C&O Fengshui Jewelry (hereinafter referred to as “C&O Fengshui”) respects your concerns about privacy. This Online Privacy Statement describes the types of personal information we collect on www.cofengshui.com (the “Website”) and in our retail stores (the “Stores”), how we use this information, with whom we share it, and the choices available to users of our Website regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.

Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. You can view information specific to the following regions below:

• European Union

• California

Information We Collect

The types of personal information submitted by users of our Website and customers of our Stores include:

• Contact information (such as name, postal address, telephone number, and email address);

• Date of birth and anniversary;

• Website login credentials;

• Payment information (e.g., payment card details); and

• Purchase and transaction information (including serial numbers for watch registrations).

Providing your personal information is purely voluntary. However, if you do not provide your personal information, we may be unable to provide you with our products and services, fulfill your requests, or respond to your inquiries.

Information We Collect by Automated Means

When you use our Website, we may collect certain information by automated means using technologies such as cookies, web server logs, web beacons (including tags and pixels from third parties like Facebook (https://www.facebook.com/about/privacy/)), and JavaScript.

Cookies are files that websites send to your computer or other connected device to uniquely identify your browser or to store information or settings on your device. Our Website may use cookies (e.g., HTTP cookies) and other types of local storage (e.g., browser-based or plugin-based local storage). Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all the features of our Website or other websites and online services.

In addition to collecting information through cookies, our web servers may log information such as your device type, operating system type, browser type, domain name, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Web server logs may also record information such as the address of the web page that referred you to our Website and the IP address of the device you use to connect to the Internet. They may also log information about your interaction with the Website, such as which pages you visit. To control which web servers collect information by automated means, we may place tags called “web beacons” on our web pages, which are small files that link a web page to a specific web server and its cookies. We may also use JavaScript or other computer languages to send instructions to your device to gather the information described above and other details about your interactions with the Website.

Our Website also uses third-party plugins from Instagram, Facebook, Pinterest, TikTok, and YouTube. The providers of these plugins may collect your data by automated means when you interact with them. This information is collected directly by the providers of these plugins and is subject to their respective privacy policies or statements.

We may use third-party web analytics services on our Website, such as Google Analytics. These service providers help us analyze how users use the Website. Information collected for this purpose (including your IP address or other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn more about opting out of these providers’ activities, please click the relevant links below:

• Google Analytics
  Furthermore, this Website uses the following third-party analytical cookies:

• Google Adwords

• Refersion

• Rakuten

How We Use the Information We Collect

We may use the information described above to:

• Provide products and services;

• Create and manage your account;

• Process your payment;

• Send you catalogs and other promotional materials and communicate with you about, and administer your participation in, special events, programs, offers, surveys, and market research, to the extent permitted by applicable law and, where required, with your consent;

• Respond to your inquiries;

• Perform data analyses (including anonymization and aggregation of personal information);

• Operate, evaluate, and improve our business (including developing new products and services; enhancing and improving our products and services; managing our communications; analyzing our products and services; and performing accounting, auditing, and other internal functions);

• Protect against, identify, and prevent fraud and other unlawful activity, claims, and other liabilities; and

• Comply with and enforce applicable legal requirements, relevant industry standards, and our policies.

We also may use the information in other ways for which we provide specific notice at the time of collection.

To the extent permitted by applicable law and, where required, with your consent, we also use information collected through automated means for: (i) customizing users’ visits to our Website; (ii) delivering content (including advertising) tailored to users’ interests and browsing patterns; and (iii) managing our Website and other aspects of our business. To the extent permitted by applicable law, we also may use this information to provide you with advertisements about our products when you browse this and other websites.

Online Tracking

As we engage in remarketing, you may see our advertisements on other websites based on your visit to this Website. For example, if you view a specific product on this Website, you may see an advertisement for that product on a third-party website. Our remarketing campaigns are handled by service providers that track your activities on this Website and on third-party websites using automated means such as cookies. Therefore, to the extent permitted by applicable law, we and our service providers may collect information about our visitors’ online activities over time and across third-party websites. To learn how to opt out of remarketing, please click here.

Our Website is not designed to respond to “do not track” signals from browsers.

Information We Share

We do not sell or otherwise disclose personal information we collect about you, except as described in this Online Privacy Statement. We may share personal information with service providers who perform services on our behalf based on our instructions. These service providers include those providing targeted personalized content, offers, and advertisements; processing credit card payments; and providing web hosting services. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We may also share certain personal information with our affiliates for the purposes described in this Online Privacy Statement. Additionally, to the extent permitted by applicable law and, where required, with your consent, we may share personal information with third parties whose products or services may interest you, or with third-party database providers whose databases may be used by other companies for their own purposes, including marketing. You can choose to block disclosures related to marketing databases. Accordingly, you may object to the use of your personal information in relation to marketing databases or withdraw any consent previously provided to us at any time free of charge, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal.

If you do not wish for your personal information to be used for direct marketing purposes related to marketing databases, or where applicable, if you wish to withdraw any consent previously provided to us, you may contact us as specified in the “How to Contact Us” section of this Online Privacy Statement to request that we opt you out of this use.

Furthermore, we may disclose your information: (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government entities; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Notice to California Residents

Access to Specific Information and Data Portability Rights

You have the right to request that a business disclose certain information to you about its collection and use of your personal information over the past 12 months, subject to certain exceptions defined in the California Consumer Privacy Act (“CCPA”) and other applicable laws and regulations. This right of access includes the following information:

• The categories of personal information we collected about you;

• The categories of sources from which we collected personal information about you;

• The business or commercial purpose for collecting that personal information;

• The categories of third parties with whom we share that personal information;

• The categories of personal information each recipient received; and

• The specific pieces of personal information we collected about you.

Deletion Request Rights

You have the right to request that a business delete any of your personal information that it has collected from you and retained, subject to certain exceptions defined in the CCPA and other applicable laws and regulations.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

• Sending an email to info@cofengshui.com;

A verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. This may include requiring you to provide us with at least two or more pieces of personal information to match against personal information we may or may not maintain and which we have determined to be reliable for verification purposes.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Right to Opt-Out of Sale

You have the right to request that a business stop selling your personal information and refrain from doing so in the future, subject to certain exceptions defined in the California Consumer Privacy Act and other applicable laws and regulations. You may exercise this right by:

• Sending an email to info@cofengshui.com;

We may deny a “Do Not Sell” request if we have a good-faith, reasonable, and documented belief that the request is fraudulent.

Authorized Agent

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, or a person to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465 (an “Authorized Agent”), may make a verifiable consumer request or Do Not Sell request related to your personal information. You may also make a verifiable consumer request or Do Not Sell request on behalf of your minor child.

If you wish to have an Authorized Agent make a request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent, and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.

Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of your CCPA rights. We will not:

• Deny you goods or services;

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

• Provide you a different level or quality of goods or services; or

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

To the extent required by applicable law, California residents may request that we provide them with (i) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. California residents may contact us as specified in the “How to Contact Us” section of this Online Privacy Statement to make this request.

Notice to Nevada Residents

Nevada residents have the right to submit a verified request directing us not to sell their personal information. If you are a Nevada resident and wish to submit such a request, please send it to info@cofengshui.com.

Your Rights and Choices

We offer you certain choices regarding the personal information we collect from you. To update your preferences, ask us to remove your information from our mailing lists, or submit a request, please contact us as specified in the “How to Contact Us” section of this Online Privacy Statement. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, amend, delete, or block such information by contacting us as indicated below. You may withdraw any consent you previously provided to us or object at any time to the processing of your personal information, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal.

Data Transfers

We may transfer the personal information we collect about you to countries other than the country in which the information was originally collected, including to the United States. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Online Privacy Statement.

How We Protect Personal Information

We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide on the Website against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Links to Other Websites

For your convenience and information, our Website may provide links to other websites. These websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly suggest you review. We are not responsible for the content of any linked websites that are not owned or controlled by us, any use of those websites, or the privacy practices of those websites.

Updates to Our Online Privacy Statement

This Online Privacy Statement may be updated periodically to reflect changes in our personal information practices. We will post a prominent notice on our Website to notify you of any significant changes to our Online Privacy Statement, indicating at the top of the notice when it was most recently updated, and/or take any further steps required by applicable law.

Children’s Personal Information

Our Website is designed for a general audience and is not directed to children. We do not knowingly collect or solicit personal information from children under the age of 13 (or the relevant applicable age under respective law) through our Website. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information from our records. If you believe that a child under 13 may have provided us with personal information, please contact us as specified below.

How to Contact Us

If you have any questions or comments about this Online Privacy Statement, wish to exercise your rights, or would like us to update information we have about you or your preferences, please contact our Customer Service by email at info@cofengshui.com. You also may write to:

C&O Fengshui Jewelry
Suite NT-1707, Floor 17, North Tower
Wanyin Twin Center
No. 58 Lishui Road, Gongshu District
Hangzhou, Zhejiang 310015
China
Attn: Customer Support

EU Appendix

If you are a resident of the European Union (“EU”), the following EU-specific provisions apply to our processing of your personal information (i.e., personal data as defined in the General Data Protection Regulation (“GDPR”)) in place of the relevant sections of this Online Privacy Statement:

• We collect the following categories of personal information through this Website: contact information you provide to us; date of birth and anniversary, your login credentials (if you register with us); personal information in the content you provide; and traffic data collected through automated processing (e.g., cookies).

• We process the above information to provide products and services; create and manage your account; send you catalogs and other promotional materials; communicate with you about and administer your participation in special events, programs, offers, surveys, and market research; respond to your inquiries; perform data analyses (including web analytics); operate, evaluate, and improve our business (including developing new products and services; enhancing and improving our products and services; and performing accounting, auditing, and other internal functions); prevent, identify, and prevent fraud and other illegal activities, claims, and other liabilities; comply with and enforce applicable legal requirements, relevant industry standards, and our policies; customize your visits to the Website; and provide content tailored to your interests (including advertising).

• We use the above information based on legitimate business interests, to fulfill a contract with you, to comply with applicable legal obligations, or, where required, based on your consent to the processing, which you can withdraw at any time.

• We will retain your personal information for as long as needed for the purpose for which it was obtained, which generally means for the duration of our relationship or while you keep an account with us, plus a reasonable period taking into account applicable statutes of limitation or to comply with mandatory applicable laws.

• Only authorized personnel of C&O Fengshui, its affiliates, and our service providers will have access to your personal information.

• We do not share your personal information with any third party (e.g., database provider) for the third party to market its products or services to you without your consent.

• We require our service providers to process personal information only according to our instructions and to ensure the security of the information.

• Under the GDPR, you have the right to access your personal information, to have it corrected or deleted, and to restrict or object to the processing of your personal information. You also have the right to receive the personal information you provided to us (based on your consent or on a contract to which you are a party) in a structured, commonly used, and machine-readable format. You have the right to have this information transmitted to other companies, where technically feasible. You also have the right to lodge a complaint with a data protection authority if you are not satisfied with our response.

• To exercise your rights, please contact us by email at: info@cofengshui.com

• We use the following categories of cookies on our Website:

  • o Essential Cookies: These cookies are essential for using and navigating our Website. They help us collect information such as your session ID and other server information to authenticate users.

  • o Functional Cookies: These cookies collect your choices or remember your preferences so we can show you relevant content. They allow us to recognize your location during a browsing session and remember your language.

  • o Analytical Cookies: We use analytical cookies to collect information about how users browse and use our Website, such as which pages they visit, how long they stay on a page, whether a page is displayed correctly or if errors occur. Some of these cookies are provided by third-party analytics providers, including Google Analytics. To learn more about cookies from these third-party providers, please click the link below:

    • Google Analytics

  • If you do not want to allow cookies at all, or only want to allow certain cookies, please see your browser settings. You can withdraw your consent to our use of cookies at any time via your browser settings and delete cookies that have already been set. Your browser’s help menu or the website www.allaboutcookies.org contains comprehensive information about the opt-out process for cookies. Please note, however, that without cookies, you may not be able to use all the features of our Website or other websites and online services.

  • For your convenience, we have provided links below to cookie management instructions for popular web browsers:

    • Internet Explorer

    • Microsoft Edge

    • Google Chrome

    • Safari

    • Mozilla Firefox

  • If you wish to opt out of third-party cookies related to interest-based advertising, please visit http://optout.aboutads.info/ or http://optout.networkadvertising.org/. Please note that opting out does not mean you will no longer receive online advertising. It means that the companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. Opting out of cookies and data collection for one browser, device, or application does not necessarily opt you out for all browsers, devices, or applications.

Personal Data Types Collected by C&O Fengshui

C&O Fengshui obtains consumer personal data in several ways. For instance, C&O Fengshui collects personal data directly from consumers when they visit the C&O Fengshui website.

The types of personal data C&O Fengshui collects directly from consumers include:

• Contact information (such as name, postal address, telephone number, and email address);

• Date of birth;

• Login credentials for the C&O Fengshui website;

• Payment information (e.g., payment card details);

• Purchase and transaction information (including serial numbers for watch registrations); and

• Data collected automatically via the C&O Fengshui website (e.g., IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URL, information on actions taken on the C&O Fengshui website, and dates and times of activity);

C&O Fengshui may also obtain and use consumer personal data in other ways for which C&O Fengshui provides specific notice at the time of collection.

Notice

C&O Fengshui provides information in this policy about its consumer personal data practices, including the types of personal data C&O Fengshui collects, the types of third parties to which C&O Fengshui discloses personal data and the purposes for disclosure, the rights and choices consumers have regarding restricting the use and disclosure of their personal data, and how to contact C&O Fengshui about its practices concerning personal data.

Relevant information also may be found in notices pertaining to specific data processing activities.

Choice

C&O Fengshui generally offers consumers choices regarding whether and how their personal data may be (i) disclosed to third-party controllers or (ii) used for purposes materially different from those for which the information was originally collected or subsequently authorized by the relevant consumer. C&O Fengshui obtains opt-in consent for certain uses and disclosures of sensitive data. Consumers may contact C&O Fengshui as specified below regarding the company’s use or disclosure of their personal data. C&O Fengshui uses personal data only for purposes consistent with the purposes described in this policy, unless C&O Fengshui has provided the consumer with an appropriate choice.

C&O Fengshui shares consumer personal data with its affiliates and subsidiaries. C&O Fengshui may disclose consumer personal data without offering an opportunity to opt out, and C&O Fengshui may be required to disclose personal data (i) to third-party processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. C&O Fengshui also reserves the right to transfer personal data in the event of an audit or the sale or transfer of all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution, or liquidation).

Security

C&O Fengshui takes reasonable and appropriate measures to protect consumer personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal data.

Data Integrity and Purpose Limitation

C&O Fengshui limits the consumer personal data it processes to that which is relevant for the purposes of the particular processing. C&O Fengshui does not process consumer personal data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant consumer. In addition, to the extent necessary for these purposes, C&O Fengshui takes reasonable steps to ensure the personal data the company processes is (i) reliable for its intended use, and (ii) accurate, complete, and current. In this regard, C&O Fengshui relies on its consumers to update and correct the relevant personal data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact C&O Fengshui as specified below to request that C&O Fengshui update or correct relevant personal data.

Pursuant to applicable law, C&O Fengshui retains consumer personal data in a form identifying or making identifiable the relevant consumer only for as long as it serves the purpose(s) for which the personal data was collected or subsequently authorized.

Access

Consumers generally have the right to access their personal data. Accordingly, where appropriate, C&O Fengshui provides consumers with reasonable access to the personal data it maintains about them. C&O Fengshui also provides a reasonable opportunity for consumers to correct, amend, or delete personal data that is inaccurate or has been processed in violation of the Privacy Policy Principles. C&O Fengshui may limit or deny access to personal data where the burden or expense of providing access would be disproportionate to the risks to the consumer’s privacy, or where the rights of persons other than the consumer would be violated. Consumers may request access to their personal data by contacting C&O Fengshui as indicated below.

How to Contact C&O Fengshui

If you have any questions or concerns regarding this policy or C&O Fengshui’s consumer personal data practices, please contact C&O Fengshui:

By writing to:
C&O Fengshui Jewelry
Suite NT-1707, Floor 17, North Tower
Wanyin Twin Center
No. 58 Lishui Road, Gongshu District
Hangzhou, Zhejiang 310015
China
Attn: Customer Support

By email: info@cofengshui.com