HONGKONG MOER TECHNOLOGY CO., LIMITED
PRIVACY POLICY
This Privacy Policy explains how HONGKONG MOER TECHNOLOGY CO., LIMITED ("MOER", "we", "us" or "our") collects, uses, stores, discloses and protects personal data when you visit the MOER website on which this Policy is displayed, submit a business inquiry, or otherwise communicate with us through the Site.
Important: The Site is intended for legitimate business-to-business wholesale inquiries concerning age-restricted products. It is not intended for persons under 21, or under any higher minimum age that applies where they live.
This Policy applies to personal data processed through the Site and related communications. For those processing activities, HONGKONG MOER TECHNOLOGY CO., LIMITED is the entity responsible for deciding why and how personal data is processed, unless a different entity is identified at the point of collection.
Regional sections apply only where the relevant law applies to MOER and to the particular personal data or individual. They supplement the general sections of this Policy. If a regional section conflicts with a general section, the regional section controls for the covered processing to the extent required by law.
This Policy does not govern the independent privacy practices of distributors, logistics providers, social-media platforms, payment providers used outside the Site, or other third parties. Their own privacy notices apply to their processing.
Depending on how you use the Site, we may collect the following categories of personal data:
• Identity and professional details, such as your name, job title, employer or business name, and the capacity in which you contact us.
• Contact details, such as business email address, telephone number, country or region, and messaging identifiers that you choose to provide, including WhatsApp or Telegram details.
• Inquiry and commercial information, such as products of interest, estimated quantities, target market, requested specifications, distribution plans, messages, attachments, and records of quotations or negotiations.
• Technical and usage data, such as IP address, browser and device type, operating system, language, referring page, pages viewed, approximate location derived from IP address, timestamps, and diagnostic or security logs.
• Cookie and preference data, such as consent choices, session information, analytics identifiers, and advertising identifiers where these technologies are enabled and permitted.
• Compliance information that may be reasonably required before entering a business relationship, such as business registration details, licensing information, sanctions-screening results, or confirmation that you are authorized to act for your organization.
Please do not submit government identification numbers, health information, payment-card information, or other sensitive personal data through a general inquiry form unless we specifically request it through an appropriate channel.
• Directly from you when you complete a form, request a catalogue or quotation, communicate with us, subscribe to business updates, or provide information during due diligence or negotiations.
• Automatically from your browser or device through server logs, cookies and similar technologies.
• From your organization, business partners, public business registers, trade events, professional networks, or other lawful sources where relevant to a prospective or existing business relationship.
We may use personal data to:
• Receive, assess and respond to wholesale, distribution, OEM/ODM, partnership, support or other business inquiries.
• Provide requested catalogues, specifications, samples, quotations or other pre-contract information.
• Verify business identity, authority, eligibility, licensing and compliance requirements, including sanctions, export-control and fraud checks where appropriate.
• Manage prospective and existing business relationships, keep communication records, and administer contracts entered into outside the Site.
• Operate, maintain, troubleshoot, secure and improve the Site, including detecting misuse, attacks, spam and technical failures.
• Measure Site performance and understand how visitors use the Site, subject to consent where consent is legally required.
• Send business marketing communications about MOER products, trade events or opportunities when permitted by law and consistent with your choices.
• Comply with legal and regulatory obligations, enforce our terms and agreements, establish or defend legal claims, and respond to lawful requests from authorities.
• Complete a corporate transaction, such as a reorganization, financing, merger, acquisition or sale of assets, subject to appropriate safeguards.
Where applicable law requires a legal basis, we rely on one or more of the following:
• Your consent, for example for non-essential cookies or particular marketing communications. You may withdraw consent at any time, without affecting processing that occurred before withdrawal.
• Steps requested by you before entering a contract, or performance of a contract with you or your organization.
• Our legitimate interests or those of a third party, including responding to B2B inquiries, developing business relationships, securing and improving the Site, preventing fraud, and protecting legal rights, provided those interests are not overridden by your rights and interests.
• Compliance with a legal obligation, including recordkeeping, regulatory, sanctions, export-control, tax, fraud-prevention and law-enforcement requirements.
• Establishment, exercise or defence of legal claims, or another basis expressly permitted by applicable law.
We may use basic automation to route inquiries, detect spam, identify security risks or support compliance screening. We do not currently make decisions based solely on automated processing that produce legal effects or similarly significant effects on an individual. If this changes, we will provide any notice, explanation and rights required by applicable law before using such processing.
The Site may use cookies, pixels, local storage and similar technologies. Strictly necessary technologies support core functions such as security, network management, form operation and consent storage. Optional technologies may support preferences, audience measurement, analytics or advertising.
Where required by law, optional technologies will be used only after you make a consent choice. You can use any cookie controls displayed on the Site and can also adjust your browser settings. Blocking some technologies may affect Site functionality. The cookie interface should identify the current vendors, purposes and durations used on the Site and should make rejecting optional cookies as accessible as accepting them where required.
Some analytics or advertising technologies, if enabled, may involve disclosure of online identifiers and browsing activity to third parties and may be treated as a "sale", "sharing" or targeted advertising under certain US state laws. Where applicable, the Site will provide an opt-out mechanism and will recognize browser-based opt-out preference signals, such as Global Privacy Control, when legally required.
We may disclose personal data only as reasonably necessary to the following recipients:
• Service providers that support hosting, content delivery, form handling, email, customer relationship management, analytics, cybersecurity, document storage, professional advice or other business operations. They are permitted to process personal data only for authorized purposes and subject to appropriate obligations.
• Affiliates, manufacturers, brand partners, sales representatives, distributors or logistics providers where necessary to evaluate or fulfil a business request and where lawful.
• Professional advisers, auditors, insurers, banks and counterparties involved in due diligence, legal advice, compliance or a corporate transaction.
• Courts, regulators, law-enforcement bodies and other authorities where disclosure is required by law or reasonably necessary to protect rights, safety, security or the integrity of the Site.
• Another party at your direction or with your consent.
We do not sell personal data for money. We also do not provide personal data to third parties for their own direct marketing unless we have given any notice and obtained any consent required by applicable law. Disclosures involving optional advertising technologies are addressed in Sections 7 and 14.
MOER operates internationally. Personal data may therefore be accessed, stored or processed in Hong Kong and in other countries where our service providers or business partners operate. Those countries may have privacy laws that differ from the laws where you live.
Where applicable law requires safeguards for an international transfer, we will use an appropriate mechanism, such as an adequacy decision, the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, consent where valid, or another lawful transfer basis. We may also carry out transfer risk assessments and apply supplementary safeguards where required. You may contact us for information about safeguards relevant to your personal data, subject to lawful confidentiality restrictions.
We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, including legal, accounting, security and dispute-resolution needs. As a general guide:
• An inquiry that does not lead to an active business relationship is normally retained for up to 24 months after the last meaningful interaction.
• Records connected with an active business relationship, quotation, order or contract may be retained for the relationship and then for up to seven years, or another period required by applicable law or reasonably needed for claims and compliance.
• Security and technical logs are normally retained for up to 12 months, unless a longer period is needed to investigate an incident or comply with law.
• Marketing preference and suppression records may be retained for as long as needed to respect an opt-out request.
Actual retention may be shorter or longer depending on the nature of the data, the sensitivity and risk, operational necessity, legal requirements, and whether information can be securely anonymized.
We use reasonable administrative, technical and organizational measures designed to protect personal data against unauthorized or accidental access, disclosure, alteration, loss, erasure or misuse. These measures may include access controls, secure transmission, system monitoring, backups, staff confidentiality obligations and service-provider review, as appropriate to the risk.
No method of transmission or storage is completely secure. You should use caution when sending confidential information through the internet and should not submit sensitive information through a public inquiry form unless requested.
Depending on where you live and subject to legal conditions and exceptions, you may have the right to:
• Ask whether we process your personal data and request access to it.
• Request correction of inaccurate or incomplete personal data.
• Request deletion or restriction of processing.
• Object to processing based on legitimate interests and object at any time to direct marketing.
• Withdraw consent where processing relies on consent.
• Request a portable copy of certain personal data you provided to us.
• Appeal a refusal to act on a privacy request where applicable US state law provides an appeal right.
• Lodge a complaint with a competent privacy or data-protection authority.
To exercise a right, use the current contact details or Contact Us page published on the Site and clearly describe your request. We may need to verify your identity and authority before acting. We will respond within the period required by applicable law. Authorized agents may submit requests where permitted, but we may request proof of authorization.
You will not be discriminated against for exercising a privacy right. Some rights are not absolute, and we may retain or continue processing information where lawfully permitted, including for legal obligations, security, fraud prevention or legal claims.
This Section 13 applies when the EU General Data Protection Regulation, the UK General Data Protection Regulation or related national data-protection law applies. MOER acts as controller for the Site processing described in this Policy. The purposes and legal bases are described in Sections 4 and 5; recipients in Section 8; international transfers in Section 9; retention in Section 10; and individual rights in Section 12.
• Required information. Fields marked as required on an inquiry form are needed to receive and route the request. If you do not provide them, we may be unable to respond or take requested pre-contract steps. Other fields are optional unless we explain otherwise.
• Legitimate interests. Where we rely on legitimate interests, those interests include responding to genuine B2B inquiries, maintaining business relationships, securing and improving the Site, preventing fraud and protecting legal rights. You may object, and we will assess your circumstances and any compelling lawful grounds.
• Direct marketing. You have an absolute right to object to processing for direct marketing. Electronic marketing and non-essential cookies will also follow applicable ePrivacy and UK PECR consent rules.
• Supervisory complaints. You may complain to the data-protection authority in the EEA country where you live or work or where you believe an infringement occurred. In the UK, you may complain to the Information Commissioner's Office.
• Representatives. If MOER appoints an EEA or UK representative because applicable law requires one, the representative's current contact details will be identified on the Site or its Contact Us page.
• Automated decisions. As stated in Section 6, we do not currently use solely automated decision-making that has legal or similarly significant effects on individuals.
This Section 14 applies only to the extent MOER is subject to a US state comprehensive privacy law, including the California Consumer Privacy Act as amended ("CCPA"), and the relevant information and individual are covered by that law. Terms such as "personal information", "consumer", "sell", "share" and "targeted advertising" have the meanings given by the applicable law.
During the preceding 12 months, we may have collected the following statutory categories, to the extent described in Section 2:
• Identifiers and customer-record information, including name, business contact details, IP address and online identifiers.
• Commercial information, including products of interest, requested quantities, quotations and business communications.
• Internet or other electronic network activity, including pages viewed, referral data, device data and interactions with the Site.
• Approximate geolocation derived from IP address, professional or employment-related information, and communications submitted to us.
• Compliance and due-diligence information reasonably needed for business verification, sanctions, export-control, fraud or legal checks.
The sources of these categories are described in Section 3, the business and commercial purposes in Section 4, and the categories of recipients to whom information may be disclosed for business purposes in Section 8. We retain each category according to Section 10. We do not intentionally collect sensitive personal information through general Site forms and do not use sensitive personal information to infer characteristics about an individual.
We do not sell personal information for monetary consideration. If optional advertising or analytics technology enabled on the Site constitutes sale, sharing or targeted advertising under applicable law, the cookie interface or a clearly labelled privacy choices link will identify that practice and provide the required opt-out. We will process legally recognized opt-out preference signals, including Global Privacy Control, as required. We do not knowingly sell or share personal information of persons under 16. The Site does not offer financial incentives in exchange for personal information.
Subject to applicable exceptions, covered US residents may have the following rights:
• Know or access the personal information collected, used, disclosed, sold or shared, including a portable copy where required.
• Correct inaccurate personal information and delete personal information.
• Opt out of sale, sharing, targeted advertising or qualifying profiling, and limit certain uses or disclosures of sensitive personal information where those rights apply.
• Receive equal service and not be discriminated against for exercising a privacy right.
• Appeal a decision on a request where the applicable state law provides that right.
Submit a request through the current contact details or Contact Us page on the Site and state your US state of residence and the right you wish to exercise. We may verify identity and authority using information reasonably related to the request. An authorized agent may act where permitted, subject to proof of authority and, where allowed, direct confirmation from the consumer. To appeal a denial, reply to the decision and state that you are submitting an appeal. Opt-outs available through the cookie or privacy choices interface do not require account creation.
Where we propose to use personal data for direct marketing, we will provide any notice and obtain any consent required by law, including applicable European ePrivacy, UK PECR and US electronic-marketing requirements. You may opt out at any time, free of charge, by using the unsubscribe method in a message or by contacting us through the Site. We may keep a minimal suppression record so that we can continue to respect your choice.
The Site and the products displayed on it are not directed to anyone under 21, or under any higher minimum legal age applicable in the visitor's location. We do not knowingly collect personal data from such persons. If you believe that an underage person has provided personal data through the Site, contact us so that we can investigate and take appropriate action.
The Site may link to third-party websites, social networks, messaging services or embedded content. We do not control those parties' privacy practices. Review their notices before providing personal data or using their services.
We may update this Policy to reflect changes in the Site, our practices or applicable law. The revised version will be posted on the Site with a new effective or last-updated date. Where required by law, we will provide additional notice or request renewed consent.
For privacy questions, requests or complaints, contact HONGKONG MOER TECHNOLOGY CO., LIMITED using the current contact details or Contact Us page published on the Site. Please include "Privacy Request" in the subject or first line of your message and identify the country or region in which you are located so that we can route the request appropriately.
Effective Date: 20 July 2026
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