PRIVACY POLICY

INGCO TOOLS and its affiliates (collectively, "INGCO", "we", "us", and "our") respect your privacy. Please read the following to learn more about our Privacy Policy ("this Policy"). This Policy applies to INGCO websites, products, and services that display or provide links to this Policy.

This Policy describes how INGCO processes your personal data, but it may not address all possible data processing scenarios. INGCO may inform you of product or service specific data collection through supplementary policies or notices provided before collection.

This Policy describes:

1) How We Collect & Use Your Personal Data

2) Cookies & Similar Technologies

3) How We Disclose Personal Data

4) How to Access & Control Your Personal Data

5) How We Protect Your Personal Data

6) How We Process Children's Personal Data

7) Third-Party Providers and Their Services

8) Sensitive Information

9) Updates to This Policy

10) How to Contact Us

1.How We Collect & Use Your Personal Data

Personal data means any data that, either on its own or jointly with other data, can be used to identify a natural person. You directly provide us with such data when you use our websites, products, services to interact with us. For example, creating an INGCO account or contacting us for support. We may also obtain data by recording how you interact with our websites, products or services. For example, we may use technologies like cookies or receive use data from software running on your device. As permitted by law, we may also obtain data from public and commercial third-party sources, for example, purchasing statistics from other companies to support our services. The personal data we collect includes name, gender, enterprise name, job position, postal and email addresses, phone number, login information (account and password), photos, and certificate information, etc., depending on how you interact with INGCO, for example, the website you visit or the products and services that you use.

1.1 Personal data: including name, business name, country, city, email address, phone number, login information (account and password), etc., depending on how you interact with INGCO, such as the website you visit or the products and services you use.

We also collect the information you provide to us and the content of messages you send us, such as the query information you provide, or the questions or information you provide for customer service support. If you use the online ordering service, we may also collect your shipping address and order information.

If you use location-related services (such as using your nearest store), we may collect all kinds of information related to the ambiguous or precise location of your device. If you do not agree to provide location information or you have disabled location services on your mobile device, we may ask you to manually select your area, or enter your zip code. Your desktop or mobile device Settings may allow you to disable or block location services, which will prevent our services from accessing your location information. We recommend that you refer to the help information or user manual delivered with your device or browser for relevant instructions. If you choose not to provide this information, we may not provide you with content exclusive to your location, and we and/or our marketing partners may not be able to provide you with applicable personalized services and content.

Log information: information related to your use of certain functions, applications, and websites. Examples include cookies and other identifier technologies, Internet protocol (IP) addresses, network request information, temporary message history, standard system logs, error crash information, log information generated using the service (such as registration time, access time, activity time, etc.).

Before using INGCO’s products or services, you may need to provide personal data. In some cases, you may be able to opt not to disclose your personal data to INGCO. However, not providing INGCO with certain data may mean that we cannot provide you with certain products or services or respond to an issue that you have raised.

We may use your personal data for the following purposes:

1.2 Creating an account.

1.3 Fulfilling your transaction or service requests, including fulfilling orders; delivering. Contacting you with your consent; send to you the information about products and services that you may interested; inviting you to participate in INGCO activities (including promotional activities), market surveys, satisfaction surveys，sending you important notices, such as installation of and updates to operating system or application or sending you marketing information. If you do not want to receive these types of information, you can opt out at any time.

1.4 Providing you with customized user experience and content.

1.5 Qualifying and managing suppliers and business partners, and communicating or working with suppliers and business partners.

1.6 Improving our products and services through internal audit, data analysis and research.

1.7 Analyzing the efficiency of our business operations and evaluating market share.

1.8 Troubleshooting when you send us error reports.

1.9 Ensuring the security of our products, services and customers or users, executing and improving our loss prevention and anti-fraud programs.

1.10 Complying with and enforcing applicable legal requirements, industry standards and our policies.

INGCO may also collect and use non-personally identifiable information (Non-PII). Non-PII is information that cannot be used to identify a particular individual. For example, INGCO will collect statistical data, such as the numbers of visits to its website. We collect this data to understand how users use our websites, products and services so that we can improve our services better. INGCO may collect, use, process, transfer or disclose Non-PII for other purposes at its own discretion.

We will endeavor to isolate your personal data from Non-PII and ensure that the two types of data are used separately. If personal data is combined with Non-PII, it will still be treated as personal data during processing.

INGCO will process your personal data following the requirements of applicable laws on an appropriate legal basis, including:

1)Processing your personal data to fulfill the contract when responding to a transaction or service request;

2)Processing your personal data with your consent;

3)Processing based on the legitimate interests of INGCO or a third party when we use your personal data to contact you, conduct marketing or market surveys, improve our products and services, execute and improve our loss prevention and anti-fraud programs, and other purposes. Legitimate interests include enabling us to more effectively manage and operate our business and provide our products and services; protecting the security of our businesses, systems, products, services, and customers; internal management; complying with internal policies and processes; and other legitimate interests described in this policy;

4)Processing your personal data as necessary to comply with and fulfill legal obligations.

5)If you provide to us your email address, we may use services provided by third-party platforms (such as social networking and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your information for such purposes, please contact us as detailed at “10. How to Contact Us?” below.

2.Cookies & Similar Technologies

We and our service providers use cookies for security purposes, to facilitate navigation; to display information more effectively; to personalize your experience; to tailor email marketing to you based on your use of the Services; to determine return visitors; to keep track of items in your cart and serving tailored ads on other sites, as described below.

We also gather statistical information about the use of the Services in order to continually improve their design and functionality; to improve and better transact business and to understand how Services are used, measure which parts of our Sites are most visited or used, monitoring the number of visitors to our Sites and assist us with resolving questions regarding the Services.

Cookies also allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services and on other sites. We may also use cookies or other technologies in online advertising to track responses to our ads and measure the effectiveness of our advertising.

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 using experience. You can remove or reject cookies using your browser or device settings, but in some cases doing so may affect your ability to use our products 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 do a number of different tasks such as remembering your preferences and chosen items, assisting you to improve your site experience as well as trying to ensure that the adverts or offers you see online are more relevant to you. In and of themselves, cookies are harmless and serve crucial functions for websites. These “cookies” can be divided into 4 types each of which is outlined below.

2.2 Types of Cookies

(a) Strictly Necessary Cookies. These cookies are essential for you to browse our website and use its fundamental services, 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 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 areas 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 websites 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 our 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 websites and services through third-party social networking and other websites. But we will only allow third-party cookies placed on our websites 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 enter 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. Your mobile device may also allow you to control cookies through its settings. For more details, please see the device manufacturer's instructions. It is worth mentioning 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 websites and services.

2.5 Web Beacons and Pixel Tags

In addition to cookies, we may also use other similar technologies on our websites such as web beacons and pixel tags. For example, when you receive an email from INGCO, it may contain a click-through URL that links to a INGCO web page. If you click the link, INGCO will track your visit to help us learn about your preferences for products and services and improve our customer service. A web beacon is a transparent graphic image embedded in a website or in an email. We use pixel tags in emails to find out whether an email has been opened. You can unsubscribe from the INGCO mailing list at any time if you do not want to be tracked in this manner.

By using our website, you consent to the use of cookies, web beacons and pixel tags as described above.

3.How We Disclose 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.

3.1 Third Parties that may process your information

(a) Third parties related to Advertising & Marketing—Google, Facebook, WhatsApp, 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 communications which you receive in addition to contacting us or setting your rights in My Privacy Center.

(b)Third parties related to Payment& Delivery (Online order website)

If you make a purchase on it, your payment and delivery information will be necessary. Such information will be transferred to third parties above and processed by them. It is the third party who collect your purchase info like card number, billing address and contacts rather than INGCO to collect it. And your purchase is under constraint of third party’s privacy policy rather than this Privacy. We should not be liable for personal data breach caused by these third-party websites during and after your actions of Payment& Delivery. We sincerely recommend you to learn about the privacy policy of these third parties and make your choice among different Payment& Delivery 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 processed 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.

3.2 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.

3.3 Legal Compliance and Security

We may be required to disclose personal data in accordance with laws, legal proceedings, litigation and/or requests from public and government agencies in or outside your country of residence. We may also disclose personal data if we determine that disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance.

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

3.4 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.How to Access & Control Your Personal Data

It is your responsibility to ensure that all personal data submitted to INGCO is correct and valid. INGCO is dedicated to maintaining the accuracy and completeness of personal data and keeping the data up-to-date.

To the extent required by applicable law, you may have the right to access certain personal data we maintain about you, request that we update or correct inaccuracies in that data, object or restrict to our use of your personal data, and ask us to delete your personal data from our database. To exercise these rights, please click here to give your feedback online. Your written request may be required for security. We may decline the request if we have reasonable grounds to believe that the request is a fraudulent, unfeasible or may jeopardize the privacy of others.

If allowed by applicable laws, you have the right to withdraw your consent at any time when INGCO processes your personal data based on your consent. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another justification other than your consent.

If you think that the way we process your personal information does not comply with applicable data protection laws, you can contact the relevant competent data protection authority. You can obtain the information for contacting EY data protection authorities for http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

5.How We Protect Your Personal Data

The security of your personal data is important to us. We use appropriate physical, management, and technical measures to protect your personal data from unauthorized access, disclosure, use, modification, damage, or loss. For example, we use cryptographic technologies for data confidentiality, protection mechanisms to prevent attacks, and access control mechanisms to permit only authorized access to your personal data. We also provide training on security and privacy protection for employees to raise their awareness of personal data protection. INGCO is committed to protecting your personal data; however, please note that no security measure is perfect.

We will retain your personal information for no longer than is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law. The data storage period may vary with scenario, product, and service. The standards INGCO uses to determine the retention period are as follows: the time required to retain personal data to fulfill business purposes, including providing products and services; maintaining corresponding transaction and business records; controlling and improving the performance and quality of products and services; ensuring the security of systems, products, and services; handling possible user queries or complaints and locating problems; whether the user agrees to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention; etc. We will maintain your registration information as long as your account is necessary for service provision. You can choose to deregister your account. After you deregister your account, we will stop providing you with products and services through your account and delete your relevant personal data, provided that deletion is not otherwise stipulated by special legal requirements.

6.How We Process Children's Personal Data

Our websites, products and services are primarily intended for adults. A child must not create an INGCO account without the consent of a parent or guardian. If a child's personal data is collected with prior parental consent, we will only use or disclose the data as permitted by law, with the explicit consent of the child's parents or guardians, or when necessary for the protection of the child. If we accidentally collect a child's personal data without verified prior consent from the child's parents, we will attempt to delete the data as soon as possible.

7.International Transfer of Your Personal Data

As a global company, your personal data collected by INGCO may be processed or accessed in the countries/regions where you use our products and services or in other countries/regions where INGCO or its affiliates, subsidiaries, service providers or business partners exist. These jurisdictions may have different data protection laws. In this case, the INGCO will take measures to ensure that the data are processed according to the requirements of this policy and applicable law, including the data subject's personal data from the European Union to the European commission has not yet been admitted that the country or region with enough data protection level, we may use a variety of legal mechanism, such as the European commission approved standard contract terms, Obtain consent from EU data subjects for cross-border transmission, or implement security measures such as anonymization of personal data prior to cross-border data transmission.

8.Sensitive Information

In general, we ask that you do not send or disclose to us, through the Services or otherwise, any sensitive personal information (e.g.

social security numbers, information relating to racial or ethnic origin, political opinions, religious or other beliefs, health, biometric or

genetic characteristics, criminal background, or union membership). If you choose to submit such information to us, or if we request it in the course of investigating a complaint or dispute involving the Services, we collect and process such information in accordance with applicable law.

9.Updates to This Policy

INGCO reserves the right to update or change this Policy at any time. We will release the latest Privacy Policy on this page for any changes. If major changes are made to the Privacy Policy, we may notify you through different channels, for example, posting a notice on our website or sending you direct notification.

10.How to Contact Us

If you have any privacy complaints or issues , please contact INGCO.

DIPL0501 Iron padlock