Privacy Policy

Thank you for supporting INGCO. In order to protect your personal data when you enjoy using services at INGCO, we draw up this privacy policy.

1. Collection of Personal Data

1.1 Definition of Personal Data

Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data. Personal data does not include data that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you.

Here is a description of the types of personal data we may collect and how we may use it:

1.2 What Personal Data We Collect

Depending on the products and services you choose, we collect or obtain specific kinds of personal data from or about you from the following sources:

(a) Data you provide

We collect the personal data you provide when you register an account to use our products and services or otherwise interact with us, such as when you fill in account information, participate in our surveys or promotional offers, comment about the products, and use our online support or online chat tool or email us.
(b) Data from your devices

Photos / Media / File. After obtaining your permission, photos /media / files access may include the authorization to:
① Read the contents of your USB storage (such as SD card)
② Add contents to your USB storage
③ Format the external storage
④ Install or uninstall external storage
Local storage. We may collect and store information (including personal data) locally on your device by using mechanisms such as website storage (including HTML 5) and application data caches.
Camera. You can upload photos when you comment by online services. In this case, we need to collect images and other information from your device.
Unique application identification numbers. Certain services include a unique application number. These numbers and the related information about your installation (for example, the operating system type and version) may be sent to website when you install or uninstall that services or when that services periodically contacts our servers (such as for the purpose of automatic updates).

(c) Data about purchase. If you place an order, we collect personal data in related with the purchase, including the product information, the transaction number, user name, shipping address and other authentication information, as well as billing and contact details.

(d) Data about Advertising. When you visit our website, we may collect certain device information, including your device and application information, identification numbers, the IP address, operating system type and version, browser type, usage information, diagnostic information, and location information from or about the computers, phones, or other devices on which you install or access our products or services. Where available, our services may use GPS, your IP address, and other technologies to determine the approximate location. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you.

1.3 What is the Source of Your Personal Data

With your prior consent, we collect your personal data:

（a）From you directly as described above, including information generated when you use our services and products;

（b）From your device as described above;

（c）From our partners. They are third parties such as Google, Facebook, Twitter, VK, etc.. when you log in our website through these accounts, we are available to obtain your register information automatically because of these third parties have previously authorized us to collect your information in order to help you log in;

（d）From cookies and similar technologies. When you visit our website, we automatically collect technical information such as your IP address via cookies.

2. How We Use Cookies and Similar Technologies

We use cookies and similar technologies to provide, protect, and improve our products and services, such as by personalizing content, offering and measuring advertisements, understanding user behavior, and providing a safer shopping experience. You can also control the use of cookies on your device, but choosing to disable cookies on your device may limit your ability to use some features on our website and services.

2.1 Definition of "Cookies"

Cookies are small text files that are placed on your device by websites that you are browsing. Cookies allow us to track use, infer browsing preferences, and improve and customize your browsing experience. Cookies are harmless and serve crucial functions for websites. The following describes the categories of cookies

2.2 Types of Cookies

(a) Required cookies These cookies are essential for website functionality, such as visiting our website or making a purchase. These cookies don’t require your consent. If you disable these cookies, we will not be able to fulfill your basic request.

(b) Statistics Cookies. These cookies collect anonymous information on how people use the site and the data is merged with other users to enable us to improve how the site operates. This includes cookies from third-party analytics services which are for the exclusive use of the owner of the website visited. For example we utilize Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve such as navigation, shopping experience and marketing campaigns. Data stored by these cookies never show personal details from which your individual identity can be established. If you disable or opt-out of these cookies, you may not be able to use certain features of our website and services, and it may reduce the support or information that we can provide you.

(c) Preferences Cookies. These cookies allow our site to remember the choices you have made about your preferences, such as what language you prefer, or what your user name and password are so that you can automatically log in and we can provide you with better services and improve the shopping experience. If you reject these cookies, you may feel that the efficiency of browsing the web has decreased.

(d) Marketing Cookies. These cookies track information about your browsing habits in order to recommend advertising more personalized for you. These cookies may remember your online activities and/or across third-party sites or online services, and share them with the third parties such as advertisers. For example, by placing these cookies, you can share pages and content on our website and services through third-party social networking and other websites. But we will only allow third-party cookies placed on our website with your explicit consent. To understand how third parties use cookies, please review their privacy policies. If you reject these cookies, you will also see advertisements that are not much relevant to you, which may affect your shopping experience.

2.3 How to Control Your Cookie Settings

When you first visit the website, we will ask for your consent of cookies through cookie banner. You can select the types of cookies that suit you. Please note that if you choose to reject cookies, your access to certain features may be restricted. You can remove or reject cookies using your browser or device settings. Most web browsers automatically accept cookies, but you can modify your browser setting by visiting the Help section of your browser toolbar or consult your individual browser settings for cookies. For more details, please see the device manufacturer's instructions. Please note that you may need to re-select the cookies on our websites after clearing the cookies cache.

2.4 Other Similar Technologies

DPAPI (Data Protection Application Programming Interface) is a simple cryptographic application programming interface available as a built-in component in Windows 2000 and later versions of Microsoft Windows operating systems. In theory, the Data Protection API can enable symmetric encryption of any kind of data; in practice, its primary use in the Windows operating system is to perform symmetric encryption of asymmetric private keys, using a user or system secret as a significant contribution of entropy. DPAPI can help record and store users’ personal data. Data Cube is a simple application for record and analyze personal data. If you choose to reject cookies, as noted above, you may not be able to use certain features of our website and services.

3. How We Process Your Personal Data

Relying on the following legal bases, we will use your personal data with your explicit consent for the purposes specified in this privacy policy as described below. If you no longer wish to agree above services we provide, please contact us to opt-out or go to My Privacy Center (the entry path is uniformly placed at the bottom of this Privacy Policy).

3.1 Providing, Improving, and Developing Our Products and Services

We may process your Personal Data to provide, improve, and develop our products and services. This includes using personal data for purposes such as helping you get a quick registration on our website, improve the shopping process with satisfying searching function, use convenient payment functions, as well as data analysis, research, and audits. Such processing is based on your prior express consent or our legitimate interest in advertising our products and services.

3.2 Communicating with You

When you contact us, we can use your personal data to communicate with you about your account or transactions, and respond to your requests. Also, we can promptly inform you about our policies and terms as it is changed.

3.3 Optimizing Our Advertisements and Services

Subject to your prior consent, we will use your personal data, including but not limited to browsing behaviors such as search, click, favorite or add to the shopping cart to provide you with high-quality personalized products and services. In particular, you can quickly find the products you need. Also, you can be automatically notified about the promotions and the price reduction of your favorite products by email, in-site letters or other reasonable ways. In addition, we may transfer your personal data after encrypting to third parties for advertising and marketing. As for details of data processing of the third parties that may reach your personal data, please read the following introduction of third parties. You are free to choose whether receive promotion information or not. If you no longer wish to agree above services we provide, you can choose “unsubscribe” to opt out in those e-mails or contact us to help you.

3.4 Third Parties that may Process Your Information

(a) Third parties related to Advertising & Marketing——Google, Facebook, Twitter, Amazon, Pinterest, Trade Tracker, WhatsApp, Messenger, etc.

Information of your behaviors on our website, for example, what products you like to browse, may be transferred to these third parties with your explicit consent. You may receive information on advertising and marketing sent by us and/or selected third parties. We sincerely recommend you to learn about the privacy policy of these third parties. You have the option to opt-out of receiving marketing information from us and/or selected third parties. When you do not want to receive advertisements from us and/or selected third parties any more, you can opt-out by clicking the "unsubscribe" link in any email which you receive, in addition to contacting us or setting your rights in My Privacy Center.

(b) Third parties related to Payment & Delivery——CC avenue, Paypal, Cybersource, Adyen, Dlocal, Stripe, Safecharge, Oceanpayment, etc.

If you make a purchase from us, your payment and delivery information will be necessary. Such information will be transferred to third parties above and processed by them. For instance, if you choose to pay online through “Check out with Paypal”, please note that once you click “Place Order”, you will be linked to the website of Paypal. The personal data that you are asked to provide, including your card number, your billing address and your contact information, will be collected and processed by Paypal instead of INGCO, though our trademark/logo can still be seen on the top left corner on that website. INGCO should not be liable for your data processing by Paypal when you click the button “Check out with Paypal”. We sincerely recommend you to learn about the privacy policy of these third parties and make your choice among different payments cautiously.

(c) Other third parties that may process your information

Our website may contain links to and from the websites of our partner networks, advertisers and other third parties. They may collect and process your personal data if you follow a link to any of these websites. Please note that they have their own privacy policies and we do not share your information with them unless your permission or other legal basis authorize us to do so. Please check these policies before you submit any personal data to these websites. We should not be liable for personal data breach caused by these third-party websites.

3.5 Promoting Safety and Security

Subject to your prior express consent, we may use some technology measures to protect your personal data for helping verify accounts and user normal activities, as well as to promote data safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies. Such processing is based on our legitimate interest in helping ensure the safety of our products and services.

3.6 Data Processed Globally

We provide products and services to customers around the world and your personal data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections descried in this policy. We also sufficiently consider about certain legal frameworks relating the processing of data.

When we provide products and services to customers under assistance of our affiliates, business partners and service providers, your personal data may be processed out of EEA. In such circumstances, we will enter into model contractual clauses, or rely on alternative legal bases such as the Privacy Shield, where applicable, or binding corporate rules that have adopted by our partners or service providers. Appropriate or suitable safeguards, for example, encryption technology, will be provided to ensure security of your information. You have right to obtain copy of those data transferred to a third country. If you need to realize your rights, please contact us.

4. Disclosure of Personal Data

We make certain personal data available to strategic partners that work with us to provide our products and services or help us market to customers. Personal data will only be shared by us with these companies in order to provide or improve our products, services, and advertising; it will not be shared with third parties for their own marketing purposes without your prior express consent.

4.1 Service Providers

We share personal data with companies that provide services on behalf of us, such as website hosting, messaging services, account verification, marketing, sponsoring of sweepstakes, contests, and other promotions, auditing, fulfilling customer orders, data analytics, providing customer service, and conducting customer research and satisfaction surveys. These companies are obligated to protect your data and may be located wherever we operate.

4.2 Corporate Affiliates and Corporate Business Transactions

We may share personal data with affiliated companies and business partners. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.

4.3 Legal Compliance and Security

It may be necessary—by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence—for us to disclose personal data. We may also disclose personal data if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.

4.4 Legal Basis For the Processing of Personal Data from EEA Residents

It may be necessary—by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence—for us to disclose personal data. We may also disclose personal data if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

If you reside within the European Economic Area (EEA), our processing of your personal data will be justified if one of the following conditions is satisfied:

(a) Whenever we obtain your consent;

(b) Whenever the processing of your personal data is necessary for the performance of a contract between you and us or for taking any pre-contractual steps upon your requests;

(c) Where the processing is necessary for us to comply with a legal obligation;

(d) Where the processing is necessary for the purposes of our legitimate interests;

(e) Where the processing is necessary for legal and reasonable causes (under this situation we will specifically explain the details).

5. How We Store Your Personal Data

We take technology measures to make sure your personal data record is complete and accurate, such as cookies and similar technologies. In general, subject to your prior express consent, we may store our processing record of your personal data for ten years.

If you request that your personal data is no longer stored, you can delete certain personal data through My Privacy Center or contact us to delete it for you.

6.Your Rights

6.1 What Is Your Rights

We take reasonable steps to ensure that your personal data is accurate, complete, and secure. Based on protection for your personal data, youhave the following rights to obtain from us:

(a) Confirmation about whether or not your personal data is being processed, and, where that is the case, access to the personal data and information, including but not limited to the purposes of the processing and the categories of personal data concerned.

(b) Update and rectification of your inaccurate personal data concerning. Taking into account the purposes of the processing, you are also free to have incomplete personal data completed, including by means of providing a supplementary statement.

(c) Erasure of your personal data relating to your particular situation. It should be noted that data shared with other users (such as the publication of reviews) will remain visible to the public on the platform, even after deletion of your personal account.

(d) Restriction of the processing, which limits our processing authorities.

(e) reception of the personal data you provide in a structured, commonly used and machine-readable format and to transmit those data to a third party.

(f) Complaint for the processing of personal data if you consider that your rights have not been respected.

You have the right to make your objection on grounds to processing of personal data. You can also at any time:

(a) Withdraw your consent to the collection or processing of your data carried out by us for the purposes of behavioral advertising, browsing analysis and audience measurements by setting your cookies or rights.

(b) Object to the processing of your data for sales prospecting purposes by clicking on the “unsubscribe” link in our promotional emails or newsletter.

(c) Object to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.

This type of personal data is so important to your purchase activities that we strongly recommend you to think twice when you want to delete or object to the processing of these data.

6.2 How to Exercise Your Rights

We provide you with the following paths for setting your rights. You can at any time:

(a) Set your consent of cookies in the cookie banner of the website page, or withdraw your consent using your browser or device settings. For details, please refer to clause 2.3.

(b) Go to the settings for your rights on your own. The setting path is: My Privacy Center, especially your account deletion rights can be exercised in account settings when using IOS version. You can change your choice there if you want to re-enable or turn off a certain permission.

(c) Contact us to raise your request. We will respond to your request within 30 days to deal with your reasonable request. Unless there are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal data that we maintain, we will take our best to set your rights according to your requirements. In addition, please note that your withdrawal of your consent will not affect the processing of personal data relying on your previous consent.

6.3 Influence of Some Rights Settings

There will be some influences if you delete some type of personal data or object some processing of personal data:

(a ) Personal data for providing, improving, and developing our products and services. If this type of data is deleted or objected to be processed, it will be more difficult for us to optimize the website products or services, which will definitely not conducive to improving your experience of using our website.

(b) Personal data that we use to communicate with you. If this type of data is deleted or objected to be processed, we will be unable to contact you. Please make your decisions cautiously.

(c) Personal data to offer and measure targeted advertisements and services. If this type of data is deleted or objected to be processed, you will not receive the latest marketing news and personalized shopping services. The advertisements you receive will not be reduced but randomly recommend to you, which may affect your shopping experience.

(d) Personal data relating to promoting safety and security. If this type of data is deleted or objected to be processed, your account will be strongly threatened that you may not use your account normally.

If you delete your data, we have no obligation to retain your data, and we may delete any or all of your data without liability since then. However, we may retain data related to you if we believe it may be necessary to prevent fraud or future abuse, if required by law, or for legitimate purposes, such as analysis of non-personal data, account recovery, auditing our records, and enforcing our rights and obligations under our agreements.

7. How We Keep Your Personal Data Safe

7.1 We use reasonable technical and administrative security measures designed to safeguard and help prevent unauthorized access to your data, and to correctly use the data we collect. To protect the privacy and the security of your personal data, we may request data from you to enable us to confirm your identity and right to access such data, as well as to search for and provide you with the personal data we maintain.

(a) Technical Security Measures:

We are committed to using technical security measures that meet industry standards to protect your personal data. We will apply encryption technology, de-identification, anonymization and other means to protect your personal data, and we will use trusted protection mechanisms to prevent data from being leaked by malicious attacks. Also, we have built up recovery system to prevent your data from destruction, loss, alteration, unauthorized disclosure caused by automatic technology.

(b) Administrative Security Measures:

INGCO has set up Data Protection Officer (DPO) to provide professional analysis about personal data processing. Access to your personal data is strictly limited to our data controller, data processer, data protection officer who need access to such data to perform their assigned job duties. Whenever you need help directly from our DPO, you are free to inform us of your requirement.

7.2 It is important that you take precautions to protect against unauthorized access to your account credentials, and computer or other devices. To protect your information better, we sincerely recommend you to familiarize yourself with the privacy policy provided by third parties before you login in through your account registered at their websites. If you really mind providing us with your personal data through the previous third-party authorization, you may register a new account at INGCO.

7.3 Please be aware that, despite our best efforts, no security system is impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law. If you notice such kind of personal data breach, please immediately contact us. We will investigate any complaint and notify the individual of the outcome of the investigation within a reasonable period.

8. Protection for Children

Please confirm that when you agree with this privacy policy, your age is at least 16 years old or you have a guardian's authorization. Please immediately contact us if you notice that a child under 16 has provided us with personal data.

9. Changes to this Privacy Statement

From time to time, we may update our Privacy Policy to reflect new or different privacy practices. Under normal circumstances, we will not reduce your rights in accordance with this policy. We will post an updated version on this page when we make material changes to the Privacy Policy. Simultaneously, we will notify you about the modification by sending a notice to your account. There will be an special quick link in your account to offer the full text of the Privacy Policy.

The modification of the Privacy Policy is of great significance to ensure your rights on personal data. Consequently, we sincerely recommend you to check the Privacy Policy available online periodically. Additionally, you are always free to check the Privacy Policy through quick links whenever you need to input your personal data.

10. Contact Us

If you have any questions, comments or suggestions about this Privacy Policy, please click here to contact us.

Email：emtop@emtop.com

Phone: +12​3456

Hours: Mon-Sat 10:00AM - 6:00PM

Address:

Phone: +123456