Privacy Policy for Services of Guangzhou Uto Technology Co., Ltd.

1. Scope of Application

1. These Terms apply to the collection and processing of your personal information by us through our official website (domain: utootime.com), affiliated platforms, and the provision of intelligent marketing-related services (including overseas marketing strategy consulting, access to overseas market data reports, advertising account binding (including Google Ads and Facebook Ads accounts), submission of advertising creative needs, Shopify store operation authorization and data docking, etc.).
2. These Terms do not apply to information collected by third-party platforms or services (such as Google Ads, Facebook Ads, Shopify platforms, data statistics tools, payment institutions, etc.). Please refer to the privacy policies of third parties (such as Google Privacy Policy, Facebook Data Policy, Shopify Privacy Policy) on your own. We shall not be liable for the information processing activities of third parties.

2. Personal Information We Collect and Collection Methods

(I) Necessary Personal Information

To ensure the normal operation of intelligent marketing services (including Google Marketing, Facebook Marketing, and Shopify Operations) and fulfill the obligations of the service contract, we need to collect the following necessary information. If you refuse to provide it, you may not be able to obtain core services normally:

1. Account Registration and Identity Verification Information: Including your mobile phone number/email address, set account password, as well as enterprise information (such as enterprise name, business license number, tax registration certificate information) and contact person identity information (such as ID card number, passport number, Hong Kong/Macau Pass number) required in accordance with service compliance requirements (such as Google Ads/Facebook Ads account binding, Shopify store operation authorization). These are used for account identity verification, service permission activation, and business docking.
2. Service Docking and Demand Information:
   • Advertising Placement (Google/Facebook Marketing): Your Google Ads Account ID, Facebook Business Manager Account ID and authorization code, advertising placement goals (such as brand exposure, product conversion), target audience region/age/interest tags, advertising budget range, keyword strategy needs (exclusive to Google Marketing), and social media content direction (exclusive to Facebook Marketing). These are used for building advertising accounts, formulating placement strategies, and implementing optimizations.
   • Shopify Operations: Your Shopify store backend account authorization information (such as API key, access token), store product information (name, price, inventory, SKU code), order data (buyer's name, shipping address, contact information, order amount, payment status), and store traffic data (visitor source, browsing path). These are used for store decoration optimization, product listing management, order processing, traffic operation, and sales data analysis.
   • General Category: Advertising creative materials (such as brand logos, product images, promotional copy, video materials) used for the production and release of advertising content.
3. Device and Access Information: Including the device model, operating system version, IP address, browser type, access time, and page browsing records (such as viewed Google/Facebook marketing cases, Shopify operation plans) when you use the services. These are used to ensure the stability of the official website and services, identify abnormal access, and optimize the service interaction experience.

(II) Non-Necessary Personal Information

To improve the effectiveness of intelligent marketing services and provide personalized solutions, we may collect the following non-necessary information (you can choose whether to provide it voluntarily):

1. Marketing Effect Feedback Information: Such as your evaluation of Google/Facebook advertising placement effects (click-through rate, conversion rate), optimization needs for Shopify store operation data (repurchase rate, average order value), and modification suggestions for advertising creatives/store visual design. These are used to adjust marketing strategies and improve operation plans.
2. Target Audience and User Behavior Information: The consumption habits of target users for your Google/Facebook ads (such as purchase frequency, average order value preference) and social media interaction preferences (such as favorite content types, active time periods) provided by you; anonymized behavior data of Shopify store buyers (such as product browsing duration, reasons for adding to cart but not paying). These are used to accurately optimize ad targeting and improve store conversion efficiency (all data has been stripped of personally identifiable information).
3. Social and Cooperation Information: If you choose to log in to the official website quickly through a Google account, Facebook account, or Shopify account, or authorize us to access your enterprise Google Analytics data, Facebook Page fan data, or Shopify store backend statistical data, we will obtain basic information of the account (such as nickname, avatar) or statistical data within the authorized scope, subject to the authorization scope of the third-party platform.

(III) Collection Methods

1. Voluntary Provision by You: Including information filled in during account registration, materials and data uploaded when submitting Google/Facebook marketing needs/Shopify operation needs, and business docking information provided through official website forms/customer service communication (such as Shopify store authorization documents).
2. Automatic Collection by Services: Through technical tools such as our server logs, Cookies, and SDKs (such as Google Analytics SDK, Facebook Pixel SDK, Shopify API data docking tools), automatically collect device, access, and service usage data (such as Google ad click data, Shopify store visitor behavior data) when you use the official website and services; after obtaining your authorization, automatically synchronize advertising placement data (impressions, clicks, conversion costs) and store operation data (order quantity, sales volume, inventory alerts) through docking with the open interfaces of Google Ads, Facebook Ads, and Shopify platforms.
3. Provision by Third Parties: Advertising placement data obtained from Google Ads and Facebook Ads platforms (such as audience profile analysis, advertising violation early warning information); basic store data obtained from Shopify platforms (such as store opening time, payment method configuration); market insight data obtained from legally authorized third-party data institutions (such as Google search trends, Facebook user interest tag distribution, cross-border e-commerce consumption trends); service fee payment status information obtained from payment institutions. We will require third parties to ensure the legality of information sources and only use the information for agreed service purposes.

3. Purposes of Using Personal Information

We only use your personal information within the following legal and necessary scope:

1. Fulfill the Service Contract:
   • Google/Facebook Marketing: According to your authorization, log in to your Google Ads/Facebook Ads account, build advertising plans (set keywords, audience targeting, budgets), upload advertising creatives, real-time optimize placement strategies (adjust bids, pause underperforming ads), and push advertising placement data reports (daily/weekly/monthly effect summaries) to you.
   • Shopify Operations: According to your authorization, log in to your Shopify store backend, complete product listing and editing, order processing (shipping information entry, refund operations), store decoration (theme replacement, section adjustment), marketing activity settings (discount code issuance, full reduction activities), and push store operation daily reports (order quantity, sales volume, visitor count) to you.
   • General Services: Generate overseas market insight reports, produce advertising creative materials, and send service progress notifications (such as ad launch notifications, store operation node reminders) and settlement bill information.
2. Optimize Service and Marketing Effectiveness: Analyze Google/Facebook advertising placement data (such as conversion rates of different keywords, differences in audience tag effects) to optimize ad bidding strategies and targeting accuracy; analyze Shopify store data (such as visitor churn nodes, characteristics of high-conversion products) to optimize store layout design, product combination, and inventory management; provide you with more tailored personalized services based on your service usage habits.
3. Ensure Service Security and Compliance: Identify abnormal access and false service needs through device information, IP addresses, and account login logs (such as logging in to a Google Ads account from an unusual location) to prevent risks such as data leakage, illegal advertising placement, and Shopify store account theft; complete service filing, data compliance reviews, and cooperate with regulatory authorities and third-party platform investigations in accordance with the laws and regulations of China and overseas target markets (such as the Personal Information Protection Law of the People's Republic of China, GDPR, CCPA, Google Ads Policies).
4. Service Notifications and Communication: Push important information related to services to you (such as term updates, changes to Google/Facebook advertising policies); send marketing industry dynamics; push service promotion information that you agree to receive, and you can unsubscribe at any time.
5. Other Authorized Purposes: Such as your consent to our use of anonymized Google/Facebook advertising effect data and Shopify store operation data for case demonstrations, or authorization for us to share necessary information with overseas partners to jointly provide value-added marketing services (prior explicit notification and separate authorization from you are required).

4. Storage and Cross-Border Transfer of Personal Information

(I) Storage Methods and Periods

1. Storage Locations: Your personal information (such as account information, service demand documents) will be stored on our servers located in China or compliant third-party cloud storage services (such as Alibaba Cloud, Tencent Cloud); due to the needs of Google Marketing, Facebook Marketing, and Shopify Operations business, some information may be stored on the servers of corresponding third-party platforms (such as Google's U.S. servers, Facebook's Irish servers, Shopify's Canadian servers) and our cooperating overseas compliant servers. We will ensure that all storage servers comply with local data protection standards.
2. Storage Periods: We will store your personal information for the period necessary to achieve the purposes agreed in these Terms. Among them: Google/Facebook advertising placement data and Shopify store operation data will be stored for 2 years after the end of the service, and service contract-related records must be kept for at least 5 years; after the expiration period, we will adopt anonymization processing or secure deletion methods to ensure that the information is no longer used to identify you personally.

(II) Cross-Border Transfer Rules

Due to the involvement of overseas platform docking in Google Marketing, Facebook Marketing, and Shopify Operations business, your personal information may need to be transferred outside China. We will strictly abide by the following rules:

1. Legality Guarantee: Before cross-border transfer, we will ensure compliance with China's Personal Information Protection Law and the data protection laws and regulations of the receiving country/region overseas; for data transfer to Google/Facebook/Shopify platforms, we will complete it through official open interfaces to ensure encrypted transmission and require the platforms to use the data only within the authorized scope; for cross-border transfer to other third parties, we will sign data processing agreements with the recipients and, if necessary, adopt compliance mechanisms such as data export security assessments and EU Standard Contractual Clauses (SCCs).
2. Notification and Authorization: If your information needs to be transferred cross-border to Google/Facebook/Shopify platforms, we will clearly inform you of the platform name, country/region, type of transferred information, and purpose during service docking, and we will only initiate the transfer after you confirm the authorization; if other overseas third parties are involved, we will separately inform you of the detailed information of the recipient and the purpose of the transfer in advance and obtain your explicit authorization (unless otherwise specified by laws and regulations).

5. Sharing and Disclosure of Personal Information

We promise not to arbitrarily share or disclose your personal information, and will only do so in the following circumstances:

1. With Your Explicit Authorization: Share your advertising demand information and advertising creative materials with Google Ads platforms; share your enterprise qualification information and advertising content with Facebook Ads platforms; share your store operation needs with Shopify platforms; authorize us to share target audience data with third-party data institutions for accurately optimizing ad targeting.
2. Necessary Use by Cooperating Parties: Share advertising placement data with cooperating parties that provide us with Google/Facebook marketing support; share necessary store data with Shopify ecosystem cooperating parties; share device and access data with technical operation and maintenance and data statistics service providers. However, we will require them to use the data only within the agreed scope and adopt security protection measures such as encrypted storage and access permission control.
3. Compliance and Legal Requirements: Disclose your personal information in accordance with the provisions of laws and regulations, or the mandatory requirements of judicial organs or administrative regulatory authorities; if your Google/Facebook ads are at risk of violation or your Shopify store has abnormal orders, disclose necessary information to relevant platforms or regulatory authorities within a reasonable scope to protect your legitimate rights and interests.
4. Enterprise Mergers, Acquisitions, and Restructurings: If we undergo corporate changes such as merger, division, acquisition, or asset transfer, your personal information may be transferred as part of the assets. We will inform you in advance and ensure that the recipient continues to comply with this Privacy Policy.

Note: We will not sell your personal information to any third party unless we obtain your explicit written consent; nor will we use personally identifiable information for unauthorized marketing promotion or data transactions.

6. Security Protection Measures for Personal Information

In response to the data characteristics of intelligent marketing services, we adopt multi-dimensional security measures including technical, management, and physical aspects to ensure the security of your personal information:

1. Technical Protection: Adopt encrypted transmission (HTTPS protocol, end-to-end encryption) to protect the data transmission process. Especially for sensitive information such as Google Ads/Facebook Ads account authorization codes and Shopify API keys, dynamic encrypted storage is adopted; prevent information leakage and tampering through technologies such as hierarchical access permission control, real-time audit of operation logs, and abnormal behavior monitoring; when docking with Google/Facebook/Shopify platforms, only use officially certified API interfaces and update interface keys regularly.
2. Management Specifications: Establish a special data security management system and formulate separate operating procedures for Google/Facebook/Shopify businesses; conduct privacy protection and data compliance training for employees, who can only take up their posts after passing the assessment; sign confidentiality agreements with all employees and cooperating parties who have access to your information, and conduct regular security audits of cooperating parties; conduct regular security vulnerability testing of service systems and data compliance risk assessments.
3. Emergency Response: In the event of a security incident such as personal information leakage, tampering, or loss, we will immediately activate the emergency plan: suspend relevant services, reset sensitive permissions, and trace the source of the incident; within the time limit specified by laws and regulations, inform you of the incident and response suggestions through official website announcements, SMS/email notifications, etc.; if the incident involves Google/Facebook/Shopify platforms, we will synchronously assist you in submitting security appeals to the platforms.

7. Use of Cookies and Similar Technologies

To optimize the official website browsing experience and improve the accuracy of intelligent marketing services, we may use Cookies, Web Beacons, pixel tags (such as Facebook Pixel), Google Tag Manager, and other similar technologies:

1. Purposes of Cookies:
   • Essential Cookies: Help us identify your account identity and record your official website browsing preferences;
   • Marketing Optimization Cookies: Analyze your needs and preferences by recording the types of services you view on the official website to push relevant service recommendations;
   • Third-Party Platform Cookies: Through embedded Google Analytics Cookies and Facebook Pixel, count the source of official website visitors to provide data support for optimizing Google/Facebook advertising placement strategies.
2. Your Control Rights: You can choose to disable or delete Cookies through browser settings, but disabling Cookies may cause some functions to be unavailable; you can manage the collection and use of advertising data related to you through "Privacy Settings" in the Google Ads account backend and "Ad Preferences" in the Facebook account, and manage the collection rules of store visitor data through "Privacy Settings" in the Shopify store backend.
3. Explanation of Third-Party Technologies: The data collection and use rules of technologies such as Google Analytics and Facebook Pixel used on the official website are formulated by the corresponding platforms. We only authorize them to collect official website-related data for marketing effect analysis and shall not be liable for their technical use behaviors. We recommend that you refer to the official explanations of third parties.

8. Your Rights

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

1. Right to Inquiry and Access: You can log in to your official website account and view your account information, Google/Facebook marketing demand records, advertising placement data reports, and Shopify store operation data in the "Personal Center"; if you need to obtain more detailed information, you can apply through customer service channels, and we will provide the inquiry result within 10 working days.
2. Right to Correction and Supplement: If you find errors in your personal information, you can modify it yourself in the "Personal Center" or contact your dedicated operation personnel for assistance in correction; if the information is incomplete, you can supplement the relevant content, and we will update the data in a timely manner.
3. Right to Deletion: You can apply for the deletion of personal information in the following circumstances:
   • ① The collection or use of information violates the agreement of these Terms;
   • ② After the service is terminated, we no longer need to use the information;
   • ③ You withdraw your authorization;
   • ④ You cancel your account.
   After verification, we will delete the relevant information in a timely manner and assist you in applying for the deletion of relevant authorized data from Google/Facebook/Shopify platforms.
4. Right to Withdraw Authorization: You can disable the collection permission of non-necessary information in "Personal Center - Privacy Settings"; contact customer service to withdraw the authorization for Google Ads/Facebook Ads accounts and the operation authorization for Shopify stores; or directly revoke the authorization for us through the official channels of Google/Facebook/Shopify platforms. After withdrawing the authorization, we will no longer collect or use the information based on the authorization, but this will not affect the legality of the information processing activities completed before the withdrawal.
5. Right to Account Cancellation: You can apply for account cancellation through "Personal Center - Account Security" on the official website or by contacting customer service; before cancellation, we will inform you of the impact of cancellation, and we will initiate the cancellation process after your confirmation; after cancellation, we will delete or anonymize your personal information and assist you in terminating the authorization association with Google/Facebook/Shopify platforms.
6. Right to Complaint and Suggestion: If you have questions or objections to the processing of personal information, or believe that your privacy rights and interests have been infringed, you can complain to us through the contact information in Section 11 of these Terms, and we will reply with the processing result within 15 working days.

9. Protection of Minors' Privacy

Our intelligent marketing services are mainly aimed at enterprises and adult users, and we do not actively collect personal information of minors (under 18 years of age in accordance with Chinese law, or the corresponding age group specified in overseas regions). If a minor needs to use the services (such as docking business entrusted by an enterprise), they must, under the guidance of their guardian, provide necessary enterprise authorization information and the guardian's identity information through the guardian, and the guardian must agree to this Privacy Policy.

If we find that we have collected minors' information by mistake, we will delete it immediately and contact the guardian to explain the situation; if it involves minors' relevant data on Google/Facebook/Shopify platforms, we will synchronously assist in the deletion.

10. Update and Notification of Terms

1. Due to changes in laws and regulations (such as updates to overseas platform data policies, adjustments to Google/Facebook/Shopify rules), adjustments to intelligent marketing service functions, or privacy protection needs, we may update this Privacy Policy. The updated Terms will be posted in a prominent position on the official website with a new "Effective Date" marked.
2. If the update of the Terms involves core content (such as the expansion of the scope of information collection related to Google/Facebook/Shopify, changes to cross-border transfer rules, adjustments to your rights), we will inform you 30 days in advance through official website pop-ups, SMS/email notifications, etc.; if you continue to use the services after the update takes effect, it shall be deemed that you agree to the new Terms.

11. Contact Information

If you have any questions about this Privacy Policy, need to exercise your personal information rights, or complain and feedback on privacy-related issues (especially data security issues involving Google Marketing, Facebook Marketing, and Shopify Operations), you can contact us through the following methods:

12. Other Agreements

1. This Privacy Policy is an important part of the official website service terms and has the same legal effect as the service terms. If there is any conflict between the two, this Privacy Policy shall prevail; for matters not stipulated in these Terms, the service terms shall apply. If Google/Facebook/Shopify businesses are involved, the special service agreements signed between us and you (such as the Google Marketing Service Agreement, Shopify Operation Service Agreement) shall also be complied with.
2. If you have any disputes over these Terms, we recommend resolving them through negotiation with us first; if the negotiation fails, either party may file a lawsuit with the people's court with jurisdiction in the location of our company.
3. The definitions of "personal information" and "sensitive personal information" in these Terms refer to the provisions of the Personal Information Protection Law of the People's Republic of China and relevant laws and regulations; if your business involves overseas markets, you must also comply with the data protection-related laws of the target market country/region (such as EU GDPR, U.S. CCPA, Canadian PIPL) and the requirements of third-party platform rules.