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Last update: 11/01/2024
“Clorts”, “clorts.us”, “Xiamen Zongsen Trading Co., Ltd.” or “we” refers to Xiamen Zongsen Trading Co., Ltd., having its registered office at Room 407-1, No. 763 Canghong Road, Haicang District, Xiamen City, China (this address is only for receiving legal documents of commercial entities), registered under Unified Social Credit Code 913502053030303035. Xiamen Zongsen Trading Co., Ltd. is authorized by the Clorts brand to operate its online operations.
Xiamen Zongsen Trading Co., Ltd. is committed to protecting your privacy and complying with applicable data protection and privacy laws. This Privacy Policy (“Policy”) is designed to help you understand what kind of information we collect in connection with our products and services and how we process and use such information. Throughout this Policy, the term “personal data” means information relating to an identified or identifiable individual (i.e., a natural person).
This Policy applies to personal data collected in connection with products and services offered by Xiamen Zongsen Trading Co., Ltd. or in all other cases where we refer to this Policy. This Policy applies to the sale of our products, on our website and applications, in our product testing community, and for any other type of services offered by Xiamen Zongsen Trading Co., Ltd. (typically in electronic form), as well as for customer service, customer events, or sales and marketing campaigns.
We typically provide additional privacy-related terms in connection with a particular product or service. Such product or service-specific terms prevail over this Policy to the extent of any conflict. Our products or services may also contain links to other companies’ websites and other third-party services that have privacy policies of their own. We recommend that you carefully read the privacy policies of such services. Xiamen Zongsen Trading Co., Ltd. is not responsible for the privacy practices or contents of any such third-party services.
Where a consent from you to the processing of personal data described in this Policy is required under the applicable law, such consent will be obtained by appropriate mechanisms such as ticking a box stating your consent, choosing technical settings for a service or website, or other statement or conduct clearly indicating your acceptance to the processing, depending on the product, website, service, or application you are using.
DATA COLLECTED
We collect your personal data typically when you purchase our products or services, use or register into our services, enter into a sales promotion or a campaign, or otherwise interact with us. Below are examples of the categories of the data we collect on you.
Technical Information
For the most part, you may visit our websites or use our products or services without having to identify yourself. However, certain technical information is normally collected as a standard part of your use of our services. Such information includes, for example, your IP address, access times, the website you linked from, pages you visit, the links you use, the ad banners and other content you viewed, information about your devices, and other such technical information your browser provides us with or as may be otherwise collected in connection with certain products and services. When you use our services or otherwise interact with us over telecommunications networks, certain additional information, such as your mobile subscription number, may be transmitted to us by the telecommunications operator as a standard part of that communication. Please also see our Cookie Policy.
Information You Provide Us
When you register to our services, product testing, or membership program, make a purchase, enter a sales promotion, or otherwise interact with us, we may ask you to provide us with certain information such as your name, email address, street address, as well as usernames, passwords, and other such credentials that are used to authenticate users and to validate their actions or that may be needed to provide you with the products and services you have requested or to communicate with you, as well as information uploaded by you such as location, route information, pictures, etc. We may collect training data, demographic information—for example, your age, gender, postal code, and language preferences.
We may also collect other information you provide, such as your consents, preferences, and feedback, information relating to your devices, and other such information you provide us with. Please note that certain non-identifiable information collected from you may become personally identifiable when you provide us with your personal data. Some of our services may allow you to submit information about other people, for example, if you make an order for a product that you wish us to send directly to another recipient.
Special Categories of Personal Data
We may collect your biometric and health-related data such as blood pressure, heart rate, footprints, or similar depending on the product testing program you have joined or service you used. Users are requested to grant consent for such data collection explicitly per each service or product in question. For certain services, this may be done by adjusting the settings of the application or service.
Your Transactions with Us
We collect or request information relating to your purchase or use of our products or services as well as your other interactions with us. Such information may include, for example, details of the queries or requests you have made, the products and services provided (including delivery details), purchasing details (including payments made, credit card details, billing address, credit checks, and other such financial information), details of agreements between you and Xiamen Zongsen Trading Co., Ltd., records of contacts and communications, information and details relating to the content you have provided us with, and other such transactional information. We may, in accordance with applicable law, record your communication with our customer care or with other similar contact points.
Location Data
Certain services may involve the use of your location data. Use of your location data is, however, subject to your prior consent for each service.
Data Obtained from Third Parties or via Third-Party Platforms
In addition to the personal data we obtain from you, we may obtain, in accordance with applicable laws, certain personal data from online advertising, list rental companies, and other publicly available sources. This may include personal data such as credit information and address information updates.
When cookies or other equivalent technologies have been enabled on our websites or services, we and/or the third party operating such cookie or other equivalent technology may collect certain personal data of you. This may include data such as HTTP header information (IP address, browser information, page storage location, website URL, date and time), cookie-specific data (cookie IDs, cookie data, social media IDs), as well as other website/service visit-related data (data events, orders placed, registrations, products searched). More information on cookies and equivalent technologies we use can be found in our Cookie Policy.
When you interact with us or content through social media, we receive information from your interaction with our content (e.g., content viewed and information about advertisements you have been shown or have clicked on). By interacting with our sites through social media, you consent to our use of data from the social media in accordance with this privacy notice. When we maintain sites (so-called “fan sites”) on social media platforms such as Facebook or Instagram, the social media platform operators collect personal data on persons visiting these sites via cookies and process such data as data controllers.
THE PURPOSES OF PROCESSING
Xiamen Zongsen Trading Co., Ltd. processes your personal data for the purposes described in this Policy and/or any additional service-specific privacy information. Please note that one or more purposes may apply simultaneously.
| Purposes | Our Legal Basis |
| Providing you with the product or service you have requested, fulfilling your other requests such as customer service, processing your order, or otherwise performing the contract you have with us | Fulfilling contractual obligations |
| Creating and administering your membership account | Fulfilling contractual obligations |
| Accounting, tax, and bank management: issuing invoices, cashing, and accounting | Meeting our legal obligations |
| Preventing and detecting fraud or other misuses | Meeting our legal obligations (e.g., Know-Your-Customer requirements and export restrictions) and our legitimate interest (in fighting fraud) |
| Communicating with you: | |
| Your consent |
| Our legitimate interest (in communicating important information and responding to your inquiries) |
| Our legitimate interest (in informing users about the features of our products and services) |
| Recording of conversations to improve customer service, train our staff during telephone contacts with our customer service | Our legitimate interest (in improving services and training staff) |
Legal compliance. We use the information we collect to identify, investigate, and prevent activities that may violate our terms and conditions or otherwise be illegal. Following the above, we will use data in connection with legal claims, compliance, regulatory, and investigative purposes as necessary, including disclosure of such information in connection with legal process or litigation. | Meeting our legal obligations and our legitimate interest (in protecting our assets and other compliance interests) |
| Whistleblowing. We may use certain personal data in order to process and investigate a notification we receive via our website whistleblowing channels. | Meeting our legal obligations |
| Marketing. We may process your personal data for sending marketing messages and emails as well as newsletters concerning our offerings, if you have subscribed to such messages or consented to receiving them. | Your consent |
| Profiling/personalization. We may process and use your personal data for profiling/personalization for such purposes as targeted direct marketing. We may also create aggregate and statistical information based on your personal data. Profiling/personalization includes automated processing of your personal data for evaluating, analyzing, or predicting your personal preferences or interests to, for example, send you marketing messages concerning products or services best suitable for you. | Your consent |
| Third-party advertisement services. We use third-party advertising platforms, such as Facebook or Google, to display to you and other individuals that have similar interests personalized promotional and commercial offers. *) | Your consent |
| Carrying out statistical studies, conducting market research based on segments, and other general business analysis. We may process and use your personal data to develop our products and/or services as well as to better understand our customer behavior or preferences. However, we use aggregate and statistical information for these purposes where technically feasible and aim to minimize using data directly identifiable to you. | Our legitimate interest in getting to know you better and improving our services |
| Business improvement, prognosis, and reporting. We use some of the personal data collected from you to help us operate our business through using data to create accurate financial and other reports, making business forecasts, as well as conducting audits or other internal functions. | Our legitimate interest in improving our business and operations |
| Website analytics. To understand the uses made of our website and improve their operation by using cookies and other similar technologies. *) | Your consent |
| Website/content personalization. To offer personalized content and offers on the website that you are likely to be interested in, based on the cookies installed. *) | Your consent |
| Development of our products and services. Allowing you to voluntarily complete questionnaires, surveys, or tests relating to our products and services. | Your consent |
*). For more information, please see our Cookie Policy
TRANSFERS OF YOUR PERSONAL DATA
We may disclose your personal data to third parties solely as stated below in this Policy, or as obligated by mandatory law.
Service Providers and Other Authorized Third Parties
We may transfer your personal data to authorized third parties who process personal data on our behalf for the purposes described in this Policy, such as technical, logistics, e-commerce, marketing, invoicing and payment, and other service providers. Such third parties are not permitted to use your personal data for any other purposes than for what your personal data was collected, and we require them to act consistently with applicable laws and this Policy as well as to use appropriate security measures to protect your personal data. Some of these service providers, such as payment service providers, process your personal data as data controllers and their services are subject to their own privacy policies.
We may also transfer your personal data, including heart rate data, biometric data, or other health-related data, to a service partner if you use such services where a third-party company needs to process such data for the provision of the respective service or where you separately agree that a third-party company may process your data in connection with the services or products of Xiamen Zongsen Trading Co., Ltd.
International Transfers
Our products and services may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred outside the country where you use our services, including to countries outside the European Economic Area (EEA), where the level of data protection may not be deemed adequate by the European Commission. In such cases, we take steps to ensure to the best of our capabilities that protection for your personal data is provided as required by applicable laws. For international transfers of your personal data, we generally rely on the Standard Contractual Clauses (“SCCs”) of the European Commission. If you wish to know more about international transfers of your personal data, you may contact us via the contact details given below.
Where the international transfers are linked to the use of non-essential cookies or other equivalent technologies, they will only be enabled if you consent to their use via our cookie banner or cookie settings. If you do not consent to the use of such cookies or other equivalent technologies, they will not transfer your data either. See our Cookie Policy for further information.
Mergers, Acquisitions, Business Transactions, and Transfers
We may disclose and/or transfer your personal data to third parties, such as potential or existing purchasers and their advisors, in connection with mergers, acquisitions, sales, reorganizations, divestments, or any other transactions or transfers or changes of control involving Xiamen Zongsen Trading Co., Ltd. and/or its group companies, services, applications, digital services, or businesses. We may also receive personal data from such third parties, such as vendors and their advisors, for the purposes of such transactions.
Other Disclosures
We may disclose and otherwise process your personal data in accordance with applicable laws to defend Xiamen Zongsen Trading Co., Ltd.’s legitimate interests, for example, in civil or criminal legal proceedings. Your personal data may be shared with government authorities, regulators, and/or law enforcement officials if required for the purposes above, if mandated by law.
DATA CONCERNING MINORS
Xiamen Zongsen Trading Co., Ltd. does not seek to collect any information from or engage in any transactions with persons under the legal age in their respective country. Our databases may nevertheless contain personal data of children due to the fact that it is not always possible to determine precisely the age of the user. We reserve the right to block the service from any person who is or whom we reasonably suspect of being a minor.
Xiamen Zongsen Trading Co., Ltd.’s policy is to request that minors do not make purchases or engage in other legal acts on our products and services without the consent of a parent or legal guardian, unless otherwise permitted by applicable law. If you are a minor but have your legal guardian’s consent, you must be able to prove that such consent exists upon request.
DATA QUALITY AND RETENTION
We take reasonable steps to keep the personal data we possess accurate and up-to-date and to delete out-of-date or otherwise incorrect or unnecessary personal data.
Some of our products and services may allow you to manage your profile and the information in such profile. We encourage you to access your personal data via your profile from time to time to ensure that it is correct and up-to-date. Please remember that for such electronic services where you may manage your profile, it is your responsibility to provide us with correct details as well as to update the personal data you have provided us with in case of any changes.
We store your personal data only for a period necessary for the purpose in question or as long as required by applicable laws. After the personal data is no longer needed or required to be stored under applicable laws, it will be deleted or permanently anonymized. Below are some examples of retention periods that apply to your data:
- The user’s registration data will be kept until your account is deleted or within two (2) years in case of inactivity and after informing the user of the deletion.
- Personal data related to orders, deliveries, after-sales service is retained for as long as needed to perform sales/delivery contract in question, and for five (5) years thereafter for validation purposes.
- Personal data included in our financial documents and accounting records is retained for ten (10) years from the end of the accounting period in question as accounting proof.
- Personal data processed for marketing purposes is retained until you unsubscribe from our marketing messages/newsletters or otherwise ask us to stop and in any case for a maximum of three (3) years from the end of the contractual relationship for customers or for three (3) years from the data collection or last contact for prospective customers. We also keep a proof of your request not to send you direct marketing for three (3) years to respect your request in the future.
- Records of phone conversations with our customer service are destroyed one (1) month after the call was made.
In all of the cases above, we may retain the data longer than the stated retention periods if we have a legal reason (e.g., product liability or dispute) to retain the data for longer.
DATA SECURITY
We take data security seriously in all of our data processing. We implement appropriate technical and organizational security measures to prevent and minimize risks associated with providing and processing personal data.
Such security measures include, where appropriate, the use of firewalls, secure server facilities, encryption, implementing proper access rights management systems and processes, careful selection of processors, sufficient training of our personnel involved in the processing, and other necessary measures to provide appropriate protection for your personal data against unauthorized use or disclosure. Where appropriate, we also take backup copies and use other such means to prevent accidental loss or destruction of your personal data. If a particular part of a Xiamen Zongsen Trading Co., Ltd. website supports online transactions, we will use an industry-standard security measure, such as the one available through “Secure Sockets Layer” (“SSL”), to protect the confidentiality and security of online transactions.
YOUR RIGHTS
Applicable data privacy laws guarantee several rights to you in relation to your personal data being processed by us. Xiamen Zongsen Trading Co., Ltd. ensures that you can make use of these rights at all times. You have the following rights:
- You have the right to request information and access to the personal data we have collected from and of you.
- You also have the right to request that we replenish, rectify, or delete any incomplete, incorrect, unnecessary, or outdated personal data we hold on you. However, we cannot delete such personal data that is necessary for compliance with binding legal obligations or if the personal data must be retained according to applicable laws.
- You have the right to request and receive the personal data we have collected on you for performance of a contract or with your consent in a commonly used and machine-readable form.
- You may request restriction of processing of your personal data if you do not wish your personal data to be deleted, but the processing of your personal data has been deemed unlawful or the personal data is no longer necessary, or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration.
- You may at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Further, where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.
If you wish to make use of your rights mentioned above, you may do so by contacting us through the contact point referred to below in this Policy. When you contact us, please state the reason why you are contacting us (e.g., you wish to request a copy of your data, object to processing, update your data) and information that will help us to identify you. We may also request additional information from you in order to properly identify you so we can fulfill your request.
We encourage you to use available profile management tools for the above purposes as such tools often provide you with direct access to your personal data and allow you to effectively manage it. Please also note that applicable law may contain additional restrictions and other provisions that relate to your above rights.
Complaints to Supervisory Authorities
In the event you consider our processing activities of your personal data to be inconsistent with the applicable data protection laws or that we have not sufficiently ensured the realization of your rights, you may lodge a complaint with the local supervisory authority responsible for data protection matters. The up-to-date contact details of the supervisory authorities in the EU countries can be found here.
Opting Out from Email/Online Ads/SMS-Based Marketing
You may opt out from brand marketing emails and online ads by following the guidance in those emails (typically provided via an “unsubscribe” link) or by contacting Xiamen Zongsen Trading Co., Ltd. as set forth in the email and on our website.
If you opt out, (i) we may still send you non-marketing emails, such as service notifications or other information, or if you are a business customer, we may send business relation information; (ii) you will still see advertisements on third-party advertising platforms at random. You may also opt out from any SMS-based direct marketing by contacting Xiamen Zongsen Trading Co., Ltd. as set forth on our site or via SMS as may be applicable.
CONTACT DETAILS OF THE DATA CONTROLLER
The main data controller responsible for processing your personal data according to this Policy is:
- Xiamen Zongsen Trading Co., Ltd., Room 407-1, No. 763 Canghong Road, Haicang District, Xiamen City, China (this address is only for receiving legal documents of commercial entities)
You may contact us via our contact page at https://clorts.us/contact-us/ or via phone at 185 5969 1319.
As stated in the beginning of this Policy, Xiamen Zongsen Trading Co., Ltd. is authorized by the Clorts brand to operate its online operations.
CHANGES TO THIS PRIVACY POLICY
We may from time to time update and change this Policy. If the changes include new purposes of processing, we will give you prior notice of such changes and, where necessary, request your consent for such additional purposes. The last update date of this Policy is stated at the beginning of the document.
COUNTRY-SPECIFIC TERMS
Xiamen Zongsen Trading Co., Ltd. operates in some countries where local legislation guarantees you additional rights in relation to your personal data being processed. When we process your personal data in these countries or are otherwise subject to such country’s privacy legislation, we ensure that your rights are followed. We have listed below the relevant applicable additional rights per country.
France
You have a right to define guidelines relating to the fate of your personal data in the event of your death.
California, United States of America
[The California-specific privacy rights section remains unchanged unless specified.]