Last updated: May 30, 2023
1. Information We Collect About You and How We Collect It
1.1 Information You Provide To Us
Depending on the service you choose, you may provide the following types of information to us:
- Account information. When you create a Narwal account, you may provide us with information that includes your username, email address (or phone number, based on the country located in), password or other information for account verification. You might choose to provide us with additional information — like gender, photo and other information which may be shown on your profile page.
- Contact information. When you place an order with Narwal, or contact us for customer service, you may provide us with your contact information including your name, alias, email address, shipping address, billing address and phone number.
- Payment information. When you place an order with Narwal or engage in financial transactions by using our Service (such as receiving refund for your returns), you may provide us with your payment information such as your bank account, credit card number, or debit card number.
- When you contact us, we may collect information about your communications with us, including your contact information, and the time, topic, and content of your communications.
1.2 Information We Collect Through Automatic Data Collection Technologies
1.3 Information We Collect From Third Parties
If you access our Service through third parties (e.g., Facebook or Google), or if you share content from our Service to a third-party social media service, the third-party service will send us certain information about you if the third-party service and your account settings with it allow such sharing: the information we receive will depend on the policies and your account settings with the third-party service. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Service.
2. How We Use Your Information
The purpose of collecting personal information is to provide you with our Service and to ensure that we comply with applicable laws, regulations and other regulatory requirements. This involves:
- To analyze the information you provide to us so as to provide you with tailored content that will be of interest to you.
- To understand and analyze the usage trends and preferences, to improve our Services, and to develop new products, services, features, and functionality.
- To contact you for administrative and informational purposes, including for customer service. For example, to notify you about changes to our Service or any products or services we offer or provide through it.
- To detect, prevent, and respond to fraud, abuse, security risks, and technical issues that could harm our users, us, or the public.
- For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
- To comply with applicable laws, such as laws related to signing up online user accounts.
For EU/EEA Users
If you are located in the European Economic Area, we will only use your information when we have a valid legal ground, including when:
- You have consented to the use of your information, for example, to send you marketing communications.
- We need to use your information to enter into or perform a contract with you, for example to deliver Narwal products, to provide map services, or provide you with customer support and other after-sales services.
- We need to use your information to comply with a legal obligation, for example, to comply with a court order, subpoena, or warrant.
- We or a third party have a legitimate interest in using your information. In particular, we have a legitimate interest in using your information to understand and improve our Service and to monitor for and prevent fraud. We only rely on our own or a third party’s legitimate interests to process your information when these interests are not overridden by your rights and interests.
We may also use your information to send direct marketing such as communications, including updates on promotions and events, relating to products and services offered by us. If you are an individual or consumer we will only send you direct marketing with your consent or as permitted by applicable law. You may send unsubscribe requests or withdraw your consent at any time. Please visit the section Your Rights and Choices to learn more.
3. How We Share, Disclose And Transfer Your Information
- Sharing that you actively choose or request. With your consent or at your request, we will share your personal information within the scope of your consent/request with specific third parties designated by you.
- Sharing information within our group. In order to successfully conduct business operations and to provide you with all the functions of our products or services, we may share your personal information from time to time to our parent company, affiliates and subsidiaries globally when permitted by law, and necessary to provide you with our products and services.
- Sharing with third party service providers and business partners. We work with third party service providers to provide payment facilitation, shipping and delivery, application development, traffic monitoring or analysis, electronic messaging, data storage and other services for us. We require these service providers to use or disclose the information they process on our behalf, only as necessary to perform services on our behalf or comply with legal requirements.
- Any information that you voluntarily choose to make publicly available by uploading it to a publicly accessible site or venue using our Service, or that you otherwise elect to make public, will be available to anyone who has access to that content, including other users.
- We also reserve the right to preserve and disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activities, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our products and services and any facilities or equipment used to make our products and services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
- Information about our users, including information you provided and any information collected through our Service, may be disclosed and otherwise communicated to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
- We may make certain aggregated, de-identified, or non-identifying information about users of our products and services available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; (iii) product safety analysis; or (iv) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality of our products and services.
3.4 International Transfer
Information we collect from you may be processed in and may be stored, transferred to, and processed in other countries/regions where we have facilities or in which we engage service providers. These countries may be outside your country of residence and may have different data protection laws than your country.
For EU/EEA Users
The European Commission has decided that some countries/regions provide an adequate level of protection. We rely on the Commission’s decision with regard to the transfer; or
For some of these transfers, we are providing appropriate safeguards such as Standard Contractual Clauses, as according to Article 46 of the GDPR.
4. Your Rights and Choices
The GDPR provides consumers (EU/EEA residents) with specific rights regarding their personal information. This section describes your GDPR rights. To exercise any of these rights, you may contact us using the contact details provided in the section Contact Information below.
- Access to Personal Information — You have the right to obtain confirmation from us that we process your personal information and, if so, you may have the right to request access to your personal information.
- Rectification of Personal Information — You have the right to request that we rectify inaccurate personal information concerning you and, depending on the purposes of the processing, you may have the right to have incomplete personal information completed.
- Erasure/Deletion — You have the right to request us to erase some or all of the personal information concerning you.
- Restriction of Processing — You have the right to request us to restrict the further processing of your personal information. In such cases, the respective information will be marked as restricted, and may only be processed by us for certain purposes.
- Object to Processing — You have the right to object, on grounds relating to your particular situation, to the processing of your personal information by us, and we may be required to no longer process some or all of your personal information.
- Object to Direct Marketing — You have the right to object to the processing of personal information for direct marketing purposes. If you do not want to receive any of such newsletters, marketing or promotional materials from us, please follow the unsubscribe instructions provided in the email we send, or you can contact us using the contact details provided in the section Contact Information below. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).
- Object to Decision Based Solely on Automated Processing — You have the right not to be subject to a decision based solely on automated processing where the decision has a significant legal impact on you.
- Data Portability — You have the right to receive a copy of your personal information which you have provided to us, in a structured, commonly used, and machine-readable format, and you have the right to request the transfer of that personal information to another entity without hindrance from us.
- Withdraw Consent — You have the right to withdraw consent you have provided to us where we rely solely on your consent to process your personal information. You can always provide your consent to us again at a later time. Please note that the withdrawal will not affect the processing of data based on prior consent.
- The Right to Complain — You have the right to make a complaint to an applicable supervisory authority or other regulators if you are not satisfied with our responses to your requests or how we manage your personal information. A list of and more information about the EU/EEA Data Protection Authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
We encourage you to first or also reach out to us at firstname.lastname@example.org, so we have an opportunity to address your concerns directly.
5. Your California Rights and Choices
The CPRA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CPRA rights. To exercise any of these rights, you may contact us using the contact details provided in the section Contact Information below.
5.1 Access to Specific Information and Data Portability Rights
You have the right to request that the Company disclose certain information to you about our collection and use of your personal information over the past 12 months.
Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or sharing that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclose your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.
5.2 Deletion Request Rights
You have the right to request that the Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
5.3 Personal Information Sales Opt-Out Rights
Please note that if you are 16 or older, you have the right to direct us not to sell your personal information at any time (the “right to opt-out”).
5.4 Processing of Sensitive Personal Information Opt-out Rights
Please note that if you are 16 or older, you have the right to direct us not to sell your personal information at any time (the “right to opt-out”).
We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for like-goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of like-goods or services.
- Suggest that you may receive a different price or rate for like-goods or services or a different level or quality of like-goods or services.
5.6 Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website, App, other products, services and platforms that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
6. Third-Party Services
Our Service may contain features or links to websites and services provided by third parties. Any information you choose to provide on third-party sites or services, or any information otherwise collected by such third-party sites or services is collected directly by the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our Service.
7. Data Retention and Security
We have implemented measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. For example, when possible, we use encryption to transfer and store data. We further limit access to this data using access controls and confidentiality commitments.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Service, like message boards. The information you share in public areas may be viewed by any user of the Service.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Service. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained in the Service.
8. Children’s Privacy
Our Service is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website/App. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at email@example.com.
10. Contact Information
Mail Address: Room A2901, Yunzhongcheng, Building 1, Vanke Yuncheng VI, Dashi 2nd Road, Xili Community, Xili Street, Nanshan District, Shenzhen, Guangdong, China
Attn: Legal & Compliance Department
Email Address: firstname.lastname@example.org
(This document may be translated into multiple languages. In case of any inconsistency, the English version shall prevail）