Privacy Policy

STEELFLIER Watch Co., LTD Privacy Policy

Welcome to use the watch sales, after-sales maintenance, consultation and other related services (hereinafter collectively referred to as "Services") provided by STEELFLIER Watch Co., LTD (hereinafter referred to as "the Company" or "we"). This Privacy Policy is intended to clarify the methods, purposes and scope of our collection, use, storage, sharing, transfer and deletion of your personal information, inform you of the rights you have regarding your personal information and the ways to exercise them, and protect the security and legitimate rights and interests of your personal information.

This Privacy Policy applies to all channels through which you use our Services, including but not limited to the Company's official website, offline stores, official mini-programs, and cooperative platforms, as well as various business interactions with us (including but not limited to order placement, payment and settlement, after-sales refund, consultation and feedback, etc.). Your use of our Services shall be deemed as your having read, understood and agreed to all the contents of this Privacy Policy, including any subsequent updates we make to this Policy. If you do not agree to this Policy, please do not use our Services.

I. Definitions and Interpretations

1.1 Personal Information

Refers to various information recorded in electronic or other forms that can identify a specific natural person individually or in combination with other information, or reflect the activities of a specific natural person, including but not limited to name, date of birth, ID number, personal biometric information, address, phone number, email address, payment account information, order information, browsing history, etc.

1.2 Sensitive Personal Information

Refers to personal information that may endanger personal and property safety, and easily lead to damage to personal reputation, physical and mental health or discriminatory treatment if disclosed, illegally provided or abused, including but not limited to ID number, bank account information, payment account information, precise location information, etc.

1.3 Third-Party Service Providers

Refers to third-party entities that participate in relevant business links to assist us in providing Services, including but not limited to logistics and distribution agencies, payment service providers (such as Airwallex), technical support agencies, customer service outsourcing agencies, compliance audit agencies, etc.

II. Personal Information We Collect and Collection Methods

We adhere to the principles of "legality, legitimacy, necessity and minimization", and only collect personal information necessary for providing Services. We do not collect information unrelated to Services or collect personal information beyond the scope.

2.1 Personal Information You Voluntarily Provide

In the process of using our Services and interacting with us, you voluntarily provide us with personal information, mainly including:

- Identity Information: When you register an account, place an order to purchase watch products, apply for after-sales service or consult services, you may need to provide your name and ID number (such as ID card, passport, etc.) for identity verification and compliance filing;

- Contact Information: To facilitate us to communicate with you about order progress, after-sales matters and send service notifications, you need to provide your mobile phone number, email address and contact address (for logistics and distribution);

- Payment-Related Information: When you complete payment or apply for a refund through payment methods such as Airwallex, you need to provide information related to your payment account (such as bound bank card number, e-wallet account, etc.). Such information will be directly transmitted to the corresponding payment institution, and we only retain payment records (excluding sensitive information such as complete bank card numbers) for reconciliation, refund and compliance retention;

- Order and After-Sales Information: The product selection, shipping address, consignee and phone number you provide when placing an order, as well as relevant materials such as product defect photos, inspection reports and logistics documents you provide when applying for after-sales service;

- Consultation and Feedback Information: The consultation content, feedback opinions and relevant supporting materials you provide when consulting watch product information or feedback service issues through customer service channels (online customer service, phone, email, etc.).

2.2 Personal Information We Automatically Collect

In the process of you using our Services, we will automatically collect some personal information through the system to optimize service experience, ensure service security and conduct compliance audits, mainly including:

- Device and Network Information: The device model, operating system version, unique device identifier (such as IMEI, MAC address), browser type, network type (Wi-Fi/mobile network) and IP address you use, which are used to identify the legality of the device, troubleshoot service failures and ensure network security;

- Usage Behavior Information: Your browsing records of our official website and mini-programs, product viewing records, order records, payment records and after-sales operation records, which are used to analyze your needs and preferences, optimize product display and improve service efficiency;

- Location Information: If you allow us to obtain device location permissions, we will collect your approximate location information (only used for logistics and distribution optimization and offline store location recommendation, and no precise location information will be collected). You can turn off this permission in the device settings at any time without affecting the use of other Services.

2.3 Personal Information Obtained from Third Parties

On the premise of complying with relevant laws and regulations and obtaining your authorization, we may obtain relevant personal information about you from legally compliant third parties, mainly including:

- Payment Institutions (such as Airwallex): Obtain your payment status, payment records and refund records to complete order settlement, refund processing and reconciliation;

- Logistics and Distribution Agencies: Obtain your waybill number, delivery progress and signing information to synchronize order logistics status to you;

- Cooperative Platforms: If you purchase our products through third-party cooperative platforms (such as e-commerce platforms), we will obtain necessary information such as your order information and contact information from the cooperative platforms to fulfill orders and provide after-sales services. The obtaining of such information has been authorized by you on the cooperative platform;

- Compliance and Security Institutions: According to the requirements of laws and regulations, obtain necessary identity verification information from public security, market supervision and other institutions for compliance filing and risk prevention and control.

2.4 Information Not Collected

We will not collect personal information unrelated to Services such as your religious beliefs, political views, medical and health information, and social relationship information, unless you voluntarily provide it and obtain your explicit authorization.

III. Purposes of Using Personal Information

The personal information we collect is only used for the following legitimate purposes and shall not be used for purposes unrelated to Services:

- Fulfill Orders and Provide Services: Used to process your order placement, product delivery, payment and settlement, after-sales maintenance and refund processing (including refunds related to Airwallex payments), and synchronize order progress, logistics information and after-sales results to you;

- Customer Service: Used to respond to your consultations, complaints and feedback, solve problems you encounter in using Services, and provide personalized customer service support;

- Security Assurance: Used to identify and prevent security risks such as fraud and stolen swiping, troubleshoot service failures, and ensure the security of your account, payment and personal information;

- Compliance Requirements: Used to comply with the laws, regulations and regulatory requirements of China and the countries/regions where the relevant business is located, complete tax declaration, audit filing and identity verification, and respond to regulatory inspections;

- Service Optimization and Improvement: Optimize our product display, service processes, website and mini-program functions according to your usage behavior and feedback opinions to improve service quality;

- Send Service Notifications: Send you service-related notifications such as order reminders, logistics notifications, after-sales notifications and policy update notifications. You can choose to cancel some non-essential notifications according to your needs;

- Other Purposes Explicitly Authorized by You: If we need to use personal information for purposes not clearly stated in this Policy, we will obtain your written or oral authorization in advance, and the purposes shall comply with the provisions of laws and regulations.

IV. Sharing, Transfer and Public Disclosure of Personal Information

4.1 Sharing of Personal Information

We will not sell, rent or lend your personal information to any irrelevant third parties. Only in the following cases will we share your personal information with necessary third parties, and the scope of sharing is strictly limited to the minimum necessary for providing Services:

- Payment Service Providers (such as Airwallex): Share your order number, payment amount, payment account-related information (desensitized), and refund application information to complete payment settlement, refund processing and reconciliation. Such sharing has obtained your authorization, and the third party will strictly abide by relevant confidentiality regulations;

- Logistics and Distribution Agencies: Share your name, shipping address, contact phone number and order number to complete product delivery and logistics status synchronization. The logistics agency will only use it for delivery purposes and shall not use it for other purposes;

- Technical Support and Service Outsourcing Agencies: Share necessary device information, usage behavior information (desensitized) and consultation and feedback information to provide us with technical support and customer service outsourcing services. Such agencies shall sign a confidentiality agreement with us and shall not disclose or abuse the obtained personal information;

- Compliance and Regulatory Authorities: Provide necessary personal information to them in accordance with the requirements of laws and regulations, judicial organs or administrative regulatory authorities for compliance inspections, investigation and evidence collection, case handling, etc.;

- Cooperative Platforms: If you purchase our products through third-party cooperative platforms, we will share your order fulfillment status and after-sales processing results with the cooperative platforms to cooperate with the platform's regulatory requirements and synchronize information to you;

- Third Parties Explicitly Authorized by You: Under the condition of your active authorization, share relevant personal information with the third parties designated by you, and the scope of authorization shall be subject to your explicit instructions.

4.2 Transfer of Personal Information

Without your explicit consent, we will not transfer your personal information overseas. If it is necessary to transfer personal information due to the Company's merger, division, acquisition, asset transfer and other reasons, we will notify you in advance, ensure that the transfer process is legal and compliant, and require the receiving party to continue to perform the obligation of personal information protection. If the receiving party does not have the corresponding protection ability, we will terminate the transfer.

4.3 Public Disclosure of Personal Information

We will not publicly disclose your personal information unless it meets one of the following conditions:

- With your explicit written consent, and the scope of disclosure is limited to the scope authorized by you;

- In accordance with the mandatory requirements of laws and regulations, judicial organs or administrative regulatory authorities, publicly disclose necessary personal information (we will desensitize the information that can identify personal identity to protect your privacy as much as possible);

- To safeguard public interests and social security, or protect the legitimate rights and interests of you and other users, publicly disclose within a necessary and reasonable scope (such as preventing fraud, tracking malicious orders, etc.).

V. Storage and Security Protection of Personal Information

5.1 Storage Method and Period

- Storage Location: Your personal information will be mainly stored on servers located in the People's Republic of China. We will not arbitrarily transfer personal information to overseas storage. If it is necessary to transfer personal information overseas due to cross-border business needs, we will strictly comply with relevant Chinese laws and regulations, obtain your explicit authorization, and take necessary security protection measures (such as signing data export agreements, conducting security assessments, etc.) to ensure the security of personal information.

- Storage Period: We will retain your personal information in accordance with the principles of "minimum necessity and shortest period", and the retention period is the shortest time necessary to achieve the purpose of the service:
        

  - Order information, payment records, after-sales records, etc.: After the order is completed and the statutory retention period (such as tax and audit requirements) is met, they will be deleted or anonymized in accordance with the law;

  - Identity information, contact information, etc.: After you cancel your account, they will be deleted or anonymized in accordance with the law;

  - If there are clear provisions on the retention period in laws and regulations (such as the provisions on the protection of consumers' rights and interests), we will retain them in accordance with the statutory period and handle them in a timely manner after the expiration.

5.2 Security Protection Measures

We attach great importance to the security of your personal information and take various security measures in technology, management and physics to prevent risks such as leakage, tampering, loss and abuse of personal information:

- Technical Guarantee: Adopt encryption technology (such as SSL/TLS encryption) to transmit and store personal information, desensitize sensitive personal information (such as payment account information) to prevent illegal access to information; establish a sound technical protection system to prevent security risks such as network attacks and virus intrusion;

- Management Guarantee: Establish and improve the personal information protection management system, clarify the information security responsibilities of each position, conduct personal information protection training for employees, and strictly prohibit employees from arbitrarily obtaining, disclosing or abusing personal information; conduct permission control for employees who have access to personal information, implement the principle of minimum permission, and conduct regular security audits;

- Physical Guarantee: Conduct physical isolation and security protection for the servers and computer rooms that store personal information, equip professional security personnel and monitoring equipment to prevent information leakage at the physical level;

- Emergency Response: Establish an emergency response mechanism for personal information security. If a personal information security incident such as leakage, tampering or loss occurs, we will promptly activate the emergency plan, take remedial measures to reduce risks, and promptly notify you and relevant regulatory authorities in accordance with the requirements of laws and regulations.

5.3 Your Security Notes

Please properly keep your account information, payment password, mobile phone verification code and other sensitive information, and do not disclose them to others; if you find any account abnormality, illegal use of personal information, or receive suspicious service notifications, please contact our customer service in a timely manner, and we will handle it for you promptly.

VI. Your Rights to Personal Information

In accordance with relevant Chinese laws and regulations and this Policy, you have the following rights to your own personal information, and we will provide you with convenient ways to exercise them:

- Right of Inquiry: You have the right to inquire about your personal information collected, stored, used and shared by us, including but not limited to order information, payment records, personal data, etc.;

- Right of Correction: If you find that your personal information is incorrect (such as wrong contact information or shipping address), you have the right to request us to correct it, and we will correct it in a timely manner after verification;

- Right of Deletion: Under the conditions specified by laws and regulations and this Policy, you have the right to request us to delete your personal information (such as the order has been completed and there is no statutory retention obligation, you cancel your account, etc.). We will delete it in a timely manner after verification, and anonymize it if it cannot be deleted;

- Right to Withdraw Consent: You have the right to withdraw your consent to our collection, use and sharing of personal information (such as withdrawing location permission, SMS notification permission, etc.). After withdrawing consent, we will no longer continue to collect and use relevant personal information, but it will not affect the services and information processing completed based on your consent before the withdrawal;

- Right to Cancel Account: You have the right to apply for canceling your account. After the account is canceled, we will delete or anonymize your personal information (except as required by laws and regulations). After canceling the account, you will no longer be able to use our relevant Services;

- Right to Complain and Report: If you believe that our personal information processing behavior violates the provisions of laws and regulations or infringes on your personal information rights and interests, you have the right to complain and report to us, or to relevant regulatory authorities.

6.1 Methods of Exercising Rights

You can exercise the above rights through the following methods:

- Contact Official Customer Service: Submit your application through the customer service phone, online customer service, email and other channels published on the Company's official website, explain your needs and relevant identity information, and we will verify and feedback the processing results within 15 working days;

- Offline Application: If it is convenient for you, you can go to the Company's offline stores, bring your valid ID documents, and submit a written application to the staff, and we will verify on site and assist you in handling it;

- Complaint and Report: If you are not satisfied with our processing results, you can submit a complaint to the Company's complaint department, or report to the local market supervision department, cyberspace administration and other regulatory authorities.

VII. Protection of Minors' Personal Information

We attach great importance to the protection of minors' personal information. If you are a minor under 18 years old, you need to use our Services under the guidance of your guardian, and the guardian shall agree to this Privacy Policy on your behalf.

We will not take the initiative to collect personal information of minors. If the guardian finds that the minor's personal information has been collected by us, he/she can contact us to request deletion, and we will delete the relevant information in a timely manner after verification to ensure the privacy security of minors.

VIII. Updates and Notifications of the Privacy Policy

With the update of laws and regulations, the development of business and the progress of technology, we may revise this Privacy Policy. The revised Privacy Policy will be more conducive to protecting your personal information rights and interests.

After this Privacy Policy is updated, we will publicize it through channels such as the Company's official website, official mini-program, order notification and email, and it will take effect automatically after the publicity period expires. If you continue to use our Services after the policy update, it shall be deemed that you have accepted the updated Privacy Policy; if you do not agree to the updated policy, you can stop using our Services.

IX. Disclaimer

In the following cases, we shall not be liable for the leakage, tampering, loss, etc. of personal information:

- Personal information leakage caused by your improper storage (such as account password leakage, mobile phone loss, etc.);

- Personal information being illegally obtained and abused by third parties due to reasons not attributable to us (such as third-party hacker attacks, fraud, etc.);

- You take the initiative to disclose personal information to third parties, or submit personal information through channels not provided by us;

- Other disclaimer situations specified by laws and regulations.

X. Dispute Resolution and Contact Information

10.1 Dispute Resolution

If you have any dispute with us regarding personal information protection, you can first negotiate with us through customer service channels; if the negotiation fails, either party has the right to file a lawsuit with the people's court with jurisdiction where the Company is located.

10.2 Contact Information

If you have any questions, needs, complaints or reports regarding personal information protection, you can contact us through the following methods:

- Customer Service Email: [info@steelflier.com]

XI. Supplementary Provisions

11.1 This Privacy Policy shall be interpreted by STEELFLIER Watch Co., LTD.

11.2 This Privacy Policy shall come into force on the date of publication. If there are any inconsistencies between the original relevant personal information protection provisions and this Policy, this Policy shall prevail.

11.3 If any clause of this Policy is invalid or revoked due to violation of laws and regulations, it shall not affect the validity of other clauses.

STEELFLIER Watch Co., LTD

Effective Date: March 13, 2026