WEBSITE
PRIVACY POLICY

Effective Date: April, 2020
 

Introduction

Welcome! You have arrived at a site that is owned and/or operated by Sinomax USA, Inc. (collectively, “Sinomax”, “we”, or “us” or “our”).   This Privacy Policy (this “Policy”) governs: (i) your use of our sites that post a link to this Policy (including both mobile and online versions of our sites), and also applies to your use of interactive features, widgets, applications, content or downloads that (a) we own or control; or (b) interact with such sites and post this Policy; (ii) in-person interactions; and (iii) phone and email interactions (all of the foregoing, collectively, the “Sites”) regardless of how you access or use them, whether via personal computers, mobile devices or otherwise, but does not apply to data we receive from third parties, even if they use our technology to collect it, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Policy.  The Sites include the following:
 

  • Sinomax-usa.com

  • Purelux.com

  • Dreamserenity.com

  • Dreamstudiosleep.com

  • Dreambed-lux.com

  • Ecossentials.com

  • Zeopedic.com
     

To the extent we provide you notice on our Sites of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
 

In addition, please review each Site’s Terms of Service (“Terms of Service”), which governs your use of each Site.
 

Acceptance of the Privacy Policy

By using our Sites, you consent to this Policy and the applicable Terms of Service and our collection, use and sharing of your information and data, and other activities, as described below.

This Policy affects your legal rights, responsibilities and obligations and govern your use of the Sites and are legally binding. If you do not wish to be bound by this Policy, do not use the Sites and uninstall Site downloads and applications.
 

Updates to This Policy

We may prospectively change this Policy and Additional Policy by posting new or changed terms on the Site as more fully explained here.
 

Table of Contents

It is important that you read and understand these entire Policy before using the Site.  This table of contents further highlights some key issues and points and you can click on the headings to be taken to the full explanation.


1. OVERVIEW OF POLICY

2. WHAT INFORMATION DO THE SITES COLLECT AND WHEN DO WE COLLECT IT?

3. HOW DO WE USE THE INFORMATION COLLECTED?

4. HOW AND WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?

5. CERTAIN PRIVACY RIGHTS

6. WHAT ABOUT INFORMATION I DISCLOSE PUBLICLY?

7. DO THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SITES APPEAR ON THE SITES?

8. HOW DO I CHANGE MY INFORMATION AND COMMUNICATIONS PREFERENCES?

9. NOTICES AND QUESTIONS

10. HOW LONG WILL WE RETAIN YOUR PERSONAL INFORMATION?

11. WHAT ABOUT SECURITY?

12. WHAT ABOUT CHANGES TO PRIVACY POLICY.

13. DO YOU NEED EXTRA HELP?

 

1.OVERVIEW OF POLICY
 

It is important that you read these entire Policy, but below are some of the more significant terms that we want to bring to your attention (click on section references for details). The complete provisions, and not the headings or summaries, govern.
 

  • What Information Do the Sites Collect and When Do We Collect It?
     

    • Information You Provide To Us.  You may give us Personal Information and Demographic Information, such as when you register or contact us.
       

    • Information We Collect As You Access And Use the Sites.  Tracking Technologies (such as cookies) collect Usage Information based on your Device Identifier.  Information is collected through your interactions with Third Party Sites.
       

    • Information Third Parties Provide About You.  We may obtain information about you from third parties.
       

    • Interactions with Third Party Sites. If you interact with third party sites, those sites may send us information about you and you or we may send them information about you.
       

    • Are Ads Served On The Sites?  We and third parties may send you targeted ads based on your location, information and/or behavior.  If you object, do not use our Sites and/or exercise choices some third parties may offer.
       

    • Information You Provide About a Third Party.  You may give us information about others, such as when you send a friend a message.
       

  • How Do We Use The Information Collected?
     

    • Use of Information By Us.  We use your Personal Information, Demographic Information and Usage Information for a variety of purposes.
       

    • Use of Information For Recruitment Purposes.  If you apply for a job with us, we use the application information for considering you for a position.
       

  • How and When Do We Disclose Information To Third Parties?
    We may provide your information to third parties under various circumstances.

    These may include:

     

    • When You Request Information From or Provide Information to Third Parties.  If you request information from third parties, request that we send information to third parties or interact with third party sites, content, ads or tools (including third party share functionality) we may share your information with such parties and/or they may collect your information directly.
       

    • Third Parties Providing Services on Our Behalf.   Our vendors may collect your information or we may share it with them.
       

    • Administrative and Legal Reasons.  There are a variety of administrative and legal reasons for which may share your information.
       

    • Affiliates and Business Transfer.  We may share your information with our affiliates or in the event of a sale, merger or similar transaction.
       

    • Sweepstakes, Contests And Promotions.  Promotions entrants may be required to consent to certain information sharing.
       

  • Certain Privacy Rights
     

    • Your California Privacy Rights.  You have certain rights under California privacy laws.
       

    • What About Transfer of Information To The United States?  Data may be transferred to the United States.
       

    • What Should Parents Know About Children?  We do not intend to collect Personal Information from children.  If you think we have, let us know.
       

  • What About Information I Disclose Publicly?
     

    • User Generated Content and Public Information.  Posting content in public areas makes it available to others. 

    • Name and Likeness.  You grant us the right to use your name and likeness in connection with your posting and activities.
       

  • Do Third Party Content And Links To Third Party Sites Appear on The Sites?  We are not responsible for your interaction with third party content or locations.
     

  • How Do I Change My Information And Communications Preferences?  You may change certain account information and preferences.
     

  • Notices and Questions.
     

  • How Long We Retain Your Personal Information.  We retain your Personal Information only for as long as it serves the purpose(s) for which it was initially collected.
     

  • What About Security?  No data security is absolute, but we take reasonable steps to secure data appropriately. 
     

2. WHAT INFORMATION DO THE SITES COLLECT AND WHEN DO WE COLLECT IT?
 

A. Information You Provide to Us. On the Sites, we may ask you to provide us with certain categories of information such as:
 

(i) Personal Information.  Personally identifiable information, such as your first and last name, social security or taxpayer identification number, home address, email address, phone number, payment information (e.g. credit card number, expiration date, CVV, electronic payment account information) and financial information (“Personal Information”); and
 

(ii) Demographic Information.  Demographic information, such as Information about your type of business, gender, marital status, income or revenues, education level, and occupation (“Demographic Information”).
 

We may collect this information through various forms and in various places on a Site, including (1) when you purchase a product from the Site, (2) communicate with us about a Product you have purchased from us, (3) through account registration or contact us forms, (4) by responding to surveys or polls in which we ask you to participate, (5) through chat or other communications features on the Site, or (6) when you otherwise interact with the Site. When you make a payment for a product that you purchase via a Site, you will likely need to provide Personal Information to our service providers (i.e., payment processors), such as your credit card number or electronic payment account information.
 

If we combine Demographic Information with the Personal Information we collect directly from you on the Sites, we will treat the combined data as Personal Information under this Policy.
 

B.  Information We Collect or Store as You Access and Use the Sites.  In addition to any Personal Information or other information that you choose to submit to us via our Sites, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Sites (“Usage Information”).  This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, laptop, tablet, mobile phone or other device (each, a “Device”) whenever you visit or interact with our Sites.  Usage Information typically is anonymous information not associated with you or your identity. However, if Usage Information is combined with your Personal Information in a manner that it is directly associated with your identity, it will be treated as Personal Information under this Policy.
 

This Usage Information may include:
 

  • your IP address or other unique identifier (“Device Identifier”).  A Device Identifier is a number that is automatically assigned to your Device used to access the Sites, and our computers identify your Device by its Device Identifier;
     

  • your Device functionality (including browser, operating system, hardware, mobile network information);
     

  • the URL that referred you to our Sites;
     

  • the areas within our Sites that you visit and your activities there, including remembering you and your preferences;
     

  • your Device location;
     

  • your Device characteristics; and
     

  • certain other Device data, including the time of day, among other information.
     

C. Tracking Technologies.  We may use various developed methods and technologies to store or collect Usage Information (“Tracking Technologies”).  Tracking Technologies may set, change, alter or modify settings or configurations on your Device.  A few of the Tracking Technologies include the following (and subsequent technology and methods later developed):
 

(i)  Cookies and Similar Technologies.
 

Cookies are small pieces of data stored and managed by your web browser that enable certain Site features and functionality. Cookies and similar technologies can be used to recognize you and your device when you visit a Site, remember your preferences, and make your interactions with the Site faster and more secure. Cookies are a built-in feature of the Web, but they can generally be managed, disabled, or removed using most commercial web browsers. Each browser you use will need to be set separately and different browsers offer different functionality and options for cookies. Please be aware that if you disable or remove cookies on your device, some parts of a Site may not function properly, and that when you revisit the Site your ability to limit cookies is subject to your browser settings and limitations. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit allaboutcookies.org or aboutcookies.org.  Note that such limitations, however, are not effective on mobile applications, though many applications allow users to “opt out” of certain advertisements and other features by adjusting their mobile device settings.
 

The types of cookies that we use on the Sites, and the purposes for which they are used, are as follows:
 

  • Strictly necessary cookies: These cookies are essential to enable you to move around a Site and use its features, such as accessing secure areas. Without these cookies, any services on a Site you wish to access cannot be provided.
     

  • Analytical/performance cookies: These cookies allow us to recognize and count site visitors and to see how visitors move around a Site when they are using them. This helps us to improve the way a Site works, for example, by ensuring that users are finding what they are looking for easily. All information these cookies collect is aggregated and is used only to improve how a website works.  In addition, we use third party service providers to provide certain analytics services to use in connection with the operation of a Site.  These include Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to track Site usage and activity anonymously. Google Analytics uses cookies, and the information generated by such cookies about your use of a Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information on our behalf for the purpose of evaluating your use of a Site, compiling reports on website activity and providing to us other services relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google. You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under:
    https://tools.google.com/dlpage/gaoptout?hl=en-GBM. Further information about Google’s terms and conditions for Google Analytics can be found at: http://www.google.com/analytics/terms/gb.html.

     

  • Functionality cookies: These cookies allow a Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video. Additionally, these cookies can be used to allow an optional service to function.  The information these cookies collect may be anonymized and these cookies cannot track your browsing activity on other websites.
     

  • Targeting cookies. These cookies record your visit to a Site, the pages you have visited and the links you have followed. We use this information to make Sites more relevant to your interests. We may also share this information with third parties for this purpose.
     

(ii)  Tracking URLs. These are used to determine from which referring website a Site is accessed.
 

(iii) Web Beacons. A web beacon is an electronic image, also called a "gif," that may be in the form of a "png" image, as well as iframe, script, input link, embed, object, and other tags that are used to track usage. We may use these web beacons on a Site to deliver cookies, to attribute sales to any advertising media or affiliate partners with whom we may have a relationship, to count visits, to compile statistics about usage, to help determine the effectiveness of promotional or advertising campaigns, and/or in emails that we may send you in order to tell if you have opened or acted on email that we have sent you.
 

There may be other Tracking Technologies now and later devised and used by us in connection with the Sites.  Further, third parties may use Tracking Technologies with our Sites.  We may not control those Tracking Technologies and we are not responsible for them.  However, you consent to potentially encountering third party Tracking Technologies in connection with use of our Sites and accept that our statements under this Policy do not apply to the Tracking Technologies or practices of such third parties.  For more information on advertising and advertisers, and related Tracking Technologies, click here.
 

D. Information Third Parties Provide About You.  We may receive information about you from your friends and others that use the Sites, such as when they submit content to us or post on the Sites.  Additionally, we may periodically supplement the information we collect directly from you on our Sites with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you, and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with Personal Information we collect on the Sites, it will be treated as Personal Information and we will apply this Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our promises under this Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.
 

E. Interactions with Third Party Sites; Third Party Ads.
 

The Sites may include: (i) functionality that allows certain kinds of interactions between the Sites and your account on a third party web site or application; (ii) third party sites’ interfaces or links on the Sites to facilitate your sending a communication from the Sites; and/or (iii) content served by advertisers or third party ad networks/exchanges.   These third parties may gather and retain any information used or provided in any such communications or other activities, and may enable such third parties to market products or services to you, and to monitor which ads have been served to your browser and which webpages you were viewing when such ads were delivered. They may themselves set and access their own Tracking Technologies on your Device and track certain behavioral Usage Information regarding users of your Device via a Device Identifier. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
 

We do not control these third parties, and these third parties’ practices are not subject to this Policy.  You should review the relevant third party’s terms of service, privacy policy, permissions, notices and choices regarding their collection, storage and sharing practices.  We are not responsible for any such third party policies, practices, technologies or activities. We are not responsible for the effectiveness of or compliance with any third party’s opt-out options.
 

We do however work with third parties to make efforts to have you provided with the information on their practices and any available opportunity to exercise choice.  Some third parties may offer you certain choices regarding their practices.  Further, while we may use a variety of companies to serve advertisements on the Sites, you may wish to visit http://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members.  You may also opt-out of receiving third party behavioral ads on this site by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices/#completed.
 

F. Information You Provide About a Third Party.  You may send someone else a communication from the Sites, such as sending an invitation to a friend.  If so, the information you provide (names, e-mail addresses, mobile number, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise.  Please be aware that when you use any send-to-a-friend functionality on our Sites, your e-mail address, mobile number, name or user name and message may be included in the communication sent to your addressee(s).  Some of these tools may be third party tools subject to third party privacy policies.

 

3.  HOW DO WE USE THE INFORMATION COLLECTED?
 

A. Use of Information by Us. We may use your Personal Information, Demographic Information or Usage Information that is subject to this Policy: (i) to process and consummate your transactions with us (including delivering products and services to you); (ii) to provide you with information that you have requested or agreed to receive including to send you electronic newsletters, or to provide you with information about products or services, including special offers or promotional materials on behalf of us or third parties; (iii) to enable you to participate in a variety of the Sites’ features such as online entry sweepstakes, contests or other promotions; (iv) to process your registration with the Sites, including verifying your information is active and valid; (v) to improve the Sites or our products and services, to customize your experience on the Sites, or to serve you specific content that is relevant to you; (vi) to contact you with regard to your use of the Sites (including trying to solve any problems that you may encounter relating to your use of the Sites) and, in our discretion, changes to the Sites and/or Sites’ policies; (vii) for internal business purposes; and (viii) for purposes disclosed at the time you provide your information or as otherwise set forth in this Policy.
 

Please note that information submitted to the Sites via a “contact us” or other similar function may not receive a response; we will not use that information so provided to contact you for marketing purposes unrelated to your inquiry unless you agree otherwise.
 

B. Use of Information for Recruitment Purposes.  Where you have provided us with Personal Information or Demographic Information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application.  We may, as part of this recruitment process, collect information about your education, employment history and similar matters.  Where this Personal Information or Demographic Information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.

 

4. HOW AND WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?
 

We may share Personal Information, such as aggregated user statistics, with third parties.  We may share your Device Identifiers with third parties along with data related to you and your activities.  We do not share your Personal Information that we have collected directly from you on our Sites with third parties for those third parties’ marketing purposes unless you consent to such sharing at the time you provide your Personal Information.  In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Policy.
 

A. When You Request Information From or Provide Information to Third Parties.  You may be presented with an option on our Sites to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it.  If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third party privacy policies and practices of such third parties.  In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Sites or link to them from our Sites.  This may include using third party tools such as Facebook, Twitter, Pinterest or other third party posting or content sharing tools.  It may also include ordering or purchasing products from affiliates or third parties through us where we indicate that the affiliate or third party rather than us is the seller.  We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
 

B.  Third Parties Providing Services on Our Behalf.  We may use third party vendors to perform certain services on behalf of us or the Sites, such as hosting the Sites, designing and/or operating the Sites’ features, tracking the Sites’ activities and analytics, and enabling us to send you special offers or perform other administrative services.  We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us.  Third party analytics service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you.  We are not responsible for those third party technologies or activities arising out of them.  However, some may offer you certain choices regarding their practices (click here for your choices related to Google Analytics). We are not responsible for the effectiveness of or compliance with any third parties opt-out options.
 

C. Administrative and Legal Reasons.  We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information), including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Terms of Service or the applicable Site or other policies applicable to a Site, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Sites or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues.  Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law.  Such disclosures may be carried out without notice to you.
 

D. Affiliates and Business Transfer.  We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates.  We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Sites or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
 

E. Sweepstakes, Contests and Promotions.  We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Sites that may require registration.  By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion.  If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

 

5.      CERTAIN PRIVACY RIGHTS
 

A.  California Privacy Rights. 

(i) Shine the Light.  Under California’s “Shine the Light” law (California Civil Code Section 1798.83), California residents have the right to receive information about third parties with whom we have shared information about you for their marketing purposes during the previous calendar year and a description of the categories of Personal Information shared.  To make such a request, please contact us here, with “Request for California Privacy Information” in the subject line or written request.  Requests may be made only once a year and are free of charge.
 

(ii) Summary of CCPA Rights.  If you are a California resident, in addition to your “Shine the Light” rights outlined above, you have certain rights pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). These CCPA rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. You can exercise these rights using the contact details below.

 
 
 
 
 
 
 

Disclosure of Personal Information We Collect About You

Personal Information Sold or Used for a Business Purpose

Right to Deletion

Protection Against Discrimination

Stop Selling My Personal Information

You have the right to know:

  • The categories of Personal Information we have collected about you;

  • The categories of sources from which the Personal Information is collected;

  • Our business or commercial purpose for collecting or selling Personal Information;

  • The categories of third parties with whom we share Personal Information, if any; and

  • The specific pieces of Personal Information we have collected about you.
     

You can ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to Personal Information we collected about you in the previous 12 months.

In connection with any Personal Information we may sell or disclose to a third party for a business purpose, you have the right to know:
 

  • The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and

  • The categories of Personal Information that we disclosed about you for a business purpose.

Subject to certain exceptions, on receipt of a verifiable request from you, we will:
 

  • Delete your Personal Information from our records; and

  • Direct any service providers to delete your Personal Information from their records.
     

Choosing to delete your Personal Information may impact your ability to use the Sites and online features.

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
 

  • Deny goods or services to you;

  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

  • Provide a different level or quality of goods or services to you; or

  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
     

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your Personal Information.

You have the right under the CCPA and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your Personal Information.
 

We do not share your Personal Information for money. We do share Personal Information within our affiliated and with certain third parties, which may be considered a “sale” under California law even if we don’t receive money in exchange for the information. For purposes of California law, we may share with these parties all categories of Personal Information, except for background and criminal information, biometric information, and government identifiers. We do not knowingly sell the Personal Information of minors under 16 years of age. If you are a California resident, you have a right to opt-out of the sale of your Personal Information. To do so, click “Do Not Sell My Personal Information” at the bottom of this page.

(iii) Personal Information We May Collect About You.  We may collect and use the following Personal Information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  Please see Section 2, Section 3 and Section 4 of this Policy for additional information.

Category of Personal Information

Sources of Personal Information

Business or commercial purpose for which it was collected

Categories of third parties with whom the business shares Personal Information

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, his or her name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, bank account number, credit card number, or any other financial information or similar identifiers

Directly from you or your authorized representative; via our service providers or other third parties

Performing services on behalf of the business including maintaining or servicing accounts, providing customer service, verifying customer information, providing advertising or marketing services,  or providing analytic services

Affiliates; Service providers we use to help deliver our products and services to you, such as payment service providers and delivery companies; Other third parties we use to help us run our business, such as marketing agencies or website hosts; Third parties approved by you, such as social media sites or third-party payment providers;  Credit reporting agencies;  Third parties when required to do so by law or otherwise to protect our legal rights, property, and safety

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

Directly from you; via our service providers

Performing services on behalf of the business including providing analytic services; auditing related to a current interaction with the consumer and concurrent transactions, including  counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards

Affiliates; Service providers we use to help deliver our products and services to you, such as payment service providers and delivery companies; Other third parties we use to help us run our business, such as marketing agencies or website hosts; Third parties approved by you, such as social media sites or third-party payment providers; Third parties when required to do so by law or otherwise to protect our legal rights, property, and safety

Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Directly from you; via our service providers

Performing services on behalf of the business including processing or fulfilling orders and transactions, verifying customer information, processing payments

Affiliates; Service providers we use to help deliver our products and services to you, such as payment service providers and delivery companies; Other third parties we use to help us run our business, such as marketing agencies or website hosts; Third parties approved by you, such as social media sites or third-party payment providers; Third parties when required to do so by law or otherwise to protect our legal rights, property, and safety

Geolocation information

Directly from you; via our service providers

Performing services on behalf of the business including providing advertising or marketing services, providing analytic services

Affiliates; Service providers we use to help deliver our products and services to you, such as payment service providers and delivery companies; Other third parties we use to help us run our business, such as marketing agencies or website hosts; Third parties approved by you, such as social media sites or third-party payment providers; Third parties when required to do so by law or otherwise to protect our legal rights, property, and safety

Protected class information Refer to, for example: https://www.senate.ca.gov/content/protected-classes

Directly from you; via our service providers

Performing services on behalf of the business including providing advertising or marketing services, providing analytic services

Affiliates; Service providers we use to help deliver our products and services to you, such as payment service providers and delivery companies; Other third parties we use to help us run our business, such as marketing agencies or website hosts; Third parties approved by you, such as social media sites or third-party payment providers; Third parties when required to do so by law or otherwise to protect our legal rights, property, and safety;

Inferences drawn from any Personal Information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes

Derived

Performing services on behalf of the business including providing advertising or marketing services, providing analytic services

Affiliates; Service providers we use to help deliver our products and services to you, such as payment service providers and delivery companies; Other third parties we use to help us run our business, such as marketing agencies or website hosts; Third parties approved by you, such as social media sites or third-party payment providers; Third parties when required to do so by law or otherwise to protect our legal rights, property, and safety

(iv) How to Exercise Your Rights. 

If you would like to exercise any of your CCPA rights as described in this Policy, please:
 

  • Complete a data subject request form available on our website at [www.sinomax-usa.com/];
     

  • Call us, toll-free, at 1-877-726-3888;
     

  • E-mail us at: websiteadministrator@sinomax-usa.com; or
     

  • Write to us at: Sinomax USA, Inc., Attention:  Website Administrator, 3151 Briarpark Dr, Suite 1220, Houston, TX 77042.
     

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
 

Also note that since we do not sell Personal Information, we don’t have an opt-out for that.
 

We take the privacy of your Personal Information seriously and want to ensure that we provide only you or your authorized agent with your Personal Information.  The CCPA also requires that we verify the identity of each person that makes a request to find out what Personal Information we have about you or to delete the Personal Information we have about you.  Therefore, to verify your identity, you will need to provide us with:
 

  • Enough information to identify you (e.g., your full name);
     

  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
     

  • A description of what right you want to exercise and the information to which your request relates.
     

We are not obligated to make a disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.  Any Personal Information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
 

(v) How to Submit Request Using Authorized Agent.  An authorized agent is a person or business who has authorization to request to know what Personal Information we have about you, to delete the Personal Information we have about you, or to opt out of the sale of Personal Information on behalf of a California resident. Authorized agents use the same links described above to submit requests.
 

If you are submitting a request on behalf of another person, we require a valid power of attorney and a signed attestation form. If you do not have a valid power of attorney, we require an authorization document and a copy of the consumer’s government-issued photo identification in addition to our attestation form. Our attestation form can be downloaded from the request form.
 

B. Privacy Rights in Other Countries.  The Sites are operated in the United States. By providing us with any information or materials via the Sites, you consent to the transfer and processing of your information and materials in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States.  The data protection laws in the United States may differ from those of the country in which you are located (particularly if you are visiting from the European Union/European Economic Area) and may not afford you the same rights as the laws such countries afford you.  Further, your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By providing your Personal Information, you agree to the use of your Personal information for the uses identified above in accordance with this Policy and to the transfer of your Personal Information to the United States, as indicated above, in accordance with applicable law.
 

C. Canadian Privacy Rights.  Canadian residents may access their Personal Information that is in our custody and control, subject to certain exceptions prescribed by law. To make such a request, please contact us here. We may request certain Personal Information for the purpose of verifying the identity of the individual seeking access to their Personal Information.
 

D. Do Not Track Signals.  Some web browsers may transmit “do not track” signals.  At this time, we do not take steps to respond to such signals.  You can manage your cookie preferences using your own browser settings to accept or block some or all cookies, or to receive notice so you can consent to cookies.  If you block all cookies, some features of the Sites may be unavailable to you.
 

E. Children.  The Sites do not offer products or services to children and we do not knowingly collect any Personal Information from children younger than the age of 13. We will delete any Personal Information collected that we later determine to be from a person younger than the age of 13.

 

6.  WHAT ABOUT INFORMATION I DISCLOSE PUBLICLY?

A. User Generated Content and Public Information.  The Sites may permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), such as on blogs and message boards.  We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you.  Others may have access to this User Content and may have the ability to share it with third parties.  Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content.  Please note that Sinomax does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure.  Our promises under this Policy do not apply to any information that you disclose publicly, share with others or otherwise upload onto the publicly available positions of our Sites.  We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Sites.
 

B. Name and Likeness.  We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.  For full terms and conditions regarding User Content you submit to a Site, please review the applicable Terms of Service for that Site. 
 

C. Profiles.  A user’s profile page may be, by default, set up to display information such as the user’s display name, images, location (city/state/country), and optional information added by the user including, for example, photographs.  We may make it possible for users to see a report on other users that visited a profile page and this gives users access to such visitor’s profile pages.  Profile information is used by us primarily to be presented back to and edited by you when you access a Site and to be presented to others permitted to view that information on a Site. In some cases (e.g., posting to your page), other users of the Sites may be able to supplement your profile.  We may offer users the ability to manage their public profile and use profile preference settings, the functionality and features of which are subject to change from time-to-time so visit it frequently to confirm the settings reflect your then current preferences and we recommend that you do not post information or content as part of your profile that you are not prepared to make public.  Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules.  Users should carefully consider the use of such settings to improve information display options and to ensure the settings are properly set and functioning in the manner desired.  Notwithstanding the availability of profile preference settings, you should be aware that these settings are for convenience only, do not employ complex data security protection and may not be error free.  Further, other users that have access may repost or otherwise make public your information or content.  Accordingly, discretion and good judgment should be exercised when posting information or content as part of your profile.

 

7. DO THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SITES APPEAR ON THE SITES?
 

The Sites may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Sites are served to you.  In addition, when you are on the Sites you may be directed to other sites that are operated and controlled by third parties that we do not control.  We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others.  For example, if you “click” on a link, the “click” may take you off the Sites onto a different site.  These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies.  We encourage you to note when you leave our Sites and to review the third party privacy policies of all third party locations and exercise caution in connection with them.

 

8. HOW DO I CHANGE MY INFORMATION AND COMMUNICATIONS PREFERENCES?
 

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration.  A Site may allow you to review, correct or update Personal Information you have provided through the Site’s forms or otherwise, and you may provide registration updates and changes by contacting us as outlined here.  If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.  With respect to our mobile and other applications (i.e., when we are the application publisher), you can prospectively stop all collection of information by the application by uninstalling the application.  You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace.  Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.  Also, if you have made any public postings on the Sites such as in forums or blogs, these communications cannot generally be removed.  When you edit your Personal Information or change your preferences on the Sites, information that you remove may persist internally for Sinomax’s administrative purposes.
 

You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails. If you subscribe to text messages from us, you can terminate a particular text message subscription by reply texting “STOP.”  Subsequent or different subscriptions will be unaffected by an opt-out.   Also, if your opt-out is limited to certain types of emails, the opt-out will be so limited. We reserve the right to send you a message confirming any opt-out as well as non-marketing administrative, transactional or account related messages.

 

9. NOTICES AND QUESTIONS.
 

If you have any questions about this Policy or practices described in it, or would like to exercise your rights under this Policy, please contact us in the following ways:
 

  • E-mail: websiteadministrator@sinomax-usa.com
     

  • Regular Mail: Sinomax USA, Inc., Attention:  Website Administrator, 3151 Briarpark Dr, Suite 1220, Houston, TX 77042,
     

  • Phone: 1-877-726-3888 - 8:30am-5:30pm CST
     

Please note that e-mail communications will not necessarily be secure; accordingly, you should not include sensitive information in your e-mail correspondence with us.

 

10. HOW LONG WILL WE RETAIN YOUR PERSONAL INFORMATION?
 

We will retain your Personal Information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Policy, subsequently authorized by you, or as required under applicable law. After such time periods have expired, we may either delete your Personal Information or retain it in a form such that it does not identify you personally.
 

11. WHAT ABOUT SECURITY?
 

We take very seriously the security and privacy of Personal Information that we collect pursuant to this Policy. We incorporate commercially reasonable and appropriate safeguards to help protect and secure your Personal Information from loss, misuse and unauthorized access, disclosure and alteration, taking into consideration the risks involved in the processing and nature of such information.  We will also comply with all applicable laws and regulations. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed to be completely secure. Please consider this prior to submitting Personal Information to us via a Site.
 

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information (as defined in applicable laws concerning security breach notifications) to you via email or conspicuous posting on the applicable Site as promptly as possible, and without unreasonable delay, taking into account the legitimate needs of law enforcement or any measures necessary to determine the scope of the breach and/or to restore the reasonable integrity of the affected data system.  You may have a legal right to receive any such notice in writing. To receive free written notice of any security breach, or otherwise to withdraw your consent from receiving electronic notices, please contact us here.
 

Sinomax is aware of identity theft and unlawful practices known as "phishing.” We do not and will not solicit or request your credit card information or national identification numbers in an unsolicited email or telephone communication. If you receive such solicitations or requests that appear to be from us, please contact us 1-877-726-3888 before responding.
 

12. WHAT ABOUT CHANGES TO THE PRIVACY POLICY?
 

We reserve the right to change this Policy at any time without notice to you.  Any changes will be effective immediately upon the posting of the revised Privacy Policy.  Your continued use of a Site following the posting of revised Privacy Policy means that you accept and agree to the changes. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Policy is found by a court of competent jurisdiction to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
 

13. DO YOU NEED EXTRA HELP?
 

If you would like this Policy in another format (for example: audio, large print, braille) please contact us here.
 

© Sinomax USA, Inc. 2021. All Rights Reserved.