Privacy policy

Last Updated Date: 27 May, 2026

 

1.0 Introduction

This Website Privacy Policy ("Privacy Policy") applies to America Ugreen Limited, hereinafter referred to as “Ugreen,” “we,” “us,” and “our”. We recognize that privacy is an ongoing responsibility and will therefore update this Privacy Policy from time to time update this Privacy Notice as we adopt new personal data practices or adopt new privacy policies.

This Privacy Policy describes how Ugreen collects and uses the personal data you provide on our website located at: eu.ugreen.com (“Website”). This Privacy Policy does not govern the use of Ugreen products or services offered under contract to Ugreen customers. 

This Privacy Policy applies only to personal data processed in connection with this Website and the related services covered by this policy and does not apply to any third-party platforms, websites, services, or external links that may be accessed through this Website or the related services covered by this policy.

Our Services may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated with or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites.

This website is intended for users all over the world. Therefore, please note that our privacy practices are subject to the applicable laws of the jurisdictions in which we operate. You will see other region-specific terms that apply only to customers in those regions or that are required by applicable law.

This policy is intended to help you understand:

Ø WHAT PERSONAL DATA WE COLLECT AND HOW WE USE IT

Ø HOW WE DISCLOSE YOUR PERSONAL DATA

Ø DATA SECURITY AND RETENTION

Ø COOKIES AND SIMILAR TECHNOLOGIES

Ø YOUR RIGHTS

Ø INTERNATIONAL TRANSFERS

Ø AUTOMATED DECISION-MAKING AND PROFILING

Ø PRIVACY FOR CHILDREN

Ø UPDATE

Ø CONTACT INFORMATION

2.0 What Personal Data We Collect and How We Use It

The types of personal data we may collect about you include data you provide to us, data from third parties, and automatically collected information about your use of our Services. The table below sets out what personal data we process about you, for which purposes and on which lawful basis.

Activity / Category	Personal data processed	Lawful basis and purposes
A. Data you provide directly and voluntarily
(1) Subscribe You can choose to subscribe to our newsletters about new product launches, promotions and exhibitions	l Email address l UGREEN account (to receive/use voucher)	l Lawful basis: Your consent l Purposes: To send newsletters on new product, promotions, exhibitions and vouchers, and distribute questionnaires to collect feelings, preferences and suggestions on UGREEN products for product improvement
(2) Register Member account creation	l Username l Email address l Password	l Lawful basis: Your consent. l Purposes: To register you as a member and enable access to shopping cart, order history, registration information and point balance.
(3) Login Member sign-in	l Email address (account number) l Password	l Lawful basis: Your consent. l Purposes: To authenticate your identity as a member and grant access to member account and services.
(4) Check out Order placement	l Email address (account number) l Recipient name l Telephone number l Postal address l Payment information (via third-party provider)	l Lawful basis: Fulfillment of contract. l Purposes: To process and deliver your order to specified recipient and address, and facilitate payment via a third-party provider.
(5) Online customer service Live chat support	l Username (if provided voluntarily) l Email address (if provided voluntarily) l Chat records (only if logged in)	l Lawful basis: Your consent. l Purposes: To provide online customer service and to save chat record for tracing (only when logged in).
(6) Order tracking You can track the status of your order through the Order Tracking feature.	l Order number l Email address	l Lawful basis: Your consent. l Purposes: To allow you to track the status of your order.
B. Data collected automatically
(8) Assign sites To speed up your access to our website.	l IP address	l Lawful basis: Your consent. l Purposes: To assign you to the nearest website to speed up access.
(9) Cookies and similar technologies For more information about how we use cookies and similar technologies, and how you can manage your preferences, please refer to our Cookie Notice	l Device information l Browser behavior l Usage data	l Lawful basis: Your consent. l Purposes: To ensure the proper functioning of our Services, improve user experience and analyze service performance.
C. Data from third parties
(10) Student discount register If you are a student, you can verify your student status on Studentsbeans.	l "Yes" or "No" student verification feedback from Studentbeans	l Lawful basis: Your Consent. l Purposes: To verify your student status and grant access to student-related discounts.

 

3.0 How We Disclose Your Personal Data

We do not sell your personal data. We only share your data where permitted or required by applicable law, and solely to the extent necessary to provide and improve our Services. We work closely with certain categories of service providers — for example, in the areas of customer support, payment processing, and technical infrastructure. Where these providers process your data on our behalf, they do so only under contractual obligations and strictly within the scope required to deliver the relevant service.

3.1 Ugreen Affiliates

We share your personal data among the legal entities that make up the UGREEN corporate group for legitimate business purposes and to support the operation of our Site, products, and services, in accordance with applicable law. These entities may use your personal data in the manner described in this Privacy Policy.

3.2 Service Providers and Platform Partners

We work with a range of third-party service providers to operate our Site and deliver our Services. We may disclose personal data to third parties listed below solely to support the delivery of our Services and for the purposes described in this policy.

Third-Party Category	Third Party / Service	Purpose of Disclosure
Service Providers and Platform Partners	Shopify	As our core e-commerce platform provider, Shopify processes personal data for website hosting, checkout functionality, payment processing, and fraud analysis.
	Amazon Web Services (AWS)	We use AWS for secure cloud hosting and data storage infrastructure.
	Payment Processors	When you pay for an order, you are directed to third-party payment processors to enter your payment information. Any credit or debit card numbers you provide for payment are processed by those third-party payment processors, which are expected to comply with the Payment Card Industry Data Security Standard (PCI/DSS). We do not collect or store your full payment card details through the Website, and information collected by those providers for processing your payments is not available to us unless you otherwise provide it to us in connection with your use of the Site or our Services.
	PayPal	To securely process payments when you select PayPal as your payment method during checkout.
Analytics and Business Intelligence Partners	Google (Google Analytics)	To analyze website traffic, user engagement, and campaign performance. We have configured Google Analytics to respect user privacy choices.
	Microsoft (Clarity)	To understand user behavior through session recordings and heatmaps, helping us to identify and fix usability issues on our Site.
Advertising and Marketing Partners	Meta (Facebook Pixel)	To measure the effectiveness of our advertising campaigns on Meta's platforms (Facebook and Instagram) and to create custom audiences for retargeting purposes.
	Google (Google Ads / DoubleClick)	To manage our advertising on Google's network, including conversion tracking and serving targeted ads.
	Other Marketing Platforms	We work with various partners to manage our marketing and affiliate programs, such as Advertease, Attribuly, and Scarab Research, who assist with advertising, attribution, and product recommendations.
Customer Support and Communication Partners	Zendesk	To manage our customer support ticketing system and facilitate communications with you when you request assistance.
	QuickCEP	To provide AI-powered chat support and customer engagement services on our Site.
E-commerce Functionality and Conversion Partners	Shopify Applications	We use various Shopify applications to enhance our store's functionality, such as "Frequently Bought Together" by Code Black Belt, offer verification services from Gocertify, and lead capture pop-ups from Pop-Convert.
Security Partners	Cloudflare	We use services like Cloudflare for content delivery and security.
	hCaptcha	To protect our Site from spam and abuse by distinguishing between human users and bots.
Student Verification and Discount Partners	Studentsbeans	To verify student status and confirm eligibility for student-related discounts; we only collect "yes" or "no" feedback from the site.
Affiliates and Corporate Group	UGREEN Corporate Group Affiliates	We may share personal data with our parent company, subsidiaries, and other affiliates within the UGREEN corporate group for operational, strategic, and reporting purposes.
Legal Disclosures and Business Transfers	Legal Authorities / Relevant Transaction Parties	We may disclose your personal data if required by law or in the good-faith belief that such action is necessary to comply with a legal obligation, protect and defend our rights or property, prevent fraud, or in connection with a business transaction such as a merger, sale of assets, or bankruptcy.

 

3.3 Legal Authorities and Other Third Parties

If we are required to do so by a court order, legal obligation, or official decision, or where disclosure is necessary for the purposes of fraud prevention, enforcement of our legal rights, or a corporate transaction (such as a merger, asset sale, or bankruptcy proceeding), we may disclose your personal data to the relevant authorities, legal counterparties, or successor entities. In the case of a business transfer, we will ensure confidentiality is maintained and require any successor entity to honor this Privacy Policy or seek your re-authorization.

4.0 Data Security and Retention

4.1 How We Protect Your Personal Data

We take appropriate technical and organizational measures to ensure the security of your personal data.

We have taken appropriate security measures to protect your personal data and prevent unauthorized access, manipulation, damage or loss. We use encryption techniques to secure the transmission of your personal data. We use appropriate encryption, access control and identity verification technologies for stored personal data. We also appropriately restrict the access rights of our employees. In addition, we regularly create backup copies of personal data in order to be able to restore access to this data in the event of physical or technical incidents.

To address potential risks of leakage, damage and loss of personal data (referred to as “personal data security incidents"), we have developed a contingency plan for such incidents and conduct regular drills.

While we strive to protect your personal data, no internet transmission method or security system is perfect and we cannot guarantee that your data will be secure in all circumstances. You are often in the best position to protect yourself online. It is your responsibility to protect your login ID and password from access by third parties and to choose strong passwords.

4.2 Data Retention

We will retain personal data where we have a justifiable business need to do so and/or for as long as is needed to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (e.g. for anti-money laundering, accounting or other purposes). When we no longer have a justifiable business need to process your personal data, we will either delete it or, if this is not possible (e.g. because your personal data has been stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible.

5.0 Cookies and Similar Technologies

Our Site uses cookies and similar technologies to function, to analyze performance, to remember your preferences, and to support advertising and marketing activities. A cookie is a small text file that a website stores on your computer or mobile device when you visit the site.

Similar technologies may include web pixels or tags, local storage, and scripts or software development tags that collect or read information from your browser or device in connection with your use of the Site.

Where required by applicable law, we will place non-essential cookies and similar technologies on your device only with your consent. You may withdraw your consent or update your preferences at any time through the cookie settings tools made available on our Site.

5.1 What Cookies and Similar Technologies Are

l Cookies: Small text files stored by your browser that help recognize your device or browser and remember information about your visit or preferences.

l Web Pixels or Tags: Small transparent images or code snippets embedded on webpages or emails that can detect when content is viewed or interacted with and transmit related information to us or our service providers.

l Local Storage: Browser-based storage mechanisms that allow information to be stored locally on your device so that settings, identifiers, or other data can be retrieved later.

l Scripts and Similar Technologies: Code elements that run on a webpage to collect technical and usage information, enable analytics, support site features, measure advertising performance, or help detect abuse and security incidents.

5.2 How These Technologies Collect Personal Data

l Identifiers and Technical Data: These technologies may store or read identifiers from your browser or device, such as your IP address, browser type and version, operating system, device identifiers, browser identifiers, client IDs, cookie IDs, and similar online identifiers.

l Usage and Interaction Data: They may collect information about how you use the Site, including the pages you visit, the links you click, the products you view, your search queries, items added to your cart, the referring webpage, and the date and time of your interactions.

l Session and Behavioral Data: Some analytics and experience tools may collect session-level information, such as scrolling, navigation paths, or interaction patterns, to help us understand user behavior and address usability issues.

5.4 Purposes of Data Collection Through Cookies and Similar Technologies

l Site Operation and Service Delivery: To keep the Site working properly, enable core account and checkout functionality, maintain session continuity, and provide features requested by users.

l Preferences and Personalization: To remember your settings and choices, present relevant content, and improve convenience during future visits.

l Analytics and Improvement: To analyze performance, understand how the Site is used, diagnose technical issues, test improvements, and enhance the user experience.

l Security and Fraud Prevention: To protect the Site, detect suspicious or abusive behavior, distinguish legitimate users from automated traffic, and preserve the integrity of our services.

l Advertising and Campaign Measurement: To support marketing activities, measure campaign effectiveness, attribute conversions, and provide more relevant advertising where permitted by applicable law.

6.0 How to Exercise Your Right to Manage Personal Data

Your Rights include:

l Access and portability. You may ask us to confirm whether we are processing your personal data, provide you with details about what we have collected and how we process your personal data,and, in some limited circumstances, give you a copy of your personal data. You may ask us to provide your personal data in a structured, commonly used, machine-readable format, or you can ask to have it ported directly to another controller.

l Rectification or correction. You may ask us to correct any inaccurate or incomplete personal data that we hold about you.

l Erasure or deletion. You may ask us to delete the personal data that we hold about you.

l Objection to processing including marketing and automated decision-making. You may request that we stop processing your personal data for specific purposes including marketing and profiling.

l Restrict the processing or disclosure of personal data. You have the right to restrict the processing or disclosure of your personal data where appropriate and in accordance with applicable law(for example, where you believe that the personal data we hold about you is not accurate or lawfully held),such as , blocking, or deletion of unnecessary or excessive personal data, or personal data not processed in compliance with those laws.

l Lodge a complaint to your local Data Protection Authority. You may have the right to lodge a complaint with your national Data Protection Authority or equivalent regulatory body.

l Withdraw consent. We process most of your personal data on the basis of your consent. You have the right to give your consent ，and you also have the right to withdraw your consent.

l Account closure.

If you have registered an account, you have the same right to close your account.

This Policy does not create, extend, or modify rights , you may have all or some of the above rights, or other rights, under applicable law. These rights are not absolute and are subject to conditions or limitations as specified in applicable laws. If you would like to exercise any of the above rights, please contact us using the details in the end of this Policy. We will process your request in accordance with applicable privacy and data protection laws. To protect your privacy and security, we may take steps to verify your identity before dealing with the request.

Reasonable requests are typically processed free of charge. We reserve the right to deny requests that are unjustifiably repetitive, technically burdensome (such as by necessitating the development of new systems or fundamentally amending current practices), infringe on others' legal rights, or are impractical (such as requests involving data on backup tapes).If denied, we will notify you of the reasons for the denial and you have the right to appeal the denial , file a complaint,or seek other remedies consistent with applicable law.

7.0 International Transfers

Your personal data may be transferred to, stored, and processed in countries other than the country in which you reside, including countries outside the EEA, EU Member States or the UK, where UGREEN, our affiliates, service providers, or business partners operate.

Where we transfer personal data outside the EEA or the UK, we will take steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and applicable data protection laws.

7.1 Transfers from the EEA, EU Member States, and the United Kingdom

If we transfer personal data of individuals located in the European Economic Area (EEA), EU Member States, or the United Kingdom to a country or recipient that is not recognized as providing an adequate level of protection, we will do so only where a lawful transfer mechanism is in place under the GDPR or other applicable data protection laws.

l Standard Contractual Clauses: Where required, we rely on the European Commission's approved Standard Contractual Clauses (and, where applicable, the UK International Data Transfer Addendum or other equivalent UK-approved transfer terms) with our service providers, affiliates, or business partners receiving personal data outside the EEA or the UK.

l Other Recognized Transfer Mechanisms: Where applicable, we may rely on another transfer mechanism recognized under the GDPR, such as an adequacy decision adopted by the European Commission for the recipient jurisdiction or, if available and applicable to a certified recipient in the United States, the EU-U.S. Data Privacy Framework or another comparable lawful mechanism.

7.2 Supplementary Measures and Protection Level

When transferring personal data to recipients in countries outside the EEA or the UK that are not recognized as providing an adequate level of protection, we assess the nature of the transfer and, where appropriate, implement supplementary technical, contractual, and organizational measures designed to ensure that your personal data receives a level of protection that is essentially equivalent to the protection afforded within the EEA or the UK.

l Technical and Organizational Measures: These measures may include encryption in transit and at rest, access controls, data minimization, role-based access restrictions, vendor due diligence, and onward transfer limitations.

l Contractual Safeguards: Our contractual arrangements with recipients are intended to require them to protect the personal data they process, use it only for authorized purposes, apply appropriate security measures, and assist us in responding to data subject rights and regulatory obligations where required.

7.3 How to Obtain More Information

You may request more information about the safeguards we use for international transfers, including a copy of the relevant Standard Contractual Clauses or information about the applicable transfer mechanism, by contacting us at service.eu@ugreen.com. Where necessary, we may redact portions of such documents to protect confidential business information or security details.

8.0 Automated Decision-Making and Profiling

We do not use automated decision-making that has legal or similarly significant effects on you.

We do, however, engage in profiling for the purposes of personalization and targeted advertising. For example, we use your browsing history and purchase data to recommend products and to show you advertisements that we believe will be relevant to your interests. You have the right to object to this type of profiling, which you can exercise by managing your cookie preferences and by opting out of marketing communications.

9.0 Privacy for Children

We do not knowingly attempt to solicit or receive information from children. If you are a parent of a child and believe that your child has provided us with information about themselves, please contact us using the information in the Contact Us section below.

10.0 Update

We may update this Privacy Policy if applicable law and our business practices change. When this policy is updated, we will notify you via a pop-up window on our website or we will seek your consent again.

11.0 Contact Information

If you have any questions or concerns about this Privacy Policy, please contact us at service.eu@ugreen.com.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Please note that the dispute resolution process shall be conducted in English.