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Guangdong Tugou Technology Co., Ltd.(Hereinafter referred to as "we", "TUGOU") attaches great importance to user privacy protection. This Privacy Policy aims to explain how we collect, use, store, and protect your personal information.

Please read this Privacy Policy carefully, and only use our products and services after you fully understand and agree to it.By using our products and services, you agree to all terms of this Privacy Policy.

Information We Collect


We collectlawful, legitimate, and necessaryinformation only as required to fulfill product functions.

Information you actively provide to us when using our services includes, but is not limited to:

We collect your name, email address, phone number, product serial number, purchase date, and purchase channel information for product warranty management, extended warranty services, and after-sales support.

We collect your name, email address, phone number, product model, and issue description to respond to your inquiries and provide technical support.

We collect your email address to send product updates and important notifications (requires your active subscription).

When you visit our website, we may automatically collect the following information:
Device Information:Browser type, operating system, device model
Log Information:IP address, access time, pages viewed, referral source
Cookies and Similar Technologies:See Section 7 Cookie Policy for details
In accordance with the California Consumer Privacy Act, we may have collected the following categories of personal information in the past 12 months:
Identifiers:Name, email address, phone number, IP address
Commercial Information:Product serial number, purchase information, warranty records
Internet/Electronic Network Activity Information:Website browsing history, access time, page click information


How We Use Information


We strictly use the collected information for the following purposes:

Important Notice: We will not use your personal information for purposes not stated in this policy. If we need to change the purpose, we will seek your prior consent.

Our company focuses on consulting, product development, and customer support. We provide tailored services to businesses across various industries to meet their unique needs, helping them grow and succeed in a competitive market.

Analyze user usage to optimize product features/improve website design and user experience/conduct internal data analysis and statistics;

Prevent fraud, cyberattacks, and other risks/protect the legitimate rights and interests of you and other users;

Product updates, software upgrade notifications/important security announcements/after-sales service follow-up;


Legal Basis for Processing (GDPR Applicable)


For users in the European Union, in accordance with Article 6 of the General Data Protection Regulation (GDPR), we process your personal data based on the following legal bases: Explanation of legitimate interests:

Product Registration and Warranty Service:Based on contract performance (GDPR Article 6(1)(b))
Responding to Technical Inquiries and Support:Based on contract performance or legitimate interests (GDPR Article 6(1)(b) or (f))
Sending Product Updates and Notifications (requires subscription):Based on your consent (GDPR Article 6(1)(a))
Website Security and Fraud Prevention:Based on legitimate interests (GDPR Article 6(1)(f))
Website Analysis and Service Improvement:Based on legitimate interests (GDPR Article 6(1)(f))
Compliance with Legal and Regulatory Requirements:Based on legal obligation (GDPR Article 6(1)(c))

Explanation of Legitimate Interests: When we process data based on "legitimate interests," we ensure that such processing does not unduly affect your rights and freedoms. You have the right to object to our processing on this basis (see Section 8 for your rights).

Information Sharing and Disclosure


We solemnly commit: we will not sell your personal information. We only share your information under the following circumstances:

With your prior written or electronic consent, we will share your information with other parties.

As required by laws, regulations, legal procedures, or judicial or governmental authorities; as needed for litigation or dispute resolution; to protect our legitimate rights, property, safety, or the personal safety of you and other users;

We may entrust authorized partners to process some of your information, but strictly adhere to the following principles: 1. We will sign strict confidentiality agreements with partners; 2. Partners can only access the minimum information necessary to perform their duties; 3. Partners may not use the information for any purpose beyond the scope of the entrustment; 4. We will supervise the processing activities of partners;

 

Data Security Protection


We adopt industry-standard technical and management measures to protect your personal information:

Data encryption at rest; HTTPS/TLS encrypted transmission; Firewalls and intrusion detection systems; Regular security vulnerability scans and penetration tests.

Data access control, strictly following the principle of least privilege; All employees sign confidentiality agreements and receive regular privacy training; Regular data security audits and risk assessments

Establish a comprehensive data security incident emergency response mechanism;

We will conduct a personal information protection impact assessment in advance under the following circumstances: 1. Significant changes in the purpose, method, or scope of processing; 2. Occurrence of a major data security incident; 3. Other circumstances required by laws and regulations;

 

Data Storage and Retention Period


Storage Location

Your personal information is stored on secure servers within the People's Republic of China; we will not transfer your personal information abroad; if cross-border transfer is necessary, we will conduct a security assessment in accordance with the law and obtain your separate consent;



Retention Period

We retain your personal information only for the period necessary to achieve the processing purpose:
Product registration information: retained for 3 years after the warranty period expires, to meet after-sales service and quality traceability requirements.

Technical support consultation records: retained for 2 years, to meet subsequent service follow-up and quality improvement requirements.

Website access logs: retained for 6 months to meet security audit and troubleshooting requirements.

Email subscription information: retained until 30 days after the subscription period ends or unsubscription, to meet subscription management requirements.

Processing after the retention period expires: ** We will perform **secure deletion** or **anonymization** of overdue data to ensure that specific individuals cannot be identified.

Cookie Policy


What is a Cookie

Cookies are small text files that websites store on your device to remember your preferences and improve user experience.

 Types of Cookies We Use

Necessary Cookies:Required to ensure basic website functions, such as session management and form submission.

Functional Cookies:Optional, used to remember your preferences, such as language selection.
 Analytical Cookies:Optional, used to analyze website traffic and improve user experience.

Managing Cookies

You can manage or delete cookies through your browser settings: view stored cookies; delete specific or all cookies; block cookies from certain websites ⚠️ Note: Disabling necessary cookies may affect the normal functioning of some website features.

Your Rights


Under applicable data protection laws, you have the following rights. These rights apply to all users, and specific regions may have additional rights (e.g., Section 9 for California residents).

Right of Access: You can request confirmation of whether we process your personal information and request a copy of it.

Right to Rectification: You can request correction of inaccurate or incomplete personal information.

Right to Erasure: Under certain conditions (e.g., the purpose of processing has been achieved, you withdraw consent, etc.), you can request deletion of your personal information.

Right to Restrict Processing: Under certain conditions (e.g., dispute accuracy, unlawful processing, etc.), you can request restriction of processing of your personal information.

Right to Data Portability: You can request to receive your personal information in a structured, machine-readable format.

Right to Object: You can object at any time to the processing of your personal information based on legitimate interests.

Right Not to Be Subject to Automated Decision-Making: ** We **do not use automated decision-making or profiling technologies, and you will not be subject to decisions based solely on automated processing.

How to Exercise Your Rights

Please contact us through the contact information in Section 14 to exercise your rights. We will respond and process your request within 30 working days of receiving it.

California Consumer Privacy Notice (CCPA Applicable)

This section applies only to residents of the State of California, USA, and is provided under the California Consumer Privacy Act (CCPA).

Notice of No Sale of Personal Information

Pursuant to CCPA Section 1798.120, we hereby declare: 🚫 We do not sell your personal information. We have not sold any consumer's personal information in the past 12 months, and we will not sell it in the future. 

Specific Rights for California Residents

As a California resident, you have the following additional rights granted by the CCPA:
1. Right to Request Disclosure: You have the right to request that we disclose the categories and specific pieces of personal information we have collected, used, or shared about you in the past 12 months.
2. Right to Request Deletion: You have the right to request that we delete your personal information (except as required by law to retain it).
3. Right to Opt-Out: If we sell personal information, you have the right to opt out. However, we do not sell your information, so this right does not apply (1/2)
4. Non-Discrimination Right:
> ✅ Non-Discrimination Statement: We will not treat you differently because you exercise any of your rights under the CCPA. We will not:
> - Deny you goods or services
> - Charge you different prices or rates for goods or services
> - Provide you a different level or quality of goods or services

> - Suggest that you will receive a different price or level of goods or services

Verification Process

To protect your privacy and security, we will verify your identity when processing your CCPA requests, typically by matching the information you provide with the information we have in our records.

Authorized Agent

California residents may authorize a natural person or business entity to act as their "authorized agent" to exercise their CCPA rights on their behalf. The authorized agent must provide written proof of your authorization.

How to Withdraw Consent

For processing based on your consent, you may withdraw your consent at any time, without affecting the lawfulness of processing carried out based on consent before its withdrawal.
You can withdraw consent in the following ways:
Email subscription consent: Click the "unsubscribe" link at the bottom of any subscription email.
Cookie consent: Clear cookies through your browser settings, or modify settings in the website's cookie pop-up.
Other consent: Send an email to support@toogel.cn, specifying the specific consent you wish to withdraw.

Protection of Minors


Our products and services are primarily intended for adults.
If you are a minor under the age of 18, please read this policy with your guardian and use our services only after obtaining their consent.
For minors under the age of 14 (children), we generally do not collect their personal information. If we discover that we have inadvertently collected such information, we will delete it immediately.
If you discover that we may have collected information from a minor without guardian consent, please contact us immediately, and we will verify and handle the matter as soon as possible.

> US Users Note (COPPA): Our services are not directed to children under 13. If you believe we have collected information from a child under 13, please contact us immediately.

Updates to the Privacy Policy


We may update this Privacy Policy from time to time to reflect changes in law, business adjustments, or technological advancements.
Non-material changes: Posted on this page, with the "Last Updated" date updated.
Material changes (e.g., changes in the purpose of information use, expansion of sharing scope, etc.): We will notify you through more prominent means (e.g., website announcement, email notification, in-product notice).

Your continued use of our services constitutes your acceptance of the updated policy. We recommend that you periodically review this page for the latest privacy practices. 

Complaints and Feedback


If you have any questions, complaints, or suggestions regarding our Privacy Policy or data processing, please contact us through the contact information in Section 14.
We commit to:

Responding with the processing result within 30 working days of receiving a complaint. If you are not satisfied with the result, you may request a second review.

For users in the European Union, if you believe our data processing activities violate the GDPR, in addition to contacting us, you have the right to lodge a complaint with the data protection supervisory authority in your member state. You can find the contact information for your country's data protection authority on the European Data Protection Board website (edpb.europa.eu).

 

Contact Us


If you have any questions, comments, or suggestions regarding this Privacy Policy, or need to exercise your rights, please contact us through the following methods:

Guangdong Tugou Technology Co., Ltd.
Registered Address: Building C, No. 3 Fuyuan Road, Butterfly Ridge Industrial Park, Xiantang Town, Dongyuan County, Heyuan City, Guangdong Province
Email: support@toogel.cn
Phone: +86 762 8895 901
Website: www.toogel.cn

Last Updated: July 13, 2026
Effective Date: July 13, 2026