Beijing Nacae Technology Co., Ltd. (hereinafter referred to as “Nacae” or “we”) operates websites and online platforms within the territory of the People’s Republic of China (collectively, the “Platforms”). We are committed to protecting the confidentiality, integrity, and security of any personal information that you may share with us (“Personal Information”), and to explaining how we collect, use, and disclose such Personal Information.
Nacae processes Personal Information in compliance with applicable privacy and data protection laws and regulations currently in force and as amended from time to time, including but not limited to the Civil Code of the People’s Republic of China, the Personal Information Protection Law of the People’s Republic of China (“PIPL”), and the E-commerce Law of the People’s Republic of China, as well as in accordance with the ethical principles and general rules adopted by Nacae.
This Privacy Policy applies to Personal Information that we may collect through digital platforms, including but not limited to websites, Nacae WeChat Mini Programs, online stores on third-party e-commerce platforms (such as Tmall and JD.com), mobile applications, cloud services, and embedded components within communication platforms (collectively, the “Digital Platforms”), as well as Personal Information collected in other circumstances where this Privacy Policy is displayed or referenced. It also applies to Personal Information that you may provide to us when interacting with our customer service team or technical personnel, purchasing our products, using our services, or participating in our activities via telephone, email, text message, or in person at our offices.
Please read and confirm that you have fully understood this Privacy Policy before using our services or accessing our Digital Platforms. By clicking a confirmation button, checking an authorization option, providing Personal Information in any manner, using our services, or accessing our Digital Platforms, you represent that you are at least 14 years old and that you agree to this Privacy Policy (and any updated versions thereof). If you are under the age of 14, or if you do not agree to any part of this Privacy Policy, you must not use our services or provide Personal Information to us.
This Privacy Policy will help you understand the following:
(1) Types of Personal Information that Nacae may collect and process
(2) Protection of minors’ Personal Information
(3) Methods used by Nacae to collect and process Personal Information
(4) Optionality of providing Personal Information
(5) Purposes and legal bases for collecting and processing Personal Information
(6) How Nacae shares, transfers, or publicly discloses Personal Information
(7) Cross-border transfer of Personal Information
(8) How Nacae protects Personal Information
(9) Retention period
(10) Personal Information processor, data protection personnel, and contact details
(11) Rights of Personal Information subjects
(12) Amendments to this Privacy Policy
1. Types of Personal Information Collected and Processed by Nacae
“Personal Information” refers to any information, recorded electronically or otherwise, relating to an identified or identifiable natural person, or information that reflects the activities of a specific natural person, either independently or in combination with other information.
Depending on the services you choose, activities you participate in, and your interactions with us, the Personal Information we collect may include the following. Sensitive Personal Information is collected only when necessary and will be highlighted to you:
(1) Basic personal and contact information (e.g., name, title, date of birth, address type, region, province, city, postal code, mailing address, mobile phone number, landline number, email address);
(2) Online identifiers (e.g., account ID, IP address, user ID and passwords, WeChat OpenID, WeChat UnionID, and related information);
(3) Audio recordings (e.g., authorized call recordings);
(4) Technical needs and preferences;
(5) Log and browsing information (e.g., search terms, browser type, IP address, access date and time, pages visited, and actions taken);
(6) Purchase records (e.g., order history, items added to favorites or shopping carts);
(7) Device information (e.g., hardware model, operating system);
(8) Location information (collected with your authorization; we do not track your movement across different time periods).
2. Protection of Minors’ Personal Information
Nacae attaches great importance to the protection of the privacy of minors under the age of 14 (“Minors”). We do not intentionally collect or process Personal Information of Minors. Due to technical limitations, we may not always be able to identify a user’s age. Therefore, Minors should not provide any Personal Information (such as name, address, or phone number) without the consent of their legal guardian.
If we become aware that we have collected Personal Information from a Minor without proper guardian consent, we will delete such information upon request by the legal guardian.
3. Methods of Collecting and Processing Personal Information
(1) Information Automatically Collected from You and/or Your Device
When you use our Digital Platforms, we may automatically collect certain information through cookies and similar technologies, including information collected by third parties beyond our direct control.
Such information is generally used to analyze and improve platform performance, conduct statistical analysis, and enhance user experience.
Browsing Data
During normal operation, certain data (log files) are collected by the computer systems and software used to operate our Digital Platforms. These data include IP addresses or domain names, requested URLs, request times, methods used to submit requests, file sizes, server response codes, and system parameters. These data are used solely for anonymous statistical analysis and to ensure proper platform functionality.
Cookies
Our Digital Platforms use cookies and similar technologies to ensure proper operation, perform analytics, improve services, and deliver advertising based on your preferences. Cookies are small text files stored on your device. For more information, please refer to our Cookie Policy.
(2) Personal Information Provided Directly by You
We may collect Personal Information that you voluntarily provide in the following circumstances: placing orders; registering for events; making appointments or in-store pickups; registering online accounts; joining customer databases; subscribing to newsletters; contacting customer service; visiting our offices; or using our services or Digital Platforms.
Collected information may include basic personal details, contact and billing information, appointment details, purchase records, and other information you choose to provide.
If you contact our customer service team by telephone, or if our customer service team contacts you using the contact details you have provided, please be aware that such calls may be recorded for purposes of quality assurance, record keeping, and training. You will, in any event, be informed of such recording prior to the commencement of the recording. In addition, when you call, email, or send text messages to our customer service team and/or technical personnel, NACAE will collect the email address and/or telephone number you use to contact us in order to respond to your requests, as well as any other Personal Information contained in your communications or voluntarily provided by you during your interactions with us.
When you visit our office premises, we may also collect images captured by security surveillance systems for the purposes of ensuring safety and preventing crime. Where applicable, we will provide appropriate notices at or near the areas under video surveillance.
Furthermore, we may obtain your Personal Information for identity verification or authentication purposes (for example, when you collect products at our office premises, we may require you to present identification documents). NACAE uses such information to verify your customer identity, process your orders, deliver products and services, and/or process payments.
When you follow our official WeChat public account or use our WeChat Mini Programs, we may obtain your WeChat nickname and profile photo, as well as other information recorded in your WeChat account that you have agreed to share with us.
We may combine Personal Information that you provide or that we lawfully collect through various channels, including but not limited to social media platforms, online platforms, and offline office premises, in order to better understand your preferences and habits and to enhance and optimize the customer experience we provide to you.
4. Optional Nature of Providing Personal Information
The provision of Personal Information is optional. However, if you wish to order products, create a personal account, register in the NACAE customer database, and/or use any other services provided online, remotely, or at our physical office premises, you are required to complete all mandatory fields in the relevant forms and provide the Personal Information necessary for the purposes for which such information is processed.
If you do not provide such information, this may delay or prevent us from processing your requests, responding to your inquiries, or providing products or services.
You are free to choose whether to create a personal account on our platforms and whether to consent to the collection, processing, and use of your Personal Information by NACAE for the purposes set out in Sections 5(f), (g), and (h) below. If you do not consent, you may still make purchases; however, we will not be able to carry out the stated purposes, including but not limited to notifying you of activities you may be interested in and/or sending you other commercial communications regarding NACAE’s products, services, events, and projects. In addition, you will not be able to access certain exclusive features reserved for registered members that may enhance your service experience with NACAE.
Please note that if you consent to the processing of your Personal Information for the purposes set out in Sections 5(f), (g), and (h), once you are registered in the NACAE customer database, in order to provide you with a consistent level of service worldwide wherever you choose to interact with NACAE (for example, when you travel and purchase our products or visit our office premises), Personal Information relating to your customer profile will be securely accessible to and shared among all NACAE affiliated entities.
You may click here to view NACAE’s affiliated companies and the regions in which we operate. NACAE will implement appropriate security and confidentiality measures as required by applicable laws to ensure that information protection standards are met.
Subject to the relevant provisions of this Policy, you may withdraw or modify your consent to the processing of your Personal Information at any time by contacting the Personal Information processor at the address set out in Section 10, logging into your account, using the “unsubscribe” link included in all of our commercial electronic communications, or using any other appropriate mechanism made available by NACAE.
Please also note that, unless you delete your Personal Information or withdraw the consent you have granted to NACAE in respect of your Personal Information, you shall be deemed to have authorized NACAE to process all Personal Information you provided during your period as a registered NACAE customer. Upon cancellation of your account, the relevant Personal Information will be deleted or anonymized after we have fulfilled any obligations arising from you or from applicable legal requirements.
5. Purposes and Legal Basis for the Collection and Processing of Personal Information
Your Personal Information may be collected and processed for the following purposes:
a) To fulfill your orders and carry out all related administrative activities (including contract administration, provision of services or delivery of products, payment processing, handling of returns and exchanges, management of claims and litigation, and fraud prevention), and to comply with applicable legal or regulatory obligations.
(For these purposes, you are required to provide the purchaser’s mobile phone number, the recipient’s name, mobile phone number, and delivery address (including province, city, and district). For the purpose of issuing electronic invoices (where applicable), you are required to provide the invoice recipient’s email address and may also be required to provide the company name and taxpayer identification number.)
b) To provide after-sales services (including product warranty and repair services) and other services or information you request, to communicate with you, and to manage your customer relationship with NACAE.
(For these purposes, we will collect the Personal Information contained in your requests, as well as any additional details you may choose to provide during your interactions with our customer service or sales personnel, in order to deliver services relevant to you or your needs.)
c) After you have subscribed to the relevant services, to send newsletters, updates, and marketing communications relating to NACAE’s products, services, events, and special projects, including communicating such information with you by telephone.
(For these purposes, you are only required to provide a mobile phone number or email address, as applicable.)
d) In order to provide you with more convenient and personalized products and services and to improve your service experience, we will, based on your browsing, clicking, adding to cart, adding to favorites, purchasing, and other behavioral records, combine lawfully collected online identifier information and other information authorized by you, and use algorithmic models to predict your interests or preferences and provide personalized content that may be of interest to you. We will also adjust and optimize recommendation results based on your behavior while using relevant digital platforms.
(For these purposes, we will collect your WeChat OpenID, UnionID, and records of browsing, clicking, items added to cart, items added to favorites, and purchases.)
e) To enable you to register as a store member and enjoy related benefits on specific digital platforms (such as Tmall and JD.com).
(For these purposes, we require your mobile phone number and/or platform account information.)
In addition, if you choose to consent to joining the NACAE customer database and agree to the processing of your Personal Information, your Personal Information may also be processed and used, together with details of your online and/or in-store purchases, for the following purposes:
f) To manage your NACAE personal account, verify your identity as a registered NACAE customer, and on this basis provide global customer services and after-sales services, while enabling you to enjoy exclusive services and benefits reserved for registered members (such as saving order history, global customer support and personalized assistance, simplified product repair and warranty procedures, event invitations, pre-sales, and other promotional activities).
g) To provide personalized services and customized experiences based on your preferences regarding NACAE’s products and services, including conducting individual or group research, surveys, data analysis, and related market research.
h) Marketing: To contact and/or send you (by telephone, email, and any other form of electronic communication or digital means, including social networking platforms and other instant messaging applications) information and promotions relating to NACAE’s products and services, including commercial communications, advertisements, and product catalogs.
For the purposes set out in Sections (f), (g), and (h) above, you are required to provide the following information: name, title, location, and mobile phone number. To help us provide you with better services and experiences, you may also choose to provide additional information such as your date of birth (however, failure to provide such additional information will not affect the basic functionality of the services).
We collect and process your Personal Information based on one or more legal bases provided under applicable data protection laws, including but not limited to:
where processing is necessary for matters relating to any contract between you and NACAE (for example, when you purchase products or request repair services), or is necessary to take steps at your request prior to entering into a contract;
where we have obtained your prior consent, which you have the right to withdraw at any time in accordance with this Policy;
where processing is necessary for compliance with applicable laws and regulations.
If NACAE intends to use your Personal Information for purposes not covered by this Privacy Policy, or to use information collected for a specific purpose for another purpose, we will obtain your explicit consent in advance.
You fully acknowledge that NACAE is not required to obtain your consent for the collection, processing, and use of Personal Information in the following circumstances:
where processing is necessary for the conclusion or performance of a contract to which you are a party;
where processing is necessary for the performance of statutory duties or legal obligations;
where processing relates to national security or national defense;
where processing relates to public security, public health, or重大 public interests;
where processing relates to criminal investigation, prosecution, trial, and enforcement of judgments;
where processing is necessary to protect the life, property, or other significant interests of the Personal Information subject or other individuals and it is difficult to obtain consent;
where the Personal Information has been disclosed by the Personal Information subject;
where the Personal Information is collected from lawfully disclosed information, such as lawful news reports or government disclosures;
where processing is necessary for lawful news reporting;
or other circumstances as provided by laws and regulations.
6. How NACAE Shares, Transfers and Publicly Discloses Your Personal Information
Your personal information will never be disclosed to unknown individuals under any circumstances.
Entrusted Processing
Where necessary and/or helpful for achieving the purposes described above, NACAE may entrust the processing of personal information to external service providers. When outsourcing such processing, we will enter into relevant agreements with the service providers, clearly requiring them to strictly comply with our personal information protection requirements and prohibiting them from unlawfully providing personal information to any third party.
Service providers shall not use personal information for any purpose beyond the scope of the entrusted services.
The entrusted services may include, without limitation:
SMS service providers;
Software and system technical service providers;
Risk control service providers;
Online survey institutions;
Marketing, research and data analytics companies;
Website/system server hosting service providers.
Sharing
In addition, in order to achieve the purposes set out in this Privacy Policy, NACAE may share your personal information with third parties under the following specific circumstances:
Order fulfillment:
(i) We may share your order number and transaction amount with Alipay, WeChat Pay or other third-party payment institutions so that they can confirm your payment instructions and complete the payment; and
(ii) We may share recipient information with courier service providers who deliver your orders, so that logistics and delivery services can be completed.
NACAE Group customer database services:
In order to provide you with any services or benefits reserved for registered members of the NACAE Group customer database that you may choose to enjoy, we may share your personal information with other affiliated companies within the NACAE Group for the purpose of providing the requested services.
Click here to view NACAE Group retail entities, affiliated companies and the jurisdictions in which we operate.
Legal and regulatory compliance:
NACAE may also share your personal information with government authorities, regulatory bodies, law enforcement agencies and judicial authorities in order to comply with our legal obligations.
Transfer
NACAE will not transfer your personal information to any company, organization or individual, except in the following circumstances:
Where the transfer is made with your explicit consent;
In the event of a merger, acquisition, bankruptcy liquidation or other circumstances involving merger, acquisition or bankruptcy liquidation, where a transfer of personal information is involved, NACAE will require the new entity holding your personal information to continue to be bound by this Privacy Policy.
Prior to the transfer, we will provide appropriate notice to you, informing you of the recipient’s name and contact details, and ensure that your personal information continues to be protected in accordance with this Privacy Policy.
Where the recipient changes the purposes or methods of processing, we will require the recipient to obtain your consent again.
Public Disclosure
NACAE will only publicly disclose your personal information under the following circumstances, and only subject to appropriate security measures:
In accordance with the disclosure method expressly consented to by you, and to the extent required by your request;
Where disclosure is required by laws, regulations, administrative compulsory enforcement or judicial requirements.
Circumstances Where Consent Is Not Required
In the following circumstances, the sharing, transfer or public disclosure of your personal information does not require your prior consent:
Where it relates to national security or national defense security;
Where it relates to public security, public health or significant public interests;
Where it relates to criminal investigation, prosecution, trial or enforcement of judgments;
Where it is necessary to protect the life or property of the personal information subject or other individuals, and it is difficult to obtain the consent of the personal information subject;
Where the personal information has been publicly disclosed by the personal information subject;
Where the personal information is collected from lawfully publicly disclosed sources, such as lawful news reports or government information disclosures.
Please note that, in accordance with applicable laws, where NACAE adopts technical measures and other necessary measures to process personal information so that the information is anonymized or personal identifiers are removed, the sharing, transfer and disclosure of such anonymized information does not require notification to you or your consent.
7. Cross-Border Transfer of Personal Information
In principle, the personal information collected and processed by NACAE will be stored within the territory of the People’s Republic of China.
However, as NACAE operates as part of a global network and uses global services in order to manage our worldwide operations, improve service standards and provide you with global services, we may use overseas facilities to process, store or back up your personal information.
In such cases, we will comply with all applicable laws governing cross-border data transfers by adopting appropriate security measures and safeguards to ensure an adequate level of data protection and by obtaining your prior, specific consent where required.
Prior to transferring your personal information across borders, we will provide you with appropriate notice, informing you of, among other things, the name and contact details of the overseas recipient, the purposes and methods of processing, the types of personal information involved, and the means and procedures by which you may exercise your rights under this Privacy Policy against the overseas recipient. We will ensure that your personal information continues to be protected in a manner consistent with this Privacy Policy.
8. How NACAE Protects Your Personal Information
NACAE has adopted industry-standard security measures to protect the personal information you provide against unauthorized access, public disclosure, use, modification, damage or loss. For example, information exchanged between your browser and our servers is protected by SSL encryption; our website supports secure browsing via HTTPS protocols; encryption technologies are used to enhance the security of personal information; trusted protection mechanisms are implemented to prevent malicious attacks; and access control mechanisms are deployed to ensure that only authorized personnel may access personal information.
Your personal information is processed using appropriate electronic or automated means and computer tools, or manually in printed form, strictly limited to the purposes for which it was collected, and in a manner that ensures its security and confidentiality. Personal information is processed only by NACAE’s internal employees who are duly authorized according to their respective job responsibilities.
NACAE will take reasonable and practicable measures to avoid collecting irrelevant personal information. We will retain your personal information only for the shortest period necessary to achieve the purposes stated in this Privacy Policy, unless a longer retention period is required or permitted by applicable laws.
Please note that the Internet is not an absolutely secure environment. While NACAE will make every effort to ensure the security of any information you transmit to us, if our physical, technical or administrative safeguards are compromised, resulting in unauthorized access, public disclosure, alteration or destruction of information and causing damage to your legitimate rights and interests, NACAE shall bear corresponding legal responsibility in accordance with applicable laws.
In the event of a personal information security incident, NACAE will notify you in a timely manner in accordance with applicable laws and regulations. Such notification will include, without limitation, the nature of the incident and its possible impact, the measures taken or to be taken by NACAE, recommendations on how you may mitigate risks, and any remedial measures available to you. We may notify you by email, letter, telephone, push notification or other reasonable means. Where it is difficult to notify personal information subjects individually, NACAE will issue a public announcement in a reasonable and effective manner.
At the same time, NACAE will report all personal information security incidents to the relevant regulatory authorities as required.
9. Retention Period
Your personal information will be processed and stored for the period necessary to fulfill the purposes for which it was collected, in compliance with applicable legal retention requirements, or, where applicable, until you withdraw your consent to the processing of such information. Upon expiration of the relevant retention period, and where there is no legal or commercial reason to retain your personal information, such information will be permanently deleted or anonymized.
Specifically, with respect to the processing of information relating to registered members of the NACAE Group customer database, the retention periods are as follows:
Personal information associated with your membership account will be retained for seven (7) years from the date of your last interaction with the NACAE Group, or until you withdraw or cancel your registration in the NACAE Group customer database; and
Details of purchases and participation in activities will be retained for seven (7) years from the date of purchase or participation.
10. Personal Information Processor, Personal Information Protection Officer and Contact Details
The personal information processor is:
Beijing Nacae Technology Co., Ltd.
Room 618, 6/F, Building 1,
No. 88 Wangfujing Street,
Dongcheng District, Beijing, PRC
Email: sales@nacaeglasses.com
If you wish to exercise your rights or obtain any information regarding your rights and/or this Privacy Policy, please contact us using the address or email address listed above.
11. Rights of Personal Information Subjects
Please note that, in accordance with applicable privacy and data protection laws, you may exercise the following rights by contacting the personal information processor specified in Section 10 above:
To access and obtain a copy of your personal information;
To request the correction or supplementation of inaccurate or incomplete personal information;
To request the deletion of your personal information; and
Any other rights provided under applicable laws.
Right to Request Deletion
You may request the personal information processor to delete your personal information under any of the following circumstances:
The purpose of processing has been fulfilled, cannot be fulfilled, or is no longer necessary;
The personal information processor ceases to provide products or services, or the retention period has expired;
You have withdrawn your consent to the processing of your personal information;
The personal information processor has processed personal information in violation of laws, administrative regulations or agreements;
Or Other circumstances as provided by laws or administrative regulations.
Where your deletion request is approved, NACAE will also notify other entities that have obtained your personal information from NACAE and require them to delete such information in a timely manner, unless otherwise required by laws or regulations, or unless such entities have obtained your independent authorization.
Please note that after you delete information from NACAE’s services, such information may not be immediately removed from backup systems, but will be deleted during backup updates.
You are hereby reminded that deletion is irreversible. Once your personal information is deleted, you will no longer be able to view or manage historical orders, and services previously provided based on such information will no longer be available. We therefore recommend that you exercise your deletion rights with due caution.
You may withdraw your consent to the processing of your personal information at any time by contacting the personal information processor specified in Section 10 above, or by using any other appropriate procedures that may be provided by NACAE.
For security reasons, NACAE may require you to submit a written request or otherwise verify your identity. NACAE will respond to your request within fifteen (15) business days after receiving your request and verifying your identity, unless otherwise required by law.
Please understand that certain business functions require basic personal information in order to operate. Upon withdrawal of your consent, NACAE will be unable to continue providing the corresponding services and will cease processing the relevant personal information. However, your withdrawal of consent will not affect the legality of any personal information processing carried out prior to such withdrawal based on your consent. In addition, where retention of certain personal information is required to comply with applicable laws or regulatory requirements, NACAE will retain such information until the minimum statutory retention period expires.
In principle, NACAE does not charge fees for reasonable requests. However, for repetitive requests exceeding reasonable limits, NACAE may charge a reasonable fee depending on the circumstances.
NACAE may refuse requests that are manifestly unfounded or excessive, including but not limited to requests that require disproportionate technical efforts (such as developing new systems or fundamentally changing existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical (such as requests involving information stored on backup tapes).
In accordance with laws and regulations, NACAE may be unable to respond to your request in the following circumstances:
Where it relates to national security or national defense security;
Where it relates to public security, public health or significant public interests;
Where it relates to criminal investigation, prosecution or trial;
Where there is sufficient evidence that you have acted with malicious intent or abused your rights;
Where responding to your request would cause serious damage to the legitimate rights and interests of you or other individuals or organizations; or
Where commercial secrets are involved.
If you are dissatisfied with NACAE’s response, in particular if you believe that NACAE’s processing of personal information has infringed upon your lawful rights and interests, you may lodge a complaint with the competent supervisory authority, or seek judicial remedies by filing a lawsuit with the People’s Court of Dongcheng District, Beijing, where NACAE Technology is located.
12. Amendments to This Privacy Policy
NACAE reserves the right to amend this Privacy Policy at any time. Any changes to this Privacy Policy will be published on our website and/or other relevant digital platforms.
Once an updated version of this Privacy Policy is released, your continued use of the relevant services shall be deemed as your acceptance of such changes. For material changes, we will provide more prominent notice, including but not limited to notification via SMS or email.
The currently effective Privacy Policy is the version published on the website and/or relevant digital platforms.