Effective Date: September 25, 2023

Introduction and Overview

This Privacy Policy ( "Policy" ) explains how your personal information is collected, used, shared, and processed when you access this website, located at www.moonbayjack.com (the "Site" ), our mobile application (the "App" ), or use other services provided by Hangzhou Moonbay Industrial Co., Ltd., including any written, electronic, and oral communications, online or offline, and purchases performed (collectively,the "Services" ) as well as the rights and choices you have associated with that information.The Policy also describes your rights regarding your personal data and explains how you can contact us to learn more about our data practices or to exercise your rights.

The Site and the App are provided by Hangzhou Moonbay Industrial Co., Ltd. is responsible for collecting, processing, and protecting your personal data.In this Policy, the terms “Moonbay,” “Company,” “we,” “us,” and “our” refer to Hangzhou Moonbay Industrial Co., Ltd.

Please read our Terms and Conditions and this Policy before accessing or using our Services.If you cannot agree with this Policy or the Terms and Conditions, please do not access or use our Services.

Policy Modification: Moonbay may change this Policy from time to time, to reflect how we process your data, and if we make changes, we will revise the effective date or last modified date at the top of this Policy.If we make changes that materially affect your privacy rights, we will attempt to provide advanced notice (including via real- or near real-time disclosures) or otherwise via the Site, or by some other means of contact so that you have a reasonable opportunity to review the changes before you continue to use the Site or the Services.

If you do not agree with the modified Policy, please stop using the Site, or the Services.

1.How We Collect and Use Your Personal Data

We respect the privacy of the visitors to our digital properties and the users of our products and Services, and we are committed to protecting it through our compliance with this Policy. We collect personal information when you use our Services.

Personal information is any information that identifies or makes an individual identifiable. The definition of personal information (used interchangeably in this Privacy Policy with the term "personal data") depends on where you are a resident.

Personal Information does not include data that has been effectively irreversibly anonymized or aggregated so that it can no longer enable us or others, whether in combination with other information or otherwise, to identify an individual.

Your personal data is collected and used by us to support a range of different business purposes. The purposes and types of information we collect are listed in the chart below and should be understood to include uses of your personal data that are compatible with the purposes listed.

Please note: When communicating with us by email or through forms on our Services, or when you publicly share content through our Services, we ask that you please do not send us any sensitive information pertaining to yourself or to others. We do not collect or store sensitive information or special categories of information.

2.Sharing Your Personal Data

We may disclose and share your personal information with the parties as described below.

• A.   Within Our Corporate Organization . The Company is a part of a corporate organization that has several legal entities, business processes, management structures, and technical systems. We may share your personal information with our related group companies and, in some cases, other affiliates of our corporate group for business maintenance and personalization continuity purposes, for instance, so that you may enjoy a personalized user experience across our digital properties, to provide you with the Services, or to take actions based on your requests or preferences.

• B.   Third Party Sellers . Where a third-party seller sells its’ products on the platform and the third-party seller will ship the products to you directly, we may share your personal data (name, address, and telephone number) with them so that they may fulfill your order and provide your personal data to a shipping logistics provider in order to ship the products to you.

• C.    Service Providers . We may provide access to or share your personal information with the following types of third-party service providers as set out in the table below:

Supplier/Service Provider/Processor	Services Offered
IT system and software service provider	Website hosting services (including cloud storage), mobile app or software optimization services, customer relationship management software, email service providers, or system maintenance services.
Payment service provider	Third-party payment processing services.
Marketing and advertising services	Assistance in reaching potential new customers across multiple communications channels or sharing with affiliated companies that promote our products on their websites.
Order fulfillment service provider	Provision of logistics, warehousing, and distribution services, return and exchange services, and order status notification services for your purchased items.
Customer service provider	Assistance with customer services and support.
Fraud prevention and information security service provider	Identity verification, fraud prevention, or credit risk reduction services to protect our Site/App and our business.
Other Service providers selected by you	Other third parties, such as size recommendations and fit prediction services providers if you have chosen to help us provide you with product recommendations.

• purposes for which it was provided to them and to the extent necessary for such purposes, in accordance with our written instructions.

• C.   To Maintain Legal and Regulatory Compliance . We have the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us. We also may disclose your information where we reasonably believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that disclosure will help us protect the rights, property, or safety of the Company or our customers.

• D.   Co-Branded Services and Features . Portions of our Services may be offered as part of co-branded services and features. We will share your personal information with our co-branded partners based on your voluntary use of or participation in a co-branded service or feature. The co-branded partners will be identified on the co-branded feature or service, along with an applicable co-branded partner's privacy policy. Use of your personal information by a co-branded partner will be subject to a co-branded partner’s privacy policy. If you wish to opt-out of a co-branded partner’s future use of your personal information, you will need to contact the co-branded partner directly.

• E.

     Consent . We may disclose your personal information for any purpose with your consent.
  

• F.Corporate Transactions . We may disclose personal information—including account information, Wallet balance or points information—to a buyer, prospective buyer, corporate affiliate, or other successors in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding in which personal information held by us about our Services users is among the assets transferred. You acknowledge and agree to our assignment or transfer of rights to your personal information.

Please note that we may disclose, without restriction, aggregated or anonymized information about the users of our Services, which is information that does not identify any specific individual.

3. Cookies, Interest-Based Advertising, Ad Choices

We may use cookies, tags, web pixels, and similar technologies to automatically collect information on our Services. Cookies or tags are bits of code that allow our technology partners to collect information that usually does not directly identify you. We will request your consent before using cookies or other tracking technologies. Information within this section describes our use of cookies and your ability to control the use of cookies for advertising-related purposes.

• A.   Cookies . Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the Site’s or provider’s system to recognize your browser and remember certain information.

• "First-party cookies" are cookies set by us on the Site. "Third-party cookies" are cookies set by other companies whose functionality is embedded into our site (For example, those set by Google).

• Generally, we use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.

• We use the following types of cookies on our Services:

• Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work, and they cannot be disabled.

• Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.

• Performance or Analytics Cookies. These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies as set forth below.

• Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.

• B.   Your Choices . Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Services by taking the steps outlined below.

• First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at https://www.moonbayjack.com/ .

• Third-Party Cookies. If you wish to opt-in or opt-out of third-party advertising networks and similar entities that use advertising cookies, please click the "Manage Cookies" link in our Site footer or visit https://www.moonbayjack.com/ . For more information about third-party advertising networks and similar entities that use these technologies, please see https://www.moonbayjack.com/ . You may withdraw your consent or update your preferences at any time by clicking the "Manage Cookies" link within the Site footer or within the App menu.

• Mobile Applications. To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the Digital Advertising Alliance’s AppChoices mobile application opt-out offering here: https://www.moonbayjack.com/ .

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here: Google Chrome , Internet Explorer , Mozilla Firefox , Safari (Desktop) , Safari (Mobile) , Android Browser , Opera Mobile .

SHEIN adheres to the Digital Advertising Alliance's Self-Regulatory Principles.

• C.   Web Pixels . To see how successful our marketing campaigns or other goals of the Services are performing we sometimes use conversion pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page (e.g. a thank you page once you have completed the procedure for subscribing to one of our services or have completed one of our forms). We also use web pixels to analyze usage patterns on our Services. The use of a pixel allows us to record that a particular device, browser, or application has visited a particular webpage.

• D.   Analytics . We may use third-party service providers to monitor and analyze the use of our Services. Presently, we use Google Analytics . Google Analytics is a web analytics service that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en . Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout .

• E.   Facebook ads. We also use Facebook Business Tools and we may display interest-based ads to you when using Facebook. To modify your preferences or turn off personalization for ads served by Facebook, you can visit Facebook's Ad Preferences in addition to the Your Choices section below. We may also show ads to audiences that share similar characteristics as you. To do so, a list of email addresses is irreversibly encrypted through hashing and uploaded or transmitted from our site, and Facebook matches the hashed data against its own users, generating a lookalike audience and deleting the uploaded list. We do not have access to the identity of anybody in the "lookalike" audience unless they choose to click on one of our advertisements.

• F.   Java Script . Pages of our Site may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or "cached" within your browser to store and retrieve data in HTML5 pages when the website is revisited.

• G.   Other Tracking Technologies . We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.

• H.    Do Not Track . Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit "Do Not Track" or "DNT" signals. Since uniform standards for "DNT" signals have not been adopted, our Site does not currently process or respond to "DNT" signals.

• I.  Location Information . You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings.

4.  Security Precautions

• We maintain reasonable physical, electronic, and procedural safeguards designed to guard your personal data from unauthorized processing, use or disclosure.  Our security measures include industry-standard physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information.

• The Internet is not an absolutely secure environment, and we cannot guarantee that your personal data will be secure.  We therefore strongly recommend that you use a secure method and use a complex password to help us ensure the security of your account.  We also strongly advise that you neither share your password with others nor re-use passwords on our Services that you use on other sites or apps, as doing so increases the likelihood of your being the victim of a credential stuffing attack or other malicious cyber behavior.  If you feel that the security of your account or personal data has been compromised, please immediately contact us at our dedicated Privacy Center or as otherwise described in the "Contact Us" section below.

5. Your Rights

5.1 Access, Correction, and Deletion of your Personal Information. You have the right to access, correct, or delete the personal information that we collect. To protect the privacy and the security of your personal information, we may request data from you to enable us to confirm your identity and right to access such data, as well as to search for and provide you with the personal data we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain. To exercise your rights, you may make updates within your customer account on the Site or App, or you may contact us at our dedicated Privacy Center . We may not accommodate a request to delete or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

5.2 Unsubscribe from Our Marketing Communications. If you do not want us to use your email account to send you marketing emails or non-transactional promotional materials, please directly click on the unsubscribe link at the bottom of any of our email messages to you or contact us at our dedicated Privacy Center .

5.3 Lodging Complaints. If you believe we have infringed or violated your privacy rights, please contact us at our dedicated Privacy Center so that we may attempt to resolve any issues to your satisfaction.

5.4 Right to Opt-Out of Selling . Residents of certain states, such as California and Virginia, have the right to opt-out of having their personal information sold. We do not sell your personal information as that term is generally understood but we recognize that certain privacy laws may define “sale” or "personal information" in such a way that making identifiers linked to you available to limited third parties for a benefit may be considered a "sale." In the previous 12 months, we may have shared identifiers and inferences about you with our partners, third parties, and affiliates in such a way that, under such privacy laws, may be interpreted as “selling.” If your state allows you to opt-out from such “sales,” you may exercise your opt-out right by clicking the "Manage Cookies" link in our Site footer to load a consent tool that will allow you to opt-out of the cookies on our Site.

6. Retention

We will retain your personal data, including any correspondence you have with us only for as long as is necessary for the purposes set out in this Policy, including retaining Personal Data to comply with our legal obligations, to resolve disputes, for information security purposes, and to enforce our legal rights, terms, and policies.

7. Third-Party Websites

Our App or Site may contain links to third-party sites. This Policy does not apply to those third-party sites. We recommend that you read the privacy statements of any other sites that you visit as we are not responsible for the privacy practices of those sites.

8. Children

Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 16 or minors (as defined by applicable national laws). If you are a minor, please do not attempt to fill out our forms or send any personal information about yourself to us. If a minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact us immediately to remove the relevant personal information and unsubscribe the minor.

If we become aware that a minor has provided us with personal information, we will take steps to promptly delete such information from our files. As described further in our Terms and Conditions , please do not upload photographs showing other people, in particular if they are minors.

9. Transfer of Your Personal Data

This Privacy Policy only applies to all residents .Please note as well that when you use our Services, your personal data may be accessed or transferred other countries.Such countries may have data protection laws that are less protective than the laws of the jurisdiction in which you reside.For these transfers, we rely on appropriate safeguards as permitted under applicable law and standards.If you do not want your information transferred to, processed, accessed, or maintained other countries, you should immediately stop accessing or using the Services.

10. Contact Us

If you have questions or concerns regarding any information in this Privacy Policy, please contact us at our dedicated Privacy Center .

Our Privacy Office can be contacted via the email address below or via our postal address:

Hangzhou Moonbay Industrial CO., Ltd Office

Room B205, Cross-Border E-Commerce Comprehensive Pilot Area, No. 776 Jianshe 1st Road, Xiaoshan District, Hangzhou Zhejiang, China

Email: frank@chinamoonbay.com