with current or prospective customers and others about our products and services. |
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Analyzing trends, usage, and activities to address errors and optimize performance for a better user experience. |
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Our legitimate interest in advertising our products through a refer-a-friend program. |
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Improving the sales of our products to these groups | Our legitimate interest is in advertising our products through special discount codes. |
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The Processing is necessary for our legitimate interest in compliance with regulatory obligations, and exercising, enforcing, and defending claims. |