Effective Date: January 5th, 2025

This Privacy Policy applies to the use of this website and all associated sites, online services, email communications, advertisements, computer servers and networks linked to this website.

By using this website, you agree to this privacy policy. Suppose you do not agree with the terms and conditions set out in this Privacy Policy. In that case, you must immediately cease using and accessing this website and any content, services or products contained in or available from this website, especially those which require you to provide personal information.

 

Who are we

 When “we” (or “us” or "the Site") is referred to in this policy, it means xensuri.com or Xensuri Co., Limited

 

Privacy notice overview

This Privacy Policy describes how and why we, as Data Controller, obtain, store and process personal data when you visit or make a purchase from the Site, and applies to all services offered by XENSURI, whether you obtain XENSURI's services via PC, mobile terminal, or other devices.

This Privacy Policy applies only to XENSURI's practices, technologies, and services and does not apply to any products or services provided by third parties (collectively referred to as "Third-Party 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 XENSURI. 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.“

Xensuri Co., Limited” reserves the right to modify this Marketing Communication Policy at any time, and we may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Application or website you used prior to the change becoming effective. 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.If you have any questions regarding this policy or our marketing communications, please get in touch with us.

Your rights and our commitment to you

You have rights under data privacy laws, and Xensuri Co., Limited is committed to you being able to exercise your rights freely. Where possible, we have incorporated automated tools on our website that enable you to facilitate your rights in real time. Your rights include, under certain circumstances, the right to:

Specifically, the rights of Data Subjects under the GDPR are explained in Section below.

 

This Privacy Policy will help you understand the following content:

1. Collection and Purposes of Personal Data

2. Legal Basis for Processing

3. Cookies, Analytics, and Tailored Advertising

4. Protection of your Personal Data

5. Disclosure of Personal Data to third parties

6. Data retention

 

7. Your privacy rights

8. International transfer of personal data

9. Direct Marketing

10. Special provision on the right to privacy of minors

11. Amendment to this Policy

 

12.Contact information

 

1. Collection and Purposes of Personal Data

Data you may provide. We will collect the personal data you provide when you interact with us, such as when you create an account, contact us, submit an online form, or use our online support. If you place an order, we collect personal data in connection with the order.

The categories of data you may provide include the following:

A. Registration

In order to bring you a better experience and service, when you create a personal account on our website, we collect your name and email address or your third-party account name.

B. Subscription Information

We collect your email address for the purpose of sending you updates, logistics status updates, promotional offers, marketing information about products and services, transaction notices, and updates to the terms of our policies.

C. Purchase Information

To assist you with logistics inquiries, product returns, and refunds, we may collect information about your purchases, including quantities, prices, and discounts.

D. Payment Information

When you make a purchase, our third-party payment provider (such as PayPal) collects your name, email address, bank card type, card number, or other relevant information related to the online purchase.

E. Customer service form/after-sales service

To provide you with payment services, process your orders, and keep you updated on product services and the latest offers, we will collect your transaction records, shipping address, billing address, country or region, and other order details.

F. Web log analysis records

To enhance your marketing experience and provide convenient services for marketing research, campaign planning, and troubleshooting, we may collect weblogs or information through third-party tools, and such information will not contain any personally identifiable data.

2. Legal Basis for Processing

If you are subject to the GDPR, the purposes for which we process your personal data and the legal bases for such processing are as follows:

To fulfill our contractual obligations or prior to entering into a contract with you, If you order products or services from us or contact us to inquire about them, we use your personal data to provide these products or services. This includes managing your account and contract, facilitating user benefits and services such as customer support, processing payments for our products and services, or providing information that may help you decide whether to order from us;

Justified by our legitimate interests: We may also use your personal data when necessary for our business interests. For instance, we may use some of your personal data to update and monitor our services, diagnose or resolve technical issues, maintain the safety, security, and integrity of our property, services, technology, and business assets, enforce our terms, resolve disputes, fulfill our obligations, and protect our rights and business interests, as well as those of third parties. Additionally, we may use your data to prevent, investigate, or report fraud or illegal activities.

Consent: In some cases, we may ask you to grant us separate consent to use your Personal Data. In this case, you can revoke your consent at any time with effect for the future.

Compliance with legal obligations: We are required to collect or retain certain personal data due to legal obligations, such as tax or commercial laws, or may be obligated to provide personal data to law enforcement upon request.

 

3. Cookies, Analytics and Tailored Advertising

A cookie is a small data file that gets stored on your computer or mobile device when you visit our site. We use various types of cookies, including functional, performance, advertising, and social media or content cookies. Cookies enhance your browsing experience by allowing the website to remember your actions and preferences, such as login details and region selection. This means you don't need to re-enter this information every time you return to the site or navigate between pages. Additionally, cookies provide insights into how visitors use the website, such as whether it's their first visit or if they are returning users.

We collect information from you when you visit our website or use our mobile applications related to your service. Such as your device's Internet Protocol ("IP") address, browser type and version, the pages of our Site you visit, the time and date of your visit, the time spent on specific pages and other statistics, and whether you arrived at our pages via social media or email. We collect this information through various channels, including cookies, web beacons and other means such as Google Analytics and Facebook Pixel.

Google Analytics. We analyze the data we get from Google Analytics only to improve our website. We don't integrate the information collected from Google Analytics, and such information does not contain any personally identifiable data. Please refer to Google's Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

Google Ads/Facebook Pixel. We also use Google Ads and Facebook Pixel to deliver specific advertising on our website. You can learn more about how to accept or opt out of advertising cookies by visiting the Network Advertising Initiative's Consumer Opt-Out link, the DAA's Consumer Opt-Out link for browsers, or the DAA's Opt-Out link for mobile devices.

For more information on how we Process Your Personal Data regarding marketing, analytics, Cookies and tracking technologies, please see our Cookie Notice.

 

4. Protection of your Personal Data

When you provide, submit, or access your personal information, we implement various security measures to protect it. For example, where applicable, we use encryption technology to transmit and store data. We also apply access controls and confidentiality agreements to further limit access to this data.

Additionally, we have organizational safeguards and security protocols in place to prevent your data from being accidentally lost, misused, accessed without authorization, altered, or disclosed.

Your personal information provided on our website and online credit card transactions are transmitted through a secure server. We do not store any credit card details, which are handled by 3rd party payment provider "Stripe".Our website uses encryption technology, like Secure Sockets Layer (SSL), to protect your personal information during data transport.SSL encrypts ordering information such as your name, billing address, delivery address and credit card number.

 

5. Disclosure of Personal Data to third parties

If necessary to provide you with premium products or services, we may work with third-party service providers to analyze or process your personal data. Your personal information may be shared with third parties as listed below to fulfill your order:

• To improve your website experience: We use Shopify as our website builder and optimization tool and may share your data with them. (Please refer to the first section of this policy.)

• To create a secure payment environment: We partner with third-party payment providers such as Stripe and PayPal.The payment method you choose determines which payment provider will process your data, including your credit or debit card number and other purchase details.

• To deliver your goods: We may share your information (name, address, phone number) with transport companies.If your item is out of stock and needs to be shipped by FBA, your information may be shared with Amazon Inc.

• To offer our products and services: We share your information (name, email address) with third-party affiliates and service providers and any required subcontractors.

• To promote our campaigns: We share your data (name, email address) with third-party marketing partners and advertising platforms (like Facebook, Google) to market our campaigns on xensuri.com and other websites you may visit.

• Third-party links and websites: Our website may contain links to third-party websites. Please note that these websites have their own privacy policies, and we are not responsible for or liable for them. Please review their policies before submitting any data.

• Disclosures required by law: We may be required to disclose your data in response to lawful requests by public authorities, including law enforcement. We may disclose your personal information to comply with legal obligations.

• Independent advisors: We may disclose your personal data to our independent advisors, such as accountants, consultants, lawyers, and other professional advisors, subject to contractual confidentiality obligations.

• Corporate transactions: In the event that XENSURI is involved in a corporate business transaction, such as a merger, acquisition, or sale of company assets, we may share your personal data with third parties during negotiations or as part of the transaction. Suppose XENSURI completes such a corporate business transaction. In that case, you will be notified by email and/or a prominent notice on our website about any changes in ownership, uses of your personal data, and your options regarding your data. Personal data may also be disclosed in case of insolvency, bankruptcy, or receivership.

If we engage a third-party processor to handle your personal data, the processor will be bound by contractual obligations to (i) process the data only according to our written instructions and(ii)take measures to ensure the confidentiality and security of the data, as well as comply with applicable laws. Please note that third parties and business partners may process your data in accordance with their privacy policies and terms of service. We may also disclose your personal data to any other third party or publicly, with your prior consent or direction.

 

6. Data retention

We take all reasonable measures to ensure that your personal data is processed only for the minimum period required to fulfill the purposes outlined in this policy. We will retain your personal data in a form that allows 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) or

(b) your Personal Data are necessary in connection with the lawful purposes set out in this Policy, 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 for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

The factors used to determine how long we will retain your personal data are as follows:

(a) any applicable limitation period under applicable law; and

(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 are 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.

Once the periods in the paragraphs above have concluded, we will either:

(a) permanently delete or destroy the Relevant Personal Data, or

(b) anonymize the Relevant Personal Data.

 

7. Your privacy rights

We are committed to complying with the highest possible international data privacy laws, such as GDPR (General Data Protection Regulation) and CCPA (California Consumer Privacy Act). According to the applicable legislation, you can exercise the following rights:

Access: you can obtain information about the processing of your personal data and a copy of those personal data;

Rectification: if you consider that your personal data are inaccurate or incomplete, you may request to be corrected or modified by following your instructions;

Delete: If you find our collection and usage of your personal information violate the Laws, etc., or mutual agreements, you may contact us at support@xensuri.com and request to delete your personal information collected through such acts;

Refuse to receive promotion notifications: click on the "unsubscribe" button in any emails sent by us to refuse to receive promotion notifications.

You have the right to access the Personal Information we hold about you, to port it to a new service, and to request that your Personal Information be corrected, updated, or erased. Please kindly contact us to exercise these rights through the contact information below support@xensuri.com.

UK Individuals’Rights

If you are from the United Kingdom, you have the right, under certain circumstances to:

· Your consent;

· The performance of the contract between you and the Site;

· Compliance with our legal obligations;

· To protect your vital interests;

· To perform a task carried out in the public interest;

· For our legitimate interests, which do not override your fundamental rights and freedoms.

You may contact us using the contact details provided in the “Contact Information” section below for more information or to exercise your rights.

California Privacy Rights

Request for Information and Deletion (CCPA). California consumers have the right to request, up to twice in 12 months, that a business that collects personal information about the consumer disclose to the consumer the information listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information.

(1) The categories of personal information it has collected about that consumer.

(2) The categories of sources from which the personal information is collected.

(3) The business or commercial purpose for collecting or selling personal information.

(4) The categories of third parties with whom the business shares personal information.

(5) The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.

(6) The categories of personal information that the business disclosed about the consumer for a business purpose.

(7) The specific pieces of personal information it has collected about that consumer.

To make such a request, please email us at support@xensuri.com.

Do Not Sell My Personal Information (CCPA). California consumers have the right to opt out of the sale of the consumer's personal information. We do not sell your personal data to third parties. However, under the CCPA, some sharing of personal information necessary to provide you with personalized ads may be considered a "sale, "even if no money is exchanged, such as our use of Facebook Pixel and similar technologies. You may learn more about how to opt out of such personalized ads through our Cookie Policy.

Third-Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties' direct marketing purposes. To make such a request, please contact us using the contact details provided in the "Contact Information" section below.

Automatic decision-making

You have the right to object to processing based solely on automated decision-making (including profiling) if such decision-making has a legal impact on you or significantly affects you in another way.

We do not engage in fully automated decision-making that results in legal or significant consequences using customer data.

Our processor, Shopify, uses limited automated decision-making to prevent fraud, which does not have a legal or significant effect on you.

Services that involve automated decision-making include:

• A temporary denylist of IP addresses linked to repeated failed transactions, which lasts for a few hours.

• A temporary denylist of credit cards associated with denied listed IP addresses, which lasts for a few days.

 

8. International transfer of personal data

To run our business, we may transfer your personal information outside of your state, province, or country. This data may be subject to the laws of the countries where it is sent. We use Shopify service providers to process data, and your personal information may be transferred across borders in accordance with Shopify's policies. Shopify is a Canadian company, but it works with and processes data from individuals worldwide. When we transfer your information internationally, Shopify takes steps to protect it and strives to send it only to countries with strong data protection laws.

For more details, please refer to Shopify's Privacy Policy.

 

9. Direct Marketing

We process personal data to contact you through email, phone, direct mail, or other communication methods to provide information about Sites, Applications, products, and services that may interest you. Suppose we offer Sites, Applications, products, or services to you. In that case, we may send or display information about our offerings, upcoming promotions, and other content that may be of interest using the contact details you've provided or other suitable means, always subject to obtaining your prior opt-in consent as required by applicable law.

You can unsubscribe from specific promotional email campaigns at any time by clicking the unsubscribe link included in every promotional email we send. After unsubscribing, we will stop sending you promotional emails related to the campaigns you've unsubscribed from. However, in some cases, we may still contact you as necessary to provide any Sites, Applications, products, or services you've requested or in relation to email campaigns you remain subscribed to.

 

10. Special Privacy Policy for Minors

Our Sites, Applications, products, and services are not intended for children under the age of 16. Therefore, we do not knowingly collect or request personal data from individuals under 16. If you are under the age of 16, you should not visit or use our Sites, Applications, products, or services. In compliance with the Children's Online Privacy Protection Act (COPPA), we do not intentionally collect personal information from children. If you are the parent or guardian who believes your child has provided us with Personal Information, please contact us support@xensuri.com below to request deletion.

 

11. Amendment to this Policy

We may update this Privacy Policy periodically to reflect changes in our practices or for other operational, legal, or regulatory reasons. By continuing to use our products and services after the Privacy Policy's effective date, you accept the revised policy. If you do not agree with the updated policy, please refrain from using our products or services and contact us at support@xensuri.com to close any account you may have created.

 

12. Contact Information

We have designated personnel responsible for safeguarding personal information. For more details about our privacy practices, or if you have any questions or would like to file a complaint, please contact us at support@xensuri.com or contact us at 2 Tai Yau Street, Room B20, 11/F, Block B, Wong King Industrial Building, San Po Kong, KL, HK.