Privacy policy
Last Updated: [01/09/2026]
This Privacy Policy (“Privacy Policy”) explains how NGTECO CO., LIMITED, a company incorporated in the Hong Kong SAR (“we”, “our” or “us”), collects, uses, stores, discloses and otherwise processes Personal Data (as defined below) in connection with your access to and use of https://www.ngteco.com (the “Website”), related purchase and support interactions, and any website features made available through the Website (collectively, the “Services”).
If you use our specific devices or their companion applications, please refer to the privacy policy provided within the individual Device/APP for details on how personal data is collected and processed in connection with those products.
This Privacy Policy applies to users worldwide, with specific sections dedicated to residents of the United States and the European Economic Area (EEA)/United Kingdom. By using our Services, you acknowledge that you have read and understood this Privacy Policy.
Content
1. Collection of Personal Data
2. Personal Data Processing
3. AI Chatbot Service and Data Processing
4. Legal Bases for Processing
5. Disclosure of Personal Data
6. International Transfer of Personal Data
7. Data Retention
8. Protection of Personal Data
9. Cookies and Similar Online Technologies
10. Minor's Privacy
11. Your Privacy Rights
12. Third Party Websites and Applications
13. Changes to this Privacy Policy
14. Contact us
15. Details of Controllers
16. Supplemental Terms – Jurisdiction-Specific
1. Collection of Personal Data
For the purpose of this Privacy Policy, "Personal Data" generally means information or an opinion about an identified individual, or an individual who is reasonably identifiable. Depending on how you interact with our Services, the following data may be collected by or on behalf of NGTECO CO., LIMITED and may constitute Personal Data under applicable laws:
1.1. Personal Data you create or provide to us
We may collect certain information you choose to create or provide to us when you visit or use the Services, including account registration information (such as your name, email address, and encrypted password, and optionally your phone number and address), order and payment-related information (such as your billing and shipping addresses, order contents, delivery method, and transaction amount, while payment card details are processed by payment providers rather than directly by us), and customer-support information you submit through email, phone, product reviews, or chatbot conversations.
|
Browsing |
IP address and geographic location (country/region), device type, browser type, operating system, browsing history, duration of visit, clickstream data, and referral source. |
|
Account |
Name, email address, password (stored in encrypted format); Optional: phone number, and shipping address. |
|
Payments and Purchases |
Name, email address, phone number, shipping and billing addresses, order details, transaction amount, and shipping method. Note: We use third-party processors and do not store full credit card numbers. |
| Contact Information | Name, email address, telephone number, shipping address, billing address and postal code. |
| Customer Support and After-sales Information | When you contact us for support or after-sales service, we may collect: email address, support messages, device information, diagnostic logs. |
1.2. Personal Data collected automatically
1.2.1. Technical Data: IP address and country or region-level location, device type, browser type, and operating system.
1.2.2. Usage Data: page views, browsing history, duration of visit, clickstream data, referral source, and similar interaction data collected through cookies, session storage, local storage, and related technologies used on the Website.
1.2.3. Log Data: checkout session information, error logs, system diagnostics, and security events.
1.3. Personal Data from third-party sources
1.3.1. We may receive Personal Data about you from third parties, including vendors and service providers who assist us in providing our Services, such as Shopify, payment processors, logistics providers, analytics and advertising providers, review-management tools, loyalty or marketing tools, and other website plug-ins we enable from time to time. This may include transaction status information, shipping or delivery updates, review-related information, and Website activity data collected through cookies and similar tracking technologies.
1.3.2. Any Personal Data we receive from third parties will be handled in accordance with this Privacy Policy and we will only use it for the purposes described below or as otherwise permitted or required by law.
1.3.3. The data we receive from these third-party services depends on the features you use, the tools enabled on the Website, and where applicable your settings or interactions with those third parties.
1.3.4. You may interact with a link to or from a third party or a social media feature. If you follow a link to any of these websites, note that your interactions with these companies are governed by their privacy policy, not ours. We recommend that you review the policies and terms of use of any third party before you submit any information to those websites.
1.4.1. For the purpose of this Privacy Policy, "Sensitive Information" is a subset of Personal Data and includes categories such as health information.
1.4.2. We do not seek to collect Sensitive Information. Please do not provide sensitive information unless we specifically request it and it is reasonably necessary for a particular purpose. If we do collect sensitive information, we will handle it in accordance with applicable law.
2.1. We may use your Personal Data for the following purposes:
2.1.1. Provide Services: To sell and deliver our products, process payments, manage orders, arrange shipping, facilitate returns or exchanges, provide product reviews and related account functions, and otherwise perform our contract with you.
2.1.2. Account Administration and Communications: Managing customer accounts, providing service communications, and administering optional newsletter or marketing subscriptions where you choose to sign up.
2.1.3. Improvement: Analyzing system performance, fixing bugs, and developing new features.
2.1.4. Customer Support: To respond to enquiries, provide troubleshooting and product support, manage warranty claims, arrange repairs or replacements, and communicate with you about your requests.
2.1.5. Security, fraud prevention and legal compliance: To protect our Website, systems, and users, detect and prevent fraud or misuse, enforce our terms and policies, and comply with applicable laws and regulatory requirements.
3. AI Chatbot Service and Data Processing
3.1. Where you use our AI chatbot, we may process the text of your conversations, any device or product details you choose to provide in the chat, and the related session ID to respond to your request, maintain context, route issues to human support where needed, and improve our customer-support experience. Based on the information currently provided to us, chatbot conversation data is stored in Amazon Web Services (AWS) in the United States, transmitted over HTTPS using TLS, not shared with third-party AI model providers for their own training, and currently accessible only to authorized AI development personnel, with additional access to customer-support personnel to be enabled only where authorized in the future.
4.1. The legal bases on which we rely for the processing of Personal Data , are as follows:
4.1.1. Perform our contractual services or prior to entering into a contract with you: If you order products or services from us or if you contact us to request our products or services, we use your Personal Data to provide you with these products or services, including for account and contract management, to facilitate user benefits and services, including customer support and process payment for our products and services or with information that may be relevant for you to decide on whether you want to order our products and services;
4.1.2. Justified by our legitimate interests: The usage of your Personal Data may also be necessary for our own business interests. For example, we may use some of your Personal Data to update and monitor the services, or diagnose or fix technology problems; help maintain the safety, security and integrity of our property and services, technology assets and business; enforce our terms, resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties; and prevent, investigate or provide notice of fraud or unlawful or criminal activity.
4.1.3. Consent: In some cases, we may ask you to grant us separate consent to use your Personal Data. In this case, you can revoke your consent at any time with effect for the future.
4.1.4. Compliance with legal obligations: We are obligated to collect or retain certain Personal Data because of legal requirements, for example, tax or commercial laws, or we may be required by law enforcement to provide Personal Data on request.
5. Disclosure of Personal Data
5.1. We may disclose your Personal Data with the following categories of recipients where necessary to operate our business, provide our products and services, and comply with applicable laws.
5.1.1. Our affiliates: We may share your Personal Data with our related bodies corporate (if any) and other entities within our corporate group (“Affiliates”) for business operations, customer support, internal reporting, and to provide and improve our products and services.
5.1.2. Service providers and vendors: We may disclose Personal Data to third-party service providers who perform services on our behalf, such as:
(i) Website hosting and IT service providers;
(ii) Payment service providers;
(iii) Order fulfillment, logistics and delivery providers;
(iv) Customer support and technical support providers;
(v) Marketing, analytics and advertising service providers;
(vi) Professional advisers.
These service providers are authorized to use your Personal Data only as necessary to provide services to us and are required to protect your information in accordance with applicable confidentiality and security obligations.
5.1.3. Additional service providers and business counterparties:
We may share relevant Personal Data with business counterparties, professional advisers, or transaction counterparties where reasonably necessary for order processing, fulfillment, customer support, warranty handling, corporate transactions, or the establishment, exercise, or defense of legal claims.
5.1.4. Business transfers: We may disclose or transfer your Personal Data in connection with a corporate transaction, such as a merger, sale of assets, restructuring, financing, or acquisition of all or part of our business.
5.1.5. Legal and regulatory authorities: We may disclose Personal Data where we reasonably believe such disclosure is necessary to comply with applicable laws, regulations, court orders or legal processes, to respond to lawful requests from government or regulatory authorities, to enforce our terms and policies, to detect, prevent or investigate fraud, security incidents or other unlawful activity, or to protect the rights, property or safety of us, our customers, or others.
6. International Transfer of Personal Data
6.1. Because of the international nature of our business, we transfer Personal Data within the our group, and to third parties as noted in Section (5) above, in connection with the purposes set out in this Privacy Policy. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements than those that apply in the country in which you are located, including the US, the EEA, and the UK.
6.2. In the event of a transfer by us, we ensure that international transfers of your Personal Data are made pursuant to appropriate safeguards, such as:
6.2.1. Ensuring that the Personal Data is only transferred to countries recognized as Adequate Jurisdictions. The current adequacy decisions can be found here. There is currently no adequacy decision for China; and there is only a partial adequacy decision for the U.S., where only such companies that are registered under the Data Privacy Framework are covered by an adequacy decision or
6.2.2. The transfer is made pursuant to appropriate safeguards, such as Standard Contractual Clauses adopted by the European Commission or UK Secretary of State (as applicable) in connection with appropriate supplementary measures. The decision and the template text of these Standard Contractual Clauses can be found here;
6.3. If you wish to enquire further about these safeguards, including the specific contracts entered into, or used, please contact us using the details set out under Section (14) of this Privacy Policy.
6.4. Please note that when you transfer any Personal Data directly to any our entity established outside the UK, Switzerland, or the EEA (as applicable), this is considered a direct collection, to which the safeguards mentioned in this Section may not apply. We will nevertheless Process your Personal Data, from the point at which we receive such data, in accordance with the provisions of this Privacy Policy.
7.1. We take reasonable steps to ensure Personal Data is stored securely.
7.2. We retain your Personal Data only for as long as necessary to fulfill the purposes in this Privacy Policy, including providing the Services, complying with legal and tax obligations, resolving disputes, and enforcing our agreements. Based on the information currently provided to us, Website account, order, and transaction data processed through Shopify is generally retained while the store remains active and may continue to be retained for up to two years after store deactivation unless deleted earlier in accordance with applicable processes. AI chatbot conversation records do not currently have a fixed retention period and may be retained until a formal retention schedule is implemented or deletion is required for business, contractual, or legal reasons.
7.3. In determining how long to retain Personal Data, we consider factors such as:
7.3.1. Whether we have an ongoing relationship with you (for example, if you have an account or have recently purchased products or contacted us);
7.3.2. Whether the information is needed to provide services or manage our business operations;
7.3.3. Whether we are required to retain the information to comply with legal, tax, accounting or regulatory obligations; and
7.3.4. Any applicable limitation periods under law.
7.4. When Personal Data is no longer required, we will take reasonable steps to permanently delete or destroy the relevant Personal Data; or anonymize or de-identify the relevant Personal Data.
8. Protection of Personal Data
8.1. We implement reasonable technical and organisational measures designed to protect Personal Data from misuse, interference and loss, and from unauthorised access, modification or disclosure. Measures may include encryption in transit, access controls, logging and monitoring, staff training and vendor security requirements.
8.2. These measures may include, where appropriate:
8.2.1. Using encryption and other security technologies to protect data during transmission and storage;
8.2.2. Implementing access control mechanisms to restrict access to Personal Data to authorized personnel only;
8.2.3. Applying internal policies and procedures governing the handling of Personal Data; and
8.2.4. Regularly reviewing and improving our security practices.
8.3. While we take reasonable steps to protect your Personal Data, no method of transmission over the internet or electronic storage is completely secure. Accordingly, we cannot guarantee the absolute security of your Personal Data.
8.4. You are responsible for keeping your account credentials confidential and secure. We recommend that you use a strong and unique password, do not share your account details with others, limit access to your devices and browsers, and log out after use, especially on shared or public devices.
8.5. If you have any questions or concerns about the security of your Personal Data, please contact us using the details set out in the "Contact Us" section below.
9. Cookies and Similar Online Technologies
9.1. Cookies are small text files placed on your device when you visit our Website. They help us recognize your browser or device and remember certain information about your visit. Cookies do not usually identify you by name, but they may identify your device or browser.
9.2. Like many websites, we use cookies and similar technologies to help our Website work properly, remember your preferences, understand how our Website is used, and measure and improve our marketing. These technologies may include strictly necessary, functional, analytics, and marketing cookies, as well as session storage, local storage, and similar tools used by Shopify and certain enabled website applications. In limited cases, review invitation emails sent through third-party tools may also contain tracking pixels or similar email technologies.
9.3. We, along with third-party service providers and business partners, may use cookies, tags, scripts, and similar technologies to analyze trends, manage the Website, track your activities on the site, and collect statistical information about our user base. This helps us better understand how our Website is used, learn which sections of our Website you visit, and improve the effectiveness of our advertising and search functions.
9.4. We use cookies to ensure the best performance of our Services and to make it easier for you to access our Services by remembering your device and preferences. Where we provide a cookie banner or cookie settings tool, you can choose whether to accept optional cookies (such as analytics and advertising cookies).
9.5. You may also be able to utilize third-party tools and features to further restrict our use of cookies and similar technologies. For example, cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. In addition, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device or internet browser.
10.1. Our Services are not intended for individuals under 18 years of age, and we do not knowingly collect Personal Data from children.
10.2. If you are under the age of 18, do not meet the minimum age requirements applicable in your place of residence, or are otherwise subject to legal restrictions that limit your ability to use our Platform or services, you must not access or use our Platform or services unless your parent or legal guardian has reviewed this Privacy Policy and has provided consent where required by applicable law.
10.2.1. If we become aware that we have collected Personal Data from a child without valid parental or guardian consent, we will take reasonable steps to delete such information as soon as practicable.
10.2.2. Parents or legal guardians who believe that their child has provided us with Personal Data may contact us using the details set out in Section (14) below.
You may have certain rights in relation to the Personal Data we hold about you. These rights are subject to applicable legal requirements and limited exceptions.
11.1. Right to access: You may request access to the Personal Data that we hold about you. This includes information about the types of Personal Data we collect, how we use it, and to whom it may be disclosed.
11.2. Right to correction: You may request that we correct Personal Data we hold about you if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading.
11.3. Right to request deletion or de-identification: You may request that we delete or de-identify your Personal Data where it is no longer required for a lawful purpose, subject to our legal and regulatory obligations.
11.4. Right to withdraw consent: Where we rely on your consent to process your Personal Data, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal.
11.5. Right to make a complaint: If you believe that we have not handled your Personal Data in accordance with applicable privacy laws, you have the right to lodge a complaint with us.
11.6. How to submit a privacy request: you may submit a request to exercise your privacy rights by contacting us using the contact details set out in the "Contact us" section below. To help us process your request, please provide sufficient information to identify yourself and clearly describe your request. We may need to verify your identity before processing your request.
11.7. Our response to requests: We will respond to your request within 30 days. We may need to verify your identity before processing a request.
12. Third Party Websites and Applications
12.1. Our Website may contain links to third-party websites or services that are not owned or controlled by us (“Third Party Website(s)”). We are not responsible for the privacy practices or the content of Third Party Websites, and this Privacy Policy does not apply to your use of them. We encourage you to review the privacy policy of any Third Party Website you visit.
12.2. To provide you with a better product and service experience, our website may use certain third-party technologies, such as scripts, tags, pixels, plug-ins, or similar tools, provided by authorized third-party partners.
12.3. We conduct appropriate security assessments and monitoring of these third-party technologies to help protect the security of Personal Data. These technologies are primarily used to support core website functionalities, enhance performance, enable analytics, and ensure stable and secure operation of our website.
12.4. We may adjust the types or scope of third-party technologies used on our website from time to time in response to new service requirements or changes in business functions.
13. Changes to this Privacy Policy
13.1. We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors.
13.2. When we update this Privacy Policy, we will revise the "Last Updated" date at the top of this Privacy Policy. Where the changes are material, we will take reasonable steps to notify you in accordance with applicable law. Such notification may include, where appropriate, providing notice by email (where you have provided us with a valid email address), posting a prominent notice on our website or other platforms, or using any other notification method required or permitted by applicable privacy laws.
13.3. We encourage you to review this Privacy Policy periodically to stay informed about how we handle your Personal Data.
Should you have any questions or comments regarding this Privacy Policy, please feel free to contact us at:
14.1. Email: ngtime@ngteco.com
14.2. Tel: US: +1 770 800 2321
15. Details of Controllers
Your Personal Data is controlled by the our Group company located in your region. The following entities are responsible for processing your data:
| Controller entities | Contact Details |
| NGTECO CO.,LIMITED |
ngtime@ngteco.com US: +1 770 800 2321 |
16. Supplemental Terms – Jurisdiction-Specific
16.1.1. The following disclosures supplement the information contained in the main body of our Privacy Policy by providing additional information about our Personal Data processing practices relating to residents of certain U.S. states, including California and other states with applicable privacy laws. For a detailed description of how we collect, use, disclose, and otherwise process Personal Data, please read the main body of our Privacy Policy.
16.1.2. Collection and use of Personal Data
(1) Personal Data.
(A) Personal Data Collected: In the 12-month period preceding the “Last Updated” date of this Privacy Policy, we collected identifiers and contact details (such as name, email address, phone number, shipping and billing address), internet or other electronic network activity information (such as IP address, browser type, device information, cookie and online identifier data, browsing behavior, and shopping cart or order history), commercial information (such as order records and purchase history), and customer-support or chatbot interaction information.
(B) Personal Data Sold or Shared: We do not sell personal information for monetary consideration. However, depending on the cookies, pixels, and similar technologies enabled on the Website and your jurisdiction, certain online identifiers and internet or other electronic network activity information may be disclosed to analytics or advertising partners in a manner that may be treated as “sharing” or targeted advertising under certain U.S. privacy laws.
(C) Personal Data Disclosed for Business Purposes: In the preceding 12 months, we disclosed the categories of personal information described above to service providers and vendors that support the operation of the Website and our business, including e-commerce platform providers, payment processors, logistics and delivery providers, customer-support providers, analytics and advertising providers, and professional advisers.
(A) The following Personal Data elements we collect or otherwise process in connection with our Website, products, or services may be classified as “sensitive” under certain privacy laws (“Sensitive Personal Data”):
(b) Payment card information (collected and processed solely by our third-party payment providers; we do not have access to this data).
(c) We do not intentionally collect precise geolocation data through the Website.
(B) We only use or disclose Sensitive Personal Data where reasonably necessary and proportionate,and where permitted by law, for the purposes of performing services you have requested, verifying and improving the services we provide, detecting security incidents, fraud and other illegal actions, ensuring the physical safety of natural persons, performing services on behalf of the business, or short-term transient use. We only collect and process Sensitive Personal Data without the purpose of inferring characteristics about the relevant individual, and we do not sell Sensitive Personal Data or process or otherwise share Sensitive Personal Data for the purpose of targeted advertising (as further described below).
(C) However, depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, or withdraw your consent for, our processing of Sensitive Personal Data (as described in the Your Additional U.S. Privacy Choices section below).
(3) Deidentified Information: We may at times receive, or process Personal Data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.
16.1.3. Keep Your Information Safe and Secure
(1) All our products are built with strong security features that continuously protect your information. The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you. And if we do detect something risky that we think you should know about, we’ ll notify you and help guide you through steps to stay better protected.
(2) We work hard to protect you and us from unauthorized access, alteration, disclosure, or destruction of information we hold, including:
(A) We use encryption to keep your data private while in transit.
(B) We offer a range of security features,such as password protection and encrypted transmission.
(C) We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems.
(D) We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations.
16.1.4. Personal Data Disclosures, Sales, and Targeted Advertising
(1) We may disclose the categories of Personal Data above to the following categories of third parties: our group entities, processors and vendors, analytics and advertising partners, service providers whose tools are integrated with the Website, counterparties involved in business transactions, individuals you choose to share information with, and certain third parties where you have provided consent or where otherwise required or permitted by law. Please see Section (5) for more detail. We do not transfer Sensitive Personal Data to third parties for purposes unrelated to providing, securing, or improving our services without an appropriate legal basis.
(2) Our disclosure or making available of identifiers, internet or other electronic network activity information, and similar data to analytics or advertising partners through cookies, pixels, and related technologies may qualify as the “sharing” or processing of personal information for targeted advertising or cross-context behavioral advertising under certain U.S. privacy laws.
(3) Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of Personal Data or the processing of Personal Data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below).
(4) Please note we do not sell the Personal Data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes. In addition, we do not sell Sensitive Personal Data, and we do not process or otherwise share Sensitive Personal Data for the purpose of targeted advertising.
16.1.5. Automated Decision-Making and Profiling
We do not conduct automated processing of Personal Data for the purposes of evaluating, analyzing, or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide a right to exercise control over such forms of automated decision-making and profiling.
16.1.6. Your Additional U.S. Privacy Choices
(1) Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
(A) Right to Know: the right to confirm whether we are processing Personal Data about you and, under California and Oregon law only, to obtain certain personalized details about the Personal Data we have collected about you, including:
(a) The categories of Personal Data collected;
(b) The categories of sources of the Personal Data
(c) The purposes for which the Personal Data were collected;
(d) The categories of Personal Data disclosed to third parties (if any), and the categories of recipients to whom this Personal Data were disclosed (or a list of the specific third parties to whom Personal Data have been disclosed);
(e) The categories of Personal Data shared for targeted advertising purposes (if any), and the categories of recipients to whom the Personal Data were disclosed for these purposes; and
(f) The categories of Personal Data sold (if any) and the categories of third parties to whom the Personal Data were sold.
(B) Right to Access & Portability: the right to obtain access to the Personal Data we have collected about you and, where required by law, the right to obtain a copy of the Personal Data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
(C) Right to Correction: the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data.
(D) Right to Control Over Sensitive Personal Data: the right to exercise control over our collection and processing of certain Sensitive Personal Data.
(E) Right to Opt-Out of Targeted Advertising: the right to direct us not to use or share Personal Data for certain targeted advertising purposes.
(F) Right to Opt-Out of Sales: the right to direct us not to sell Personal Data to third parties.
(G) Right to Deletion: the right to have us delete Personal Data we maintain about you (subject to certain exceptions).
(2) Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
(3) Submitting Privacy Rights Requests
To exercise your privacy rights, please follow the procedures below:
(A) Submission Methods: You may submit a request by emailing us at ngtime@ngteco.com or, where available, by contacting us through the customer-support channels identified on the Website, including chatbot or telephone channels.
(B) Opt-Out of Tracking: To opt-out of the "sale" or "sharing" of personal data via cookies for targeted advertising, please click the “Cookie Settings” or “Do Not Sell or Share My Personal Information” link in our website footer and adjust your preferences.
(C) Identity Verification: Before processing your request, we may need to verify your identity. We will typically do this by matching the information you provide with the information we maintain in our records. Where necessary, we may ask you to provide additional information that is reasonable and necessary for verification purposes. We will not ask you to provide information that is unrelated to your request or clearly excessive.
(D) Required Information: All requests must include the requester’s full name, email address, their relationship with us, and the specific right they wish to exercise.
(E) Response Timeline: We aim to respond to your request within 30 days, although a longer period may apply where permitted by law and reasonably necessary in light of the complexity of the request.
(4) Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
(5) Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request.
