Thank you for your interest in CHOUBAO! This PRIVACY POLICY (“Policy”) describes how WILLING BRAND COMPANY LIMITED (“we”, “us” or “our”) collect, use, disclose, and protect your personal information. It also tells you about the rights and choices you have with respect to your personal information, and how you can reach us to get answers to your questions. Please note, our privacy practices are subject to the applicable laws of the places in which we operate. You will see additional region-specific terms that only apply to customers located in those geographic regions, or as required by applicable laws.

When we use the terms “we”, “us”, or “our” in this POLICY, we are referring to WILLING BRAND COMPANY LIMITED. When we use the term “Site” we are referring to choubaochina.com. When we use the term “Service” we are referring to services we provide through this Site.

This POLICY applies to the personal information we collect under the Service. We may provide different or additional privacy statements for certain activities, programs, or products. Additionally, we may offer supplementary "just-in-time" notices that clarify or enhance our privacy practices or provide you with additional choices regarding your personal information.

Our Service may include links to websites and/or applications operated and maintained by third parties. Please note that we do not control the privacy practices of websites or applications that we do not own. We encourage you to review the privacy practices of these third parties.

1. HOW WE COLLECT YOUR PERSONAL INFORMATION

The types of personal information we obtain about you depends on how you interact with our Site and use our Services. The following sections describe the categories and specific types of personal information we collect.

Personal Information You Voluntarily Provide

We may collect the following personal information you provide in connection with our Service:

• Account information including your name, email, verification code, password, delivery address, city, country/region, province, code, phone.
• Customer support information including the information you choose to include in communications with us, such as, complaints; chat logs and support tickets and customer service call recordings, other messages, and other content you send when you communicate with us.

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

Personal Information Automatically Collected By Us

As is true of most digital services, we and our third-party providers collect certain personal information automatically when you visit, interact with, or use our Service:

• We may automatically collect certain information about your interaction with the Services. To do this, we may use cookies, pixels and similar technologies ("Cookies"). The Services may collect information about how you access and use our Site and your account, including version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and your interaction with the Site.

2. HOW WE USE YOUR PERSONAL INFORMATION

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

• Providing the ervices to you. We use your personal information to provide you with the Services to perform our contract with you, including to set up, manage your account and other features and functionalities related to your account. We may also enhance your shopping experience by enabling Shopify to match your account with other Shopify services that you may choose to use. In this case, Shopify will process your information as set forth in its Privacy Policy and Consumer Privacy Policy.
• Communicating with You. We use your personal information to provide you with customer support.
• Service Improvement. We use your personal information to analyze and optimize customer experience and improve Service.
• Complying with applicable laws and regulations.
• Marketing and Advertising. We use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites.
• To enforce our Terms of Use, resolve disputes, carry out our obligations and enforce our rights, protect our business interests and the interests and rights of third parties, and to prevent, investigate or provide notice of fraud or unlawful or criminal activity.
  

3. COOKIES AND SIMILAR ONLINE TRACKING TECHNOLOGIES

Like many websites, we use Cookies on our Site. As the technological infrastructure supporting our website, Shopify deploys various cookies essential for the proper functioning of fundamental features, including but not limited to shopping cart functionality, checkout processes, and user session management.

In addition to cookies provided by the Shopify platform, we implement supplementary cookies to provide/enhance website functionality, analyze user behavior, and deliver personalized experiences. For detailed information regarding all cookies utilized on our website, please refer to our Cookies policy.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

4. HOW WE SHARE PERSONAL INFORMATION

We may share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as described below.

• We may share personal information with our vendors or other third parties who perform services on our behalf (e.g., IT management providers, data analytics providers, customer support providers). 
• We may share personal information with our corporate affiliates, including our parent company, sister companies, and subsidiaries. We will only share your information within our affiliated companies for legitimate and explicit purposes, and only share the information necessary to provide the services, and are bound by the purposes stated in this Policy (which means that these companies will use your personal information in the same way as we can under this Policy, including provide part of the functions of the Site, and supporting users).
• We may transfer any information we collect in the event we sell or transfer all or a portion of our business or assets (including any shares in the company) or any portion or combination of our products, services, businesses and/or assets.  Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, change of control or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this POLICY.
• We may disclose personal information to third parties, such as legal advisors and law enforcement agencies, regulators, other authorities and other third parties for legal reasons if we reasonably believe that such action is necessary:

o in connection with the establishment, exercise, or defense of legal claims;

o to comply with laws or to respond to lawful requests and legal process;

o to protect our rights and property and the rights, personal safety and property of others, including to enforce our agreements and policies;

o to detect, suppress, or prevent fraud; or

o as otherwise required by applicable law.

• With Your Consent: We may share personal information about an individual to certain other third parties or publicly with their consent or direction.

5. YOUR RIGHT

You are able to exercise your following privacy rights by contacting us via contact information in the Contact Us in accordance with the applicable law as well as subject to certain limitations at law, including but limited to:

Right to know, access, correct, and erase your personal information. You may access, correct or update information you provided to us at any time by logging into your account. Prior to changing or correcting your information, we may be required to verify your identity. There may be circumstances which preclude us from providing access to some or all of your information, for example where the information contains references to personal information about an individual other than you or the information is subject to legal or proprietary protections. If there is any other personal information you believe we process that you would like to access, correct or erase, please contact use.

Right of your personal information portability. You may have the right to receive a copy of certain personal information we process about you. This. comprises any personal information we process on the basis of your consent or pursuant to our contract with you (e.g., your address). You may have the right to receive this information in a structured, commonly used and machine-readable format. You may also have the right to request that we transfer or share that personal information to another party (e.g. a third-party service provider or an ecosystem), with certain exceptions. We will provide further information to you about this if you make such a request.

Right to object your personal information. You may have the right to object to our processing of your personal information. To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.

Right to opt-out sales of your personal information. You have the right to direct us not to sell your personal information to third parties. This allows you to exercise control over who has access to your data and how it's used. When you exercise this right, we will cease selling your information upon receiving your request, subject to certain exceptions permitted by applicable privacy laws. 

Right to opt-out targeted advertising or profiling. You may have the right to opt-out targeted advertising (as defined under applicable privacy law) or profiling (as defined under applicable privacy law) if we process your personal data for such use. At present, we will not send you advertisements. If we send you advertisements, you may contact us to change your preference and opt out of receiving such promotional advertisements from us. We may from time to time send you notifications when we consider it necessary to do so (for example, when we temporarily suspend access to the Services for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related notifications, which are not promotional in nature.

Right to Non-Discrimination. You have the right not to receive discriminatory treatment for exercising these rights.

Additionally, in certain circumstances, we may not be able to approve your request (for example, deleting transactional information that we have a legal obligation to retain or to prevent fraud, ensure security, or protect others' privacy).

6. INFORMATION SECURITY AND RETENTION

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.

7. CHILDREN

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13 (or such other age as may be defined as a minor under applicable law). If an individual is under the age of 13, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information, we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

8. CHANGES TO PRIVACY POLICY 

We reserve the right to change this POLICY from time to time in our sole discretion. We will notify you about material changes in the way we treat personal information by adequately informing you via your account, by placing a prominent notice on our website, or through other appropriate communication channels.  It is your responsibility to review this POLICY periodically. All changes shall be effective from the date of publication unless otherwise provided.

9. LANGUAGE

Except as otherwise set out by law, in the event of any inconsistency between the English version and local language version of this POLICY (where applicable), the English version shall prevail.

10. CONTACT US 

If you have any questions or requests in connection with this PRIVACY POLICY or other privacy-related matters, please send an email to support@choubaochina.com.

JURISDICTION - SPECIFIC TERMS

ADDITIONAL NOTICE FOR CALIFORNIA RESIDENTS

This additional notice (“Additional Notice”) for California residents supplements the POLICY . It applies solely to California residents and addresses personal information we collect online and offline.

This Additional Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA/CPRA”).

ADDITIONAL NOTICE FOR CALIFORNIA RESIDENTS

1.  Our collection and use of personal information（“Notice at Collection”）

In the past 12 months, we have collected and used your personal information for various purposes, please refer to the table below, more information that can identify you or can reasonably be associated with you, and does not fall under the scope of the information, please refer to the "How we collect your Personal Information" and "How we use your Personal Information" section of the POLICY.

Category of personal information as set forth in the CCPA	Personal information we collect	Collected From	Disclosed to	Sold or Shared to
Identifies	name, email, verification code, password, delivery address, city, country/region, province, code, phone, IP address	voluntarily provided by you or from records we have about you while providing products or Service	Recipients: · Third-party cloud services provider · Data Analytics provide   Purposes: · Provide the Services to you · Service Improvement	Recipients: ·Advertising partners   Purposes: · For marketing and advertising
Audio, electronic, visual, thermal, olfactory, or similar information	Customer service call recordings	automatically collected	Recipients: · Third-party cloud services    provider Purposes: · Provide the Services to you · Service Improvemen	N/A
Internet or other electronic network activity	version of web browser, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.	voluntarily provided by you and automatically collected.	Recipients: · Third-party cloud services provider · Data Analytics provider · Advertising partners   Purposes: ·Provide the Services to you ·Service Improvement ·Advertising	Recipients: · Advertising partners   Purposes: ·For marketing and advertising
Any information that does not fall in the abovementioned categories	Customer support information including the information you choose to include in communications with us, such as, complaints; chat logs and support tickets and other messages, and other content you send when you communicate with us.	voluntarily provided by you and automatically collected.	Recipients: · Third-party cloud services provider   Purposes: · Advertising	N/A

We may also disclose personal information to third parties at your direction or upon your request, in connection with a corporate business transaction, or to comply with legal or contractual obligations, as described in our POLICY.

We will retain your personal information for the time reasonably necessary to achieve the purposes described in the POLICY, or any other notice provided at the time of data collection, taking into account applicable statutes of limitation and records retention requirements under applicable law, as well as our records retention requirements and policies.

2. PRIVACY NOTICE AT PROCESSING OF SENSITIVE PERSONAL INFORMATION

Currently, we do don't process your "sensitive personal information"(as defined by CCPA/CPRA).

3.PRIVACY NOTICE AT PROCESSING OF CHILDREN'S PERSONAL INFORMATION

We do not knowingly collect or disclose  personal information of residents under 16 years of age. If you believe we have collected personal information from an individual below 16 without parental/guardian consent, or if you are the parent or guardian of such an individual and wish to have their information removed, please contact us through the email address in the “Contact Us” section of the Policy. Upon notification, we will promptly investigate the matter and take appropriate steps to delete any such personal information.

4. YOUR CALIFORNIA PRIVACY RIGHTS

As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):

The Right to Access/Know	You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: · The specific pieces of personal information we have collected about you. · The categories of personal information we have collected about you. · The categories of sources of the personal information. · The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed. · The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and · The business or commercial purposes for collecting or, if applicable, selling the personal information.
The Right to Request Deletion	You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Opt-Out of Personal Information Sales/Sharing	You have the right to direct us not to sell personal information we have collected about you to third parties. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Limit the Use of Sensitive Personal Information	We do not collect your sensitive personal information, therefore we do not respond to your right to limit the use of sensitive personal information.
The Right to Correct	You have right to request that we correct inaccurate personal information that we maintain about you. Once we receive and confirm a verifiable rights request, we will correct your personal information maintained in our records, unless an exemption applies.
The Right to Non-Discrimination	You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
The Right to lodge a complaint	You can contact the local authority regarding any question, concern or complaint you have relating to our processing of your personal information.
The Right to lodge a complaint"Shine the Light" Law	California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83).

 

We aim to fulfil all verified requests within 45 days pursuant to the CCPA/CPRA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay. Where permitted by the CCPA/CPRA, any disclosures will cover only the 12-month period preceding the verifiable rights request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

5. HOW TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS

How To Exercise Your Right

To exercise your righy right, please submit a request to support@choubaochina.com.

Whether the user submits the request himself or as an authorized agent on behalf of the consumer, emailing us at support@choubaochina.com with the subject line, “California Rights Request”.

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. To verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, and/or date of last transaction on our Services.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Notice of Right to Opt-out of Sale/Sharing

The meaning of “sell” and "sharing" under the CCPA is broadly defined and include sharing your information for any economic benefit. Certain activities of our processing may constitute "sale" or "sharing" under CCPA/CPRA. And you have the right, at any time to direct us not to sell/share your personal information by:

• Visiting https://choubaochina.com/pages/ccpa-opt-out ;
• Contacting us via the email address in the Contact Us section of the Policy.

We may ask you to provide additional personal information to properly identify you and track compliance with your opt-out request. We will only use the personal information provided in the opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent that we can identify you in our information systems.

“Do Not Track” Signals

In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. Currently, we do not knowingly permit third parties to collect personal information about an individual’s online activities over time and across different online services, and we do not respond to “do not track” signals.

Additionally, Shine the Light Law permits you the right to opt out of the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. Currently, we do not disclose your personal information to third parties for their direct marketing purposes.