Content

1. Categories of Personal Data Collected
2. Ways of Personal Data Collection
3. Purposes for Personal Data Processing
4. Cookies and Other Similar Technologies
5. Direct Marketing and Opt-Out
6. Disclosure of Personal Data
7. International Transfer of Personal Data
8. Your Privacy Rights and Choices
9. EEA, Switzerland, and UK Residents Privacy Statement
10. Information Security
11. Retention and Deletion of Personal Data
12. Do Not Track Signals
13. Data Breach Notification
14. Privacy of Children
15. Changes to the Privacy Policy
16. Contact Us

1. Categories of Personal Data Collected

You may access and utilize the Website and Services without disclosing your identity or revealing any information that could personally identify you. However, if you wish to utilize certain features available on the Website, such as making an order or creating an account with us, you may be requested to furnish specific Personal Data. In compliance with applicable laws, the categories of The Personal Data collected and processed by the Company or its authorized agents under this Privacy Policy include the following:

1. Contact Details: This includes your full name (required), email address (required), and optionally, your phone number, company name and job title.
2. Account information: This encompasses your username and password or any other identifiers used to access our online Services (required).
3. Financial Information: This may involve payment details, such as card numbers, along with security codes, passwords, or credentials necessary for online payments through the Website (required).
4. Website-Related Data: This consists of technical data essential for the Website’s functionality, including device type, operating system, browser specifications, IP address, language settings, connection timestamps, location data, security login details, usage data, and aggregated statistical information.
5. Marketing Data: This covers cookie data, clickstream data, browsing history, responses to direct marketing efforts, and preferences related to direct marketing communications (optional).
6. Other Personal Information: This category may include any additional Personal Data you choose to provide when interacting with us, including through social media channels (optional).

We refrain from intentionally collecting or processing your sensitive Personal Data, except under the following circumstances, if applicable:

• When processing is mandated or allowed by applicable laws.
• When processing is essential to establish, exercise, or defend legal claims.
• When we have obtained your explicit consent before processing your sensitive personal data.

While you retain the option to withhold your Personal Data, it’s crucial to acknowledge that doing so might restrict your access to certain features on the Website. Users seeking clarification regarding required information are encouraged to reach out to us for further assistance.

2. Ways of Personal Data Collection

The collection of Personal Data is conducted in accordance with applicable laws and regulations. We gather such data through three primary means, namely:

1. Voluntarily provided by you;
2. Information we receive from third-party sources;
3. Information automatically collected via the Website.

1). We may collect Personal Data voluntarily provided by you in the following circumstances:

• When you sign up and create a client account with us;
• When you make a payment online for the Service;
• When you join our email newsletter;
• When you contact us by calling, sending an email, or submitting the Website form to request a quote or to make general inquiries.

2). We may also receive your Personal Data from third parties

We may acquire information about you from third-party sources, including data providers, business partners, and integration parties, as well as from public sources and methods, such as data accessible through public APIs, public social media posts, and the Internet.

3). We may also collect some Personal Data through automated methods

We and our partners may automatically collect certain Personal Data related to you, your device, and your interactions with our Service. This typically occurs when you visit the Website or utilize any of its features or resources. Below is a detailed breakdown of the types of information we may automatically collect during your use of our Services:

1. Usage Information: We meticulously track user activities associated with the Services they utilize, including their device settings and performance metrics related to Service usage. This includes compiling data on the products or services you view, page response times, instances of download errors, the duration of your visits to our Website pages, your interactions on these pages, their frequency, and any other actions performed on the Website or Services.
2. Log Information: Whenever you interact with our Services, we log various details, such as IP addresses, cookie identifiers, details about operating systems and web browsers (including type, version, and configurations), device identifiers, browser language preferences, access timestamps, and pages accessed.
3. Information Obtained Through Cookies and Similar Technologies: We employ various technologies, including the use of cookies placed on users’ devices, to collect data. To learn more about the types of cookies and other tracking technologies utilized on our Websites, please refer to our “Cookies and Other Similar Technologies” section within this Privacy Policy.

3. Purposes for Personal Data Processing

Our use and processing of your Personal Data are strictly in accordance with applicable laws. Herein, we delineate the purposes for which we utilize your Personal Data:

1. Order Fulfillment: We process your Personal Data to provide the requested services and fulfill orders efficiently.
2. Customer Support and Communication: Personal Data are also utilized for customer support purposes, facilitating communication regarding orders, purchases, or quote inquiries, as well as addressing requests, questions, comments, and feedback.
3. Vendor and Business Partner Management: Your Personal Data is utilized to manage relationships with vendors, suppliers, and other business associates, facilitating communication as required.
4. Newsletter Delivery: With your consent, we may send informative updates, news about EMPDA, new products and services, technical support matters, and exclusive offers.
5. Website Feature Facilitation: Personal Data is used to enable certain Website features, such as collaborative blogs, if opted for.
6. Security Measures: Personal Data assists in maintaining the security and integrity of our Website, systems, servers, and technical infrastructure.
7. Fraud Prevention and Detection: We may employ Personal Data to prevent and identify instances of fraud or other unlawful activities.
8. Administrative Purposes and Business Operations: Your Personal Data is processed for evaluating and enhancing our business operations, managing communication, and conducting financial activities.
9. Legal Compliance: Personal Data may be processed to meet legal obligations, comply with judicial processes or government requests, or assert or defend legal claims.

4. Cookies and Other Similar Technologies

Upon accessing our Website or utilizing our Services, our servers automatically record data transmitted by your web browser. We utilize cookies and similar technologies to enhance your user experience and fortify the security of our Website.

Cookies, essentially small text files, are automatically stored on your device when you visit virtually any website. These files are stored by your internet browser and contain essential insights into your online activities. This information may include details such as your device’s IP address, browser type and version, operating system type and version, language preferences, the webpage you visited immediately before navigating to our Website and Services, the specific pages of our Website and Services that you visit, the duration of your visits to these pages, the content you search for on our Website, access timestamps and dates, and various statistical data.

You have the ability to manage cookies through your web browser settings. It is important to note that if you choose to delete your cookies, certain functionalities of our Services and features of the Website may experience reduced performance or become restricted in accessibility.

5. Direct Marketing and Opt-Out

Periodically, we may reach out to you via email to share information about products or services that could be of interest to you. Rest assured, we are committed to safeguarding the confidentiality of your email address and will refrain from disclosing it to any third parties except as outlined in this Privacy Policy. In some instances, we may engage third-party service providers to facilitate the sending of these emails, as detailed in this Privacy Policy. All email transmissions will adhere to relevant laws and regulations, including the CAN-SPAM Act, which mandates the prominent display of the sender’s identity and clear instructions on how to contact the sender.

If you no longer wish to receive our newsletter or marketing emails, you can easily opt-out by following the unsubscribe instructions provided within these emails or by contacting us directly at info@EMPDA.com.

Please note that even if you choose to unsubscribe from marketing communications, we may still contact you to fulfill your requests, process any orders you initiate, or as necessary or permitted by applicable law.

6. Disclosure of Personal Data

To enable the delivery of specific Services, it may be necessary to share your Personal Data with designated third parties collaborating with us, as well as affiliated entities contributing to the operation of the Website and Services provided to you. Such sharing of Personal Data may occur in the following scenarios:

1. Internal Sharing: We may disclose your Personal Data to individuals within our Company, including our personnel, for the purpose of delivering Services, managing Website operations, or other objectives outlined in this Privacy Policy.

2. External Sharing: Your Personal Data may be shared with external parties outside our Company, including Company agents, manufacturers, business consultants, and other contractors, aligning with Service provision and Website operation objectives specified in this Privacy Policy.

3. Third-Party Vendors: We engage third-party service providers to assist in various aspects of our business operations and Website management. For these purposes, we may share your Personal Data with such service providers. It’s important to note that these service providers are contractually obligated not to utilize or disclose your Personal Data except as required to perform Services on our behalf or in
compliance with legal obligations. Our existing service providers include:

4. Business Transactions: If our business undergoes a sale, merger, or transfer of all or part of its assets, including during reorganization, dissolution, liquidation, or other restructuring, your Personal Data may be disclosed to potential buyers, sellers, or their authorized representatives. Before such disclosure occurs, we take reasonable measures to maintain the security and confidentiality of your Personal Data.

5. Other Legal Disclosures: Your Personal Data may also be disclosed under the following circumstances:

• Legal Claims: When necessary for the establishment, exercise, or defense of legal claims.
• Compliance with Applicable Laws: To the extent required by applicable laws.
• Government and Law Enforcement Requests: In response to lawful requests from government agencies and law enforcement authorities to which we are subject.
• Investigation and Prevention of Unlawful Activity: For the purpose of investigating and/or preventing unlawful activities performed by you or in relation to you.

7. International Transfer of Personal Data

We are headquartered in the China, and unless you expressly agree otherwise, we may utilize processing facilities controlled or operated by our third-party service providers situated in jurisdictions distinct from the one in which your Personal Data was initially collected. These countries may have data protection laws that differ from those in your country of residence. These transfers are essential for the efficient and effective provision of our products and services to you.

By utilizing our Services, you acknowledge that your Personal Data may be stored or transferred to locations outside your jurisdiction for the purposes outlined in this Privacy Policy. If you prefer not to have your Personal Data transferred to other jurisdictions, we kindly request that you refrain from providing your Personal Data or using any part of the Service or Website.

8. Your Privacy Rights and Choices

You have certain rights relating to your Personal Data subject to local data protection laws applicable to you. In certain circumstances, you have the following rights:

Please be aware that the aforementioned rights are not absolute and may be subject to certain exceptions as defined by applicable laws.

To submit a request to exercise any of the rights described above, please contact us using the methods outlined in the “Contact Us” section below.

We will verify your request by either asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your identity, including but not limited to your name, address, transaction history, photo identification, and other details associated with your account.

We are dedicated to promptly attending to your request and will exert reasonable efforts to accomplish this task. Typically, we do not levy a fee for processing or responding to your request, except under exceptional circumstances. Should we be unable to fulfill your request, we will furnish an explanation for the denial.

If you are a resident of the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, please consult our EEA, Switzerland, and UK Residents Privacy Statement below for comprehensive information on your privacy rights under the General Data Protection Regulation (GDPR), the UK GDPR, or the Swiss Federal Data Protection Act (FDPA).

9. EEA, Switzerland, and UK Residents Privacy Statement

This EEA, Switzerland and UK Residents Privacy Statement (hereinafter referred to as the “Statement”) is specifically intended for users located in the European Economic Area (EEA), United Kingdom (UK) and Switzerland whose Personal Data is covered by the General Data Protection Regulation (“GDPR”) Swiss Federal Data Protection Act (“FADP”) or the UK GDPR or UK Data Protection Act (“UK GDPR”) and serves as an additional document to complement our Privacy Policy. In cases where any conflicts arise between our Privacy Policy and this Statement, the provisions outlined in this Statement will take precedence for users situated in the EEA, UK, and Switzerland.

Purposes and Legal Bases of Personal Data Processing

Our procedures regarding the handling of your Personal Data strictly adhere to applicable laws. Herein, we outline the purposes for which we utilize your Personal Data and the legal grounds as defined in relevant data protection legislation.

1. Your Consent: We will process your Personal Data if we have obtained your explicit consent, which you retain the right to withdraw at any time.
2. Contract: We process your Personal Data when necessary to fulfill a contractual obligation with you. For example, if you have established a client account with us and conducted an online payment, we will require your contact information and payment details to complete the transaction. Additionally, we may communicate with you via email to address any inquiries or concerns related to our Service.
3. Compliance with Legal Obligations: In specific situations, we may have a legal obligation that necessitates the processing or retention of your Personal Data.
4. Legitimate Interests: We also process your Personal Data for our legitimate business interests, which may include managing the Website, enhancing and expanding the Service, providing customer support, and identifying unlawful or fraudulent activities, among other legitimate purposes.

By utilizing our Services, you acknowledge that your Personal Data may be stored and transferred to locations outside of the European Economic Area (EEA), United Kingdom (UK), and Switzerland for the purposes outlined in our Privacy Policy. We conduct such transfers in compliance with applicable laws and ensure an adequate level of protection by implementing suitable safeguards. These transfers of Personal Data are carried out to:

1. Countries acknowledged by the European Commission as offering an adequate level of protection.
2. Countries lacking sufficient protection but subject to their transfers being governed by the standard contractual clauses of the European Commission or other appropriate cross-border transfer mechanisms intended to ensure adequate protection.

As a resident of the EEA, UK, or Switzerland, you have specific rights concerning the Personal Data we maintain about you:

1. Right to Access: You have the right to request access to your Personal Data. You are entitled to receive a copy of the Personal Data we hold about you. If applicable, you may also receive a machine-readable copy of your Personal Data.
2. Right to Rectification: You can request the correction of your Personal Data if it is found to be inaccurate. c) Right to Erasure: You may request the deletion of your Personal Data if:
   
   • Your Personal Data is no longer necessary for the purposes for which we collected or processed it.
   • You withdraw your consent (if processing is based on consent and no other legal ground exists).
   • You object to the processing of your Personal Data, and we do not have an overriding legitimate interest for processing.
   • Your Personal Data is unlawfully processed.
   • Your Personal Data must be erased to comply with a legal obligation.
3. Right to Objection: You have the right to object to the processing of your Personal Data. We will honor your request unless we have compelling overriding legitimate reasons for processing or if we need to continue processing your Personal Data for legal claims.
4. Right to Restriction of Processing: You can request the restriction of Personal Data processing if:
   
   • The accuracy of your Personal Data is disputed, and we need time to verify its accuracy.
   • Processing is unlawful, and you oppose the deletion of your Personal Data and request restriction.
   • We no longer need your Personal Data for processing purposes, but you request us to retain it for the purpose of establishing, exercising, or defending legal claims.
   • You have objected to the processing, and we need to verify overriding legitimate grounds.
5. Right to Consent Withdrawal: You have the right to withdraw your previously provided consent for the use of your Personal Data at any time.

EMPDA acts operates as a data controller of your Personal Data because we determine the means and purposes of processing your information when using our Services. To submit a request to exercise any of the rights described herein, please contact us using the methods outlined in the “Contact Us” section below.

To proceed with your request, we may require confirmation of your identity. In the event that the proof of identity you provide does not align with our records, we may request additional verification from you.

Please allow us a period of 30 (thirty) calendar days to respond to your request. Should your request be intricate or involve multiple inquiries, it may necessitate a longer duration for us to provide a response. We will notify you if we anticipate requiring more than 30 (thirty) days to furnish a response. It is important to note that there are no charges associated with obtaining a copy of your Personal Data or exercising your rights. However, a reasonable administrative fee may be applicable if you request additional copies.

10. Information Security

We maintain a secure environment to safeguard the Personal Data you provide, protecting it against unauthorized access, use, or disclosure. To mitigate the risk of unauthorized access, use, alteration, or disclosure of Personal Data under our control and custody, we have implemented reasonable administrative, technical, organizational, and physical safeguards.

While we make diligent efforts to protect our information systems, it’s important to note that no website, mobile application, computer system, or transmission of information over the Internet or any other public network can be guaranteed to be completely secure. Therefore, despite our best efforts, there are inherent security and privacy limitations on the Internet that are beyond our control.

You understand that the security, integrity, and privacy of any information and data exchanged between you and the Website and/or Services cannot be guaranteed. Despite our best efforts, such information and data may potentially be viewed or tampered with during transit by a third party.

Regarding the security measures employed while storing and processing your Personal Data:

1. Physical security procedures: Data is stored in restricted and permanently protected servers. When hard drives are replaced, they are physically destroyed. We have established procedures to control access to restricted server rooms and physical assets.
2. Administrative security procedures: Only a limited number of authorized personnel have access to Personal Data in accordance with internal access controls. Access is granted based on role permissions, limited to allowed business roles.
3. Technical security procedures: We regularly compile a log of security events every month and monitor anomalous changes in files 24 hours a day.

11. Retention and Deletion of Personal Data

We retain your Personal Data for the duration necessary to fulfill the purposes outlined in this Privacy Policy and to adhere to our record-keeping policies unless a longer retention period is required by law. Our record-keeping policies are aligned with applicable laws. Your information will be retained and utilized to the extent necessary to manage your relationship with us, fulfill our legal obligations (such as compliance with tax laws), resolve disputes, enforce our agreements, and as otherwise specified in this Policy.

Upon your request for the deletion of Personal Data, we may utilize aggregated data that includes or is derived from your Personal Data, but such data will not be used in a manner that personally identifies you. Therefore, following the deletion of your Personal Data, your privacy rights, such as the right to access, the right to erasure, the right to rectification, and the right to data portability, cannot be enforced.

12. Do Not Track Signals

Some web browsers offer a “Do Not Track” feature, signaling to visited websites your preference not to have your online activities tracked. It’s essential to distinguish tracking from the use or collection of information associated with a website. Tracking refers explicitly to the gathering of personally identifiable information from individuals who use or visit a website or online service as they navigate various websites over time.

The mechanism through which web browsers transmit the Do Not Track signal is not universally standardized. Therefore, our Website presently lacks the configuration to respond to Do Not Track signals transmitted by your browser.

13. Data Breach Notification

In the event of any compromise to the security of the Website and Services or the unauthorized disclosure of users’ Personal Data resulting from external factors such as security breaches or fraudulent activities, we reserve the right to undertake appropriate actions. These actions may involve conducting investigations, reporting incidents, and cooperating with law enforcement authorities.

If a data breach occurs, we will make reasonable efforts to notify affected individuals if we believe there is a reasonable risk of harm to the user or if such notification is required by applicable law. In such instances, we will utilize the email address we have on record to communicate this information.

14. Privacy of Children

We do not intentionally gather Personal Data from individuals under the age of 13. If you are under 13 years old, kindly refrain from submitting any Personal Data through the Website. We encourage parents and legal guardians to supervise their children’s online activities and ensure adherence to this Privacy Policy by instructing their children not to disclose Personal Data on the Website without authorization. If you suspect that a minor under the age of 18 has furnished us with Personal Data via the Website, please contact us.

Additionally, in specific jurisdictions, individuals must be at least 16 years old to provide consent for the processing of their Personal Data unless consent is granted by a parent or legal guardian.

15. Changes to the Privacy Policy

We reserve the right to amend this Privacy Policy or its terms concerning the collection and processing of Personal Data obtained through the Website and Services. Such modifications will be made at our discretion, and we will notify you of any significant changes. The revised date displayed at the bottom of this page will be updated accordingly to reflect these adjustments. Additionally, we may opt to inform you through alternative methods, such as utilizing the contact details you have provided. Any updated iteration of this Privacy Policy will come into effect immediately upon publication unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Privacy Policy will signify your acceptance of these changes. Nonetheless, we will refrain from processing your Personal Data in a manner significantly different from what was initially disclosed at the time of its collection unless we have obtained your explicit consent.

16. Contact Us

If you desire to contact us for a deeper comprehension of this Privacy Policy or to address any concerns regarding your individual privacy rights and Personal Data outlined herein, please feel free to reach out to us via the following contact information: 1) email us at info@empda.com, or 2) through our Website form available at https://empda.com/contact-us/. Our registered office address is Xuxiang Henan, Mojianshan Village, Ditang Street,Yuyao City,Ningbo City,China.

Date of publication: April 18, 2024