1. Introduction
This Privacy Notice applies to all visitors located in the European Economic Area (EEA) accessing our corporate website for product display and inquiry. ShenZhen Nowgre IOT Technology Co., Ltd. (hereinafter “we”, “us”, “our”) is the Data Controller under Regulation (EU) 2016/679 (GDPR). This notice explains how we collect, use, store, transfer and protect your personal data when you browse our website, view our products and submit inquiries via our contact form. It also sets out your statutory rights under GDPR.
Controller Information
- Company Name: ShenZhen Nowgre IOT Technology Co., Ltd.
- Registered Address: Room 6H-073, Phase II, South China International Leather & Leather Goods Raw & Auxiliary Materials Logistics Park, Hehua Community, Pinghu Subdistrict, Longgang District, Shenzhen City.
- Privacy Contact Email: sznowgre@163.com
- Contact Phone: +86 13168082107
- EU Representative (if applicable): PROCONSEIL FR, 200 rue de la Croix Nivert, 75015, Paris, France. SophieDupont@proconseilfr.com
- Data Protection Officer (DPO): Not required for our processing activities.
2. Personal Data We Collect
We collect personal data in two scenarios:
- Data you voluntarily submit via contact / inquiry form
- Identity data: your full name, company name, job title
- Contact data: email address, telephone number
- Inquiry content: product interest, message you send to us
- Automatically collected technical data during website browsing
- IP address, browser type, device model, operating system
- Website access timestamp, visited pages, referral source, cookie identifiers (see separate Cookie Notice)
We do not intentionally collect special category personal data (race, religion, health, biometrics etc.). You are not obliged to provide personal data; if you refuse, you may still browse product pages but cannot send inquiries to us.
3. Purposes of Processing & Legal Basis (GDPR Art.6)
- Legitimate Interest (Art.6(1)(f)) – Website browsing & security: process technical browsing data to maintain website stability, prevent cyber attacks, analyse visitor traffic to improve product presentation. We have completed a legitimate interest balancing test.
- Consent (Art.6(1)(a)) – Respond to your inquiry: when you submit the contact form, you consent to us processing your submitted data to reply to your product enquiry, provide product information, quotations and technical support. You may withdraw consent at any time.
- Legitimate Interest (Art.6(1)(f)) – Business communication: follow-up communication regarding your product inquiry.
- Legal Obligation (Art.6(1)(c)): retain records to comply with applicable commercial, tax and legal requirements.
We will NOT use your inquiry data for unsolicited marketing emails unless you explicitly opt-in.
4. Recipients of Personal Data
We may share your personal data only with the following limited categories of third parties when necessary:
- Website hosting / cloud service providers
- IT technical maintenance vendors
- Email service providers for replying to inquiries
- Professional service providers (accounting, legal)
- Competent public authorities, only if required by EU law or court order
All third-party data processors sign GDPR Data Processing Agreements (DPA). They may only process data under our instructions. We will never sell, rent or trade your personal data to third parties for marketing purposes.
5. International Data Transfers
Your personal data may be transferred and processed outside the EEA, in Singapore. For transfers to non-adequacy countries, we adopt the Standard Contractual Clauses (SCCs) approved by the European Commission to safeguard your personal data. You may request a copy of the SCCs via our privacy contact email.
6. Data Retention Period
We retain personal data only as long as necessary for the stated purposes:
- Inquiry form data: keep for 3 years after our last communication, unless legal rules require longer retention.
- Website access logs & technical data: 12 months. After expiry, data will be securely deleted or anonymised. Anonymised data is no longer personal data and may be kept for statistical analysis.
7. Your Rights as a Data Subject (GDPR Art.15–22)
You hold the following rights:
- Right of access (Art.15): request a copy of your personal data we hold
- Right to rectification (Art.16): correct inaccurate or incomplete personal data
- Right to erasure / Right to be forgotten (Art.17): request deletion under qualifying conditions
- Right to restriction of processing (Art.18): suspend processing of your personal data
- Right to data portability (Art.20): receive your submitted data in structured machine-readable format
- Right to object (Art.21): object to processing based on legitimate interests
- Right to withdraw consent: withdraw consent any time, without affecting lawful processing before withdrawal
- Right to lodge a complaint: file a complaint with the Data Protection Supervisory Authority in your EEA member state
To exercise your rights, send your request to: sznowgre@163.com. We will respond within one calendar month as required by GDPR.
8. Data Security
We implement appropriate technical and organisational measures to protect your personal data, including encryption, access permission control, regular security scanning, to prevent unauthorised access, loss, alteration or disclosure. Please note that internet transmission cannot guarantee absolute security of data.
9. Minors
Our website and product information are intended for business visitors aged 16 and above. We do not knowingly collect personal data from children under 16. If you find we hold data of minors, please contact us immediately for deletion.
10. Automated Decision-Making & Profiling
We do not carry out automated decision-making or profiling that produces legal or similarly significant effects on you.
11. Changes to this Privacy Notice
We may update this Privacy Notice periodically. Revised version will be published on this page with updated date. Material changes will be notified by website notice.
12. Contact
For privacy questions, data subject requests, please contact us: sznowgre@163.com, Room 6H-073, Phase II, South China International Leather & Leather Goods Raw & Auxiliary Materials Logistics Park, Hehua Community, Pinghu Subdistrict, Longgang District, Shenzhen City.