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XTEINK Privacy Policy

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from eu.xteink.com (the “Site”).

WHO WE ARE
This Site is operated by XTEINK LIMITED, registered in Hong Kong, with its registered address at Genplas Industrial Building, 56 Hoi Yuen Road, Kwun Tong, Kowloon, Hong Kong ("XTEINK", "we", "us", "our"). We are the controller of your Personal Information.

PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”. We collect device information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

COOKIES AND CONSENT
Strictly necessary cookies (for example, to keep your cart and remember your cookie choices) are used on the basis of our legitimate interest in operating a functional and secure site. All other cookies — analytics, advertising and social-media — are placed on your device only after you consent, and are used on the basis of Article 6(1)(a) GDPR. You can give, refuse or withdraw your consent at any time through "Cookie settings" in the footer of the Site; withdrawing does not affect processing carried out before you withdrew it. You may also delete or block cookies in your browser settings. For the cookies we use, their providers and retention periods, see our Cookie Policy. Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information, such as your billing name and the last four digits of your payment card (your full card number is processed by our payment service provider and is not stored by us), email address, and phone number. We refer to this information as “Order Information”. When we talk about “Personal Information” in this Privacy Policy, we are talking about both Device Information and Order Information.

HOW DO WE USE YOUR PERSONAL INFORMATION?
We process your Personal Information only where we have a legal basis under Article 6(1) GDPR:
- necessary to perform our contract with you — processing and delivering your order, payment, invoices, returns and warranty claims;
- our legitimate interests — customer support, fraud screening and Site security, and understanding how our Site is used; 
- your consent — non-essential cookies, marketing e-mails and targeted advertising; and 
- our legal obligations — tax, accounting, consumer-protection and product-safety law, and defending legal claims. You may object to processing based on our legitimate interests, and withdraw your consent, at any time (see "YOUR RIGHTS"). You must provide your name, delivery address, e-mail address, and payment details in order to place an order; Without them, we cannot conclude or perform our contract with you. Other information is optional. We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
 - Communicate with you;
- Screen our orders for potential risk or fraud; and 
- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services. We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

SHARING YOUR PERSONAL INFORMATION
We do not sell your Personal Information. We share it only with: our e-commerce platform and hosting providers (including Shopify); payment and fraud-screening providers; carriers, forwarders and customs brokers; e-mail, customer-support, analytics and advertising providers (including Google Analytics and social-media platforms); our professional advisers and insurers; and public authorities or courts where the law requires it.
Recipients acting on our behalf process your Personal Information as our processors under Article 28 GDPR and only on our instructions. A recipient that determines the purposes itself, such as a payment provider carrying out its own fraud or anti-money-laundering checks, acts as an independent controller under its own privacy notice. We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site - you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or other lawful requests for information we receive, or to otherwise protect our rights.

MARKETING, PROFILING AND YOUR CONSENT
We send marketing communications and show targeted advertising only with your prior consent, for example where you tick the relevant box at checkout or accept marketing cookies. For this, we carry out profiling: we combine the pages and products you view and information about your device with, where you are an existing customer, your order history, to infer which products may interest you. We do not make decisions based solely on automated processing within the meaning of Article 22 GDPR.
You can withdraw your consent at any time, free of charge, by clicking "unsubscribe" in any marketing e-mail, changing your choices in "Cookie settings", or writing to support@xteink.com. Objecting to marketing does not affect processing necessary to fulfil your order. You may also object to profiling based on our legitimate interests. As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/.

YOUR RIGHTS
In addition, if you are in the EEA, the UK or Switzerland, you have the right to:
- be informed and to access the Personal Information we hold about you; 
- have inaccurate or incomplete information rectified; 
- have your information erased (the right to be forgotten); 
- restrict our processing; 
- data portability — to receive the information you have provided to us in a structured, commonly used and machine-readable format and to have it transmitted to another controller; 
- object at any time to processing based on our legitimate interests, and to object at any time to direct marketing; 
- withdraw any consent you have given at any time; and 
- not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. To exercise any of these rights, e-mail us at support@xteink.com. We answer within one month and do not charge you, unless your request is manifestly unfounded or excessive; We may ask you to confirm your identity. You also have the right to lodge a complaint with a supervisory authority. We would appreciate the opportunity to address your concern first. Additionally, if you are a European resident, we note that we are processing your information in order to fulfill contracts we might have with you (for example, if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. 

INTERNATIONAL TRANSFERS
Some of our service providers are located in, or may access your Personal Information from, countries outside the EEA and the UK, in particular the United States and Canada. Where we transfer your Personal Information outside the EEA we rely on an adequacy decision of the European Commission (including for Canada, for commercial organisations subject to PIPEDA); on the EU-US Data Privacy Framework, or the UK Extension to it, where the recipient is certified; or otherwise on the Standard Contractual Clauses approved by Decision (EU) 2021/914, or the UK International Data Transfer Addendum, together with a transfer impact assessment. You may request a copy of these safeguards from support@xteink.com.

DATA RETENTION
We keep your Personal Information only as long as necessary, and then delete or irreversibly anonymise it:
- order, delivery and warranty records — for the applicable statutory warranty and limitation periods; 
- invoices and accounting records — for 6 years from the end of the financial year in which the transaction took place; 
- account data — while your account is active and for 24 months after your last activity; 
- fraud-screening and security logs — 12 months; 
- analytics data — in aggregated or pseudonymised form, up to 14 months; and 
- marketing data — until you withdraw your consent or object. Where we must keep information longer by law (for example, tax, or product-safety and traceability obligations for our devices), we keep it for that period and restrict it to that purpose. If you ask us to delete your Personal Information, we will do so unless we are legally required to retain it, and we will tell you what we keep and why. 

CHILDREN
Our Site is not intended for children. We do not knowingly collect Personal Information from children below the age at which they can validly consent to information-society services where they live — 16 years, or a lower age of not less than 13 where applicable law so provides. If you are below that age, please do not place an order or provide us with your Personal Information without the consent of a parent or guardian. If we learn that we have collected such information without the required consent, we will delete it, or where we must retain it by law restrict it to that purpose, and close the associated account. If you believe a child has provided us with Personal Information, please contact support@xteink.com. 

CHANGES
If we make material changes — in particular to the purposes or legal bases of processing, the categories of recipients, or our international transfers — we will notify you before they take effect, by e-mail where we hold your address or by a prominent notice on the Site. Where a change concerns processing based on your consent, we will ask for your consent again before the new processing begins. This version was last updated on 2026-09-24 and takes effect on that date.

CONTACT
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at support@xteink.com.

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