This Privacy Policy (“Policy”) explains how Boda Technology, Inc. (“Boda,” “we,” “us,” “our”) collects, uses, and discloses information through its website, bodatechnology.com, and all of its subdomains, as well as through other online mediums and websites that link to this Policy (collectively, the “Services”). Please read this Policy carefully so that you understand our information practices. If you do not agree with the terms of this Policy, please do not use the Services.

1. Information We Collect

We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as information collected from your browser or device that you use to access the Services.

A. Information You Provide Directly to Us

When you use the Services, such as by registering for an account or communicating with us, you may provide us information directly, including:

• Contact information, such as your name, email address, phone number, fax number, company name, and physical address.
• Registration information, including a username and password.
• Purchase information, such as quantity and type of goods purchased, name of purchaser, and shipping address.
• Payment information for your purchase, which is securely processed by our third-party payment processor.
• Correspondence between you and us and records of such correspondence, such as the contents of emails you send us, support inquiries, or other feedback you provide directly to us.
• Information you provide in product reviews and surveys; and
• Marketing preferences, such as records of your requests to opt out of marketing communications.

B. Information That is Passively and/or Automatically Collected

We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services, such as (a) IP addresses, unique device identifiers and other information about your computer or mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information. We also automatically collect data when you engage in a transaction with us, such as a transaction ID, purchase date and time, and transaction amount.

Location Information: We may automatically collect location information, including general location information (e.g., city, state and zip code) derived from your IP address or other information associated with your device. 

Cookies and Other Electronic Technologies: Some Boda pages may use cookies and similar technologies, such as web server logs, beacons, and tracking pixels. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand what pages on the Site you have visited; (iv) enhance your user experience by delivering content specific to your interests; (v) perform searches and analytics; and (vi) assist with security administrative functions. Cookies are placed in your browser cache, while tracking pixels (sometimes referred to as “web beacons” or “clear GIFs”) are electronic tags with a unique identifier embedded in websites, online ads and/or email, and are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and access user cookies. We may also use these automated technologies to collect and analyze other information related to the devices you use to access the Services, such as IP addresses, browser types, browser language, operating system used, the domain name of your Internet service provider, unique device identifiers, and other information about your devices used to access the Services. These automated technologies may also collect information on the websites you have visited before and after you visit the Services, and the advertisements you have accessed, seen, forwarded, and/or clicked on when using the Services or other websites. We or third-party technologies we use may place or recognize a unique cookie on your browser to enable you to receive customized content, offers, services or advertisements on our websites or other sites. As we adopt additional technologies, we may also gather additional information through other methods.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Microsoft Edge, Google Chrome, Mozilla Firefox, or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.

We use third parties to assist us in serving advertisements, tracking site usage statistics, and providing content-sharing services to support the Services. These third parties may also use cookies and similar technologies to collect similar information about your use of the Services. We do not control these third-party technologies, and their use of your information is governed by those parties' privacy policies. For more information about how to opt out of these third parties’ use of your information, please see Section 6 below.

C. Information Collected from Third-Party Platforms

When you interact with our social media pages, such as by “liking” our page or posting comments or replies to our content, we may collect certain information about you, consistent with your privacy settings on that platform. If you do not wish for us to collect information from these third parties, please do not interact with us via third-party platforms. We may also collect information about you that you have posted publicly, such as on business networking websites. For a description on how these third parties handle and disclose your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. We may combine information that we collect from or about you with information about you that we obtain from such social media and other content platforms.

2. How We Use Your Information 

We may use the information we collect for the following purposes:

• To provide, operate, administer, and troubleshoot the Services;
• To fulfill your orders;
• To send you information about your relationship or transactions with us;
• To respond to your inquiries and send information that we believe is of interest to you;
• To market the Services to you, including, but not limited to, by contacting you about discounts, promotions, updates, special offers, and joint marketing efforts via email or direct mail;
• To administer surveys, sweepstakes, special promotions and contests;
• To personalize your experience when using the Services;
• For internal research, reporting and data analytics;
• To improve the Services and/or develop new Services;
• To allow us and our advertising partners to personalize the content and advertising that you see on the Services and on third-party platforms;
• To comply with applicable laws and regulations;
• For internal auditing and recordkeeping purposes;
• To protect the safety of ourselves, our customers, and the public; and
• To enforce the legal or contractual terms that govern your use of the Services or defend our legal rights.

We may also combine information that we collect from you with information we obtain about you from third parties. We may aggregate and/or de-identify any information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties.

3. When We Disclose Your Information

We may disclose your information to parties outside of Boda under the following circumstances:

• Affiliates. We may disclose your information to our affiliates and subsidiaries under common ownership and/or control.
• Service Providers. We may provide access to your information to vendors and others who perform services on our behalf. These parties provide a variety of services to us, including, without limitation, order processing, billing, sales, marketing, advertising, market research, fulfillment, data storage, analysis and processing, and legal services. 
• Other Third Parties. Except as provided herein, we may disclose your information to third parties that assist in tailoring and serving advertisements that are relevant to you. We may also allow third-party advertising technologies (e.g., ad networks and ad servers) to use cookies and similar technologies on the Services to deliver relevant and targeted content and advertising to you on the Services and other websites you visit and applications you use, as explained further in “Personalized Content and Advertising” below.
• Consent. If you consent, we may disclose your information publicly or to third parties, such as if you agree to provide a product or service review and have that content attributed to you.
• Protection of Boda and Others. We may access, preserve and disclose your information if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (a) comply with applicable laws and regulations or legal process; (b) enforce our Terms & Conditions, this Policy, or other contracts with you; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of Boda, its agents and affiliates, its users and/or the public. We may also disclose information to law enforcement agencies in emergency circumstances where the disclosure of such information is consistent with the types of emergency disclosures permitted or required by law.
• Business Transfers. We may disclose and/or transfer your information, including your contact information, in connection with a proposed or actual merger, acquisition, transfer of control, distribution or sale of all, or components, of our business.

4. Our Legal Bases for Processing Your Personal Data

The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to use or disclose your “personal data” as such term is defined under applicable law. To the extent that those laws apply, our legal grounds are as follows: 

• To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our customers, or to take steps at customers’ requests in anticipation of entering into a contract with them. For example, we handle personal data on this basis to process and fulfill your orders.
• Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
• Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as to fulfill customer service requests, market our services to you, protect our users, personnel and property, and analyze and improve the Services.
• Legal compliance: We use and disclose personal data in certain ways to comply with our legal obligations.

5. International Users 

The Services are operated in the United States and are governed by United States law. If you are a resident of the European Union or other location outside the United States, please be advised that any information you provide through the Services will be transferred to the United States or other designated locations outside of the United States for certain processing/hosting operations. We have taken steps to ensure that your personal information is appropriately protected and is processed only in accordance with this Policy. 

6. Your Data Rights and Choices

A. Marketing Communications

You can unsubscribe from marketing emails we send to you by clicking the “unsubscribe” link they contain. Please note that even though you may opt-out of receiving marketing-related communications from us, we may still send you important administrative and transactional messages.

B. Rights Regarding Your Information

Depending on your jurisdiction, you may have the right, in accordance with applicable data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to: 

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
• Provide you access to and/or a copy of certain personal information we hold about you.
• Correct or update personal information we hold about you.
• Delete certain personal information we have about you.
• Provide you with information about the financial incentives that we offer to you, if any.
• Restrict or object to certain uses of your information.
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable. 

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the Services to you. 

You may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising” as described below. If you are a California resident, please see the “Notice to California Residents” section below for more information about our privacy practices and your rights.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests. 

To exercise any of these rights, you can email us at privacy@bodatechnology.com with your name and type of request you are making.

You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. 

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

C. Notice of Right to Opt Out of Processing/Sharing of Personal Information for Targeted Advertising Purposes

Depending on your jurisdiction, you may also have the right to opt out of “sharing/processing of your information for targeted advertising.” As explained in the “When We Disclose Your Information” section above, we sometimes disclose information to unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you. We also provide information to third-party advertising providers for targeted advertising purposes or use advertising analytics partners to assist us in analyzing use of our services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered as processing/sharing of personal information for targeted advertising purposes. If you would like to opt out of the disclosure of your personal information for purposes that could be considered “sharing” or processing for purposes of targeted advertising, please contact us via email at privacy@bodatechnology.com.

Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age.

8. Notice to California Residents 

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act (“CCPA”).

We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities with which we disclose such information in the “Information We Collect”, “How We Use Your Information,” and “When We Disclose Your Information” sections of this Privacy Policy. We provide additional information required by the CCPA below.

A. Categories of Personal Information we collect, use and disclose

Throughout this Policy, we discuss in detail the types of Information we collect from and about users and discuss how we use and disclose such information. The following are the “categories” of personal information under the CCPA that we collect from California consumers and that we may, as discussed throughout this Policy, use and disclose for our business purposes: 

Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information processed by our payment processor); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history); general geolocation data derived from IP addresses; any user-generated content or feedback that you provide; professional or employment related data; and username and password (which is considered “sensitive” personal information under California law).

B. How we use these categories of personal information

We and our service providers may use the categories of personal information we collect from and about you for the following business and commercial purposes (as those terms are defined in applicable law). 

• Our or our service providers’ operational purposes;
• Auditing consumer interactions on our site (e.g., measuring ad impressions);
• Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
• Bug detection and error reporting;
• Customizing content that we or our service providers display on the Services (e.g., contextual ads);
• Providing the Services (e.g., account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about the Services);
• Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
• Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third party partners;
• Other uses about which we notify you. 

Examples of these types of uses are discussed in our main privacy policy in the “How We Use Your Information” section. We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any user or device. We may also disclose this information to third parties for legal, compliance or security purposes, or in connection with a business transfer, as described further in “When We Disclose Your Information” above.

C. Sale/Sharing of Personal Information 

The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes. Under the CCPA, “sale” and “sharing” are defined such that they may include allowing third parties to receive certain information for advertising purposes. We “sell” or “share” the following categories of information to third-party advertising partners and vendors that support our advertising efforts (such as advertising analytics services): 

Identifiers (such as name, address, email address); commercial information (such as transaction data); internet or other network or device activity (such as browsing history and usage information).

If you would like to opt out of our use of your information for such purposes that are considered a “sale” or “sharing” for cross-context behavioral advertising purposes under California law, please email us at privacy@bodatechnology.com. Alternatively, if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law. Please note that we do not knowingly sell the personal information of minors under 16 years of age.

Please note, in the limited circumstances that we process sensitive personal information as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA. 

D. Additional Privacy Rights

In addition to the rights section before in section C above, California residents may make certain requests about their personal information under the CCPA as set forth in Section 7(B) (Rights Regarding Your Information) above. 

If you are a California resident and would like to exercise any of your legal rights under the CCPA, you can email us at privacy@bodatechnology.com.

E. Shine the Light

California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

F. Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Except as otherwise described herein with respect to legally required browser based opt outs, we do not recognize or respond to browser-initiated DNT signals, as there is no industry-wide framework for DNT signals. To learn more about Do Not Track, you can do so here.

9. Security and Retention of Your Information 

We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

We generally retain personal data for so long as it may be relevant to the purposes above. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. To dispose of your information, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time. 

10. Information from Children

The Services are not directed to children under the age of 16. If we discover we have received any “personal information” (as defined under the Children’s Online Privacy Protection Act) from a child under the age of 13 in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under the age of 16, please contact us at the address listed below.

For residents of the EEA, where processing of personal information is based on consent, we will not knowingly engage in that processing for users under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.

11. Contacting Us about This Policy

If you have any questions about this Privacy Notice, please contact us at privacy@bodatechnology.com. 

12. Changes to This Policy

We reserve the right to change this Policy at any time to reflect changes in the law, our data collection, use and disclosure practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Policy will be deemed to mean you understand the applicability of those changes.