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隐私政策

PRIVACY POLICY

 
Last Updated: February 8th, 2026
 
This Privacy Policy applies to all users accessing and using the Gemeaning website (the "Platform") operated by Gemeaning ("we", "us", "our"). It sets out our practices for collecting, using, disclosing, storing, and protecting your personal data, and your corresponding rights under applicable data protection laws, including the General Data Protection Regulation (GDPR) (for EU/UK users) and the California Consumer Privacy Act (CCPA/CPRA) (for California users). By using the Platform, you consent to the data processing practices described in this Policy.
 
 

1. INFORMATION COLLECTION AND PROCESSING

 
We only collect personal data that is necessary for the operation of the Platform, transaction fulfillment, and service optimization. No unnecessary personal data will be collected or stored.
 

1.1 Directly Provided Personal Information

 
You voluntarily provide the following information when interacting with the Platform (e.g., placing an order, registering an account, contacting customer support):
 
  • Full legal name
  • Billing and shipping address (including postal code, city, state/country)
  • Valid email address and contact phone number (if provided)
  • Payment details (e.g., cardholder name, payment card number; processed and stored exclusively by third-party payment gateways; we do not store raw payment data.
 
Purpose: To fulfill contractual obligations with you, process and complete your orders, arrange delivery, issue invoices/receipts, and provide timely customer support and order updates.
 

1.2 Automatically Collected Technical and Usage Data

 
We automatically collect limited technical and usage data when you access the Platform via your device, for the sole purpose of optimizing Platform performance and preventing fraud:
 
  • Technical Information: IP address, device model, operating system version, browser type and version, Internet Service Provider (ISP)
  • Usage Data: Pages accessed on the Platform, time spent on each page, clickstream data, and navigation path
  • Location Data: Approximate geographic location derived from IP address (no precise GPS location is collected)
 
Purpose: To conduct legitimate website analytics, detect and prevent fraudulent transactions and unauthorized access, optimize Platform loading speed and user experience, and ensure the stable operation of the Platform.
 

1.3 Marketing and Promotional Information

 
We will only use your email address to send promotional materials, product updates, and exclusive offers with your explicit opt-in consent (e.g., checking a consent box when placing an order or registering). You may withdraw this consent at any time by clicking the unsubscribe link in any marketing email or contacting us directly (see Section 11). Unsubscribing will not affect the delivery of transaction-related emails (e.g., order confirmations, shipping updates).
 
 

2. LEGAL BASIS FOR DATA PROCESSING

 
We process your personal data based on the following lawful grounds under applicable data protection laws, ensuring full compliance with GDPR, CCPA/CPRA, and other regional regulations:
 
  1. Contractual Necessity: Processing data to fulfill our contractual obligations with you (e.g., order processing, delivery arrangement)
  2. Legitimate Business Interests: Processing data for our legitimate interests that do not override your privacy rights (e.g., fraud prevention, Platform optimization, analytics)
  3. Explicit User Consent: Processing data for marketing purposes only after obtaining your explicit opt-in consent
  4. Legal Obligations: Processing data to comply with applicable tax, customs, and other statutory requirements (e.g., retaining order records for tax compliance)
 

2.1 Consent Management and Withdrawal

 
  • You may revoke your consent for marketing data processing at any time by emailing service@gemeaning.com or using the unsubscribe link in marketing communications.
  • Revocation of consent will take effect immediately and will not affect the lawfulness of any data processing conducted before the revocation.
  • For other data processing based on contractual necessity or legal obligations, consent is not required and cannot be withdrawn (as such processing is mandatory for service provision).
 
 

3. DATA DISCLOSURE AND SHARING

 
We do not sell, rent, or lease your personal data to any third parties for commercial purposes. Personal data may only be disclosed or shared in the following limited circumstances, with strict safeguards in place:
 

3.1 Compliance with Legal and Regulatory Obligations

 
We may disclose your personal data if required to do so by applicable law, regulation, court order, or enforceable governmental request (e.g., responding to a subpoena). We will only disclose the minimum amount of data necessary to comply with such requirements.
 

3.2 Authorized Third-Party Service Providers

 
We share your personal data with trusted third-party service providers who act as data processors on our behalf, solely to fulfill the services they provide to us. These providers are bound by written data processing agreements (DPAs) that require them to protect your personal data and comply with applicable data protection laws. Key service providers include:
 
  • Payment processors (e.g., Stripe, PayPal): Process payment transactions and verify payment information
  • Website hosting and analytics providers (e.g., Google Analytics): Host the Platform and conduct anonymous usage analytics
  • Email service providers (e.g., Mailchimp): Deliver transaction and marketing emails (only with your consent)
  • Logistics and delivery providers: Arrange order delivery and provide shipping updates
 
Note: These third-party providers may process your data in jurisdictions outside your country/region, and we ensure all such transfers comply with Section 4 of this Policy.
 

3.3 Protection of Legitimate Rights and Interests

 
We may disclose your personal data to protect the safety, rights, and property of Gemeaning, our users, or third parties (e.g., investigating and preventing fraudulent transactions, responding to security breaches).
 

3.4 Business Transfers

 
In the event of a merger, acquisition, asset sale, or other corporate restructuring of Gemeaning, your personal data may be transferred as part of the business assets. We will notify you of any such transfer via a prominent Platform notice and ensure the transferee complies with this Privacy Policy and applicable data protection laws.
 
 

4. INTERNATIONAL DATA TRANSFERS

 
Your personal data may be transferred to and processed in countries outside your jurisdiction (including the United States, where our core operations are based). We ensure all international data transfers comply with GDPR, CCPA/CPRA, and other applicable laws by implementing the following adequate safeguards:
 
  1. Standard Contractual Clauses (SCCs): We sign EU Commission-approved SCCs with all third-party service providers processing data outside the EU/EEA, which set out binding data protection obligations for the transferee
  2. GDPR Adequacy Decisions: For transfers to jurisdictions recognized by the EU Commission as having an adequate level of data protection
  3. CCPA/CPRA Compliance: For transfers to California users, we ensure all transferees adhere to CCPA/CPRA requirements for data protection and user rights
  4. No Transfers to High-Risk Jurisdictions: We do not transfer personal data to jurisdictions with no adequate data protection safeguards and unregulated data processing practices
 
 

5. DATA SECURITY MEASURES

 
We take industry-leading technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Our security measures are regularly updated to address emerging security threats:
 
  1. Data Transmission Encryption: All personal data transmitted between your device and the Platform is protected by SSL/TLS 1.3 encryption
  2. Data Storage Protection: Stored personal data (excluding payment data, held by third-party gateways) is encrypted with AES-256 encryption; raw payment data is never stored on our server.s
  3. Access Controls: Strict role-based access controls are implemented, with personal data only accessible to authorized Gemeaning personnel who need it for their job functions; all authorized personnel are bound by confidentiality agreements
  4. Regular Security Audits: We conduct periodic independent security audits and vulnerability assessments of our systems and third-party service providers
  5. Data Breach Response: We have a formal data breach response plan in place. In the event of a personal data breach, we will notify affected users and relevant supervisory authorities in accordance with applicable legal timeframes (e.g., 72 hours under GDPR)
 
Note: While we take all reasonable measures to protect your data, no electronic transmission or storage system is 100% secure. You are responsible for keeping your account credentials (if applicable) confidential.
 
 

6. COOKIES AND SIMILAR TRACKING TECHNOLOGIES

 
We use cookies and similar tracking technologies (e.g., web beacons, pixels) on the Platform to enhance your user experience and conduct anonymous analytics. All cookie usage complies with the EU ePrivacy Directive and CCPA/CPRA requirements, with clear user control options.
 

6.1 Types of Cookies Used

 
We only use the following three types of cookies, with no unapproved or malicious tracking technologies:
 
  1. Essential Cookies: Necessary for the basic operation of the Platform (e.g., session cookies to maintain your shopping cart). These cookies cannot be disabled as they are required for core functionality.
  2. Analytical Cookies: Used to collect anonymous usage data (e.g., Google Analytics cookies) to optimize Platform performance and user experience. No personal data is linked to these cookies.
  3. Marketing Cookies: Used to deliver personalized promotional content (e.g., retargeting pixels) only with your explicit opt-in consent. These cookies are disabled by default until you grant consent.
 

6.2 Cookie Management and Control

 
You have full control over your cookie preferences:
 
  1. Cookie Banner: A prominent cookie banner is displayed on your first visit to the Platform, allowing you to accept all, reject non-essential, or customize your cookie preferences
  2. Browser Settings: You may adjust or disable cookies at any time through your web browser's settings (e.g., Chrome, Firefox, Safari). Instructions for managing cookies are available on your browser's official website.
  3. Third-Party Cookie Opt-Out: For third-party marketing cookies, you may also opt out via the Network Advertising Initiative (NAI) or Digital Advertising Alliance (DAA) opt-out pages.
 
Note: Disabling non-essential cookies will not affect the basic operation of the Platform, but may limit some personalized features and analytics. Disabling essential cookies will impair core Platform functionality (e.g., unable to add items to the shopping cart).
 
 

7. CHILDREN'S PRIVACY

 
Our Platform and services are not directed to individuals under the age of 16 (the minimum age under GDPR and most regional data protection laws). We do not knowingly collect, process, or store personal data from children under the age of 16.
 
If we become aware that we have inadvertently collected personal data from a child under 16 without the explicit written consent of a parent or legal guardian, we will immediately delete the data from our servers. If you are a parent/guardian and believe your child has provided personal data to us, please contact us at service@gemeaning.com to request deletion.
 
For California users (CCPA/CPRA), we comply with the California Online Privacy Protection Act (COPPA) for children under the age of 13, with additional safeguards for minor data.
 
 

8. DATA RETENTION

 
We retain your personal data only for the minimum period necessary to fulfill the purposes for which it was collected, and in compliance with applicable tax and statutory retention requirements. Personal data is automatically deleted or anonymized once the retention period expires, with no indefinite storage.
 

8.1 Retention Periods

 
  1. Order and Transaction Data: Retained for 7 years from the date of order completion (to comply with US federal and state tax laws, and international customs requirements)
  2. Marketing Data: Retained only until you withdraw your consent; all marketing data is immediately deleted or suppressed from our mailing lists upon unsubscription
  3. Technical and Usage Data: Retained for 2 years from the last date of your Platform use, then aggregated and anonymized (anonymized data cannot be linked to any individual user and is used for general analytics only)
  4. Customer Support Data: Retained for 1 year from the resolution of your support inquiry, then deleted
  5. Account Data (if applicable): Retained until you request account deletion, then all personal data is permanently deleted within 30 days
 

8.2 Anonymization and Deletion

 
All personal data that is no longer needed is either permanently deleted from our servers or anonymized/ pseudonymized (such that the data can no longer identify you). Anonymized data is not considered personal data under applicable laws and may be used for non-identifiable analytics and Platform optimization.
 
 

9. YOUR DATA PROTECTION RIGHTS

 
Under applicable data protection laws (GDPR for EU/UK users, CCPA/CPRA for California users, and other regional regulations), you have the following enforceable rights regarding your personal data. We will respond to all valid requests free of charge and in accordance with legal timeframes (e.g., 45 days for CCPA, 1 month for GDPR).
 

9.1 Universal Rights (Applicable to All Users)

 
  1. Right to Access: Request a copy of the personal data we hold about you
  2. Right to Correction: Request correction of inaccurate, incomplete, or outdated personal data
  3. Right to Deletion: Request permanent deletion of your personal data (where permitted by law)
  4. Right to Restrict Processing: Request restriction of the processing of your personal data in specific circumstances (e.g., if you contest the accuracy of the data)
  5. Right to Data Portability: Request a copy of your personal data in a structured, machine-readable, and commonly used format (e.g., CSV, JSON) for transfer to another data controller
 

9.2 Additional Rights for EU/UK (GDPR) Users

 
  1. Right to Object: Object to the processing of your personal data for legitimate business interests or marketing purposes
  2. Right to Withdraw Consent: Withdraw your consent for data processing at any time (as set out in Section 2.1)
  3. Right to Lodge a Complaint: Lodge a complaint with your local data protection supervisory authority if you are dissatisfied with our data processing practices.
 

9.3 Additional Rights for California (CCPA/CPRA) Users

 
  1. Right to Opt-Out of Data Sale/Sharing: Request to opt out of the sale or sharing of your personal data (we do not sell personal data, so this right applies to limited third-party sharing)
  2. Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights (e.g., no higher prices or reduced service quality)
  3. Right to Know: Request details about the personal data we collect, use, and disclose about you
 

9.4 How to Exercise Your Rights

 
To submit a valid request, please email us at service@gemeaning.com with the following verification information (to prevent unauthorized access to your data):
 
  • Your full legal name (matching the name used for orders/account registration)
  • Your email address (matching the address used for orders/account registration)
  • A brief description of your request (e.g., "Request for access to personal data", "Request to correct shipping address")
  • For order-related requests: Your order number (if applicable)
 
We may request additional verification information if necessary to confirm your identity. We will not process requests that are incomplete, fraudulent, or unduly burdensome. For California users, you may authorize a third party to submit a request on your behalf (the authorized third party must provide written proof of authorization).
 
 

10. POLICY UPDATES AND NOTIFICATIONS

 
We reserve the right to revise and update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable laws, or Platform operations. All updates will comply with Google Merchant Center (GMC) requirements and regional data protection laws.
 

10.1 Notification of Changes

 
  • Material Changes: For material changes to this Policy (e.g., changes to data collection, sharing, or user rights), we will notify you via:
    1. A prominent banner on the homepage of the Platform (displayed for a minimum of 30 days)
    2. An email notification to all registered account holders and users who have placed orders
     
  • Non-Material Changes: For minor changes (e.g., updates to security measures), we will post the revised Policy on the Platform with the updated "Last Updated" date, and no additional notification is required.
 

10.2 Acceptance of Revised Policy

 
Your continued access to or use of the Platform after the effective date of the revised Policy constitutes your unconditional acceptance of the changes. If you do not agree with the revised Policy, you must immediately cease all use of the Platform, and we will delete your personal data in accordance with Section 8 (upon your request).
 
The revised Policy will apply to all personal data collected before and after the effective date of the changes, except where prohibited by law.
 
 

11. CONTACT INFORMATION

 
For any inquiries, questions, or requests regarding this Privacy Policy, your personal data, or your data protection rights, please contact our Data Protection Officer (DPO) and Privacy Team at:
 
  • Email: service@gemeaning.com
  • Subject Line: Privacy Policy Inquiry / Data Rights Request
 
We will respond to all valid inquiries and requests in accordance with applicable legal timeframes and provide clear and comprehensive answers to your questions. For EU/UK users, we will also cooperate with your local data protection supervisory authority to resolve any disputes related to personal data processing.
 
 
Gemeaning | All Rights Reserved | February 8th, 2026