Suzhou CoolCode IoT Technology Co., Ltd. Privacy Policy

1.1 How CoolCode Collects Your Personal Information

Personal information means any information, recorded by electronic or other means, relating to an identified or identifiable natural person, excluding information that has been anonymized. We may collect your personal information when you use CoolCode products and services or interact with us. The specific types of data collected vary depending on the products and services you use and how you interact with us. You are not required to provide personal information to CoolCode; however, in certain cases, if you choose not to provide it, CoolCode may be unable to provide you with the relevant products or services, or to respond to or resolve the issues you encounter. CoolCode will only collect and use your personal information for the purposes stated in this policy.

1.1.1 Information You Provide to CoolCode

(1) Account registration information. When you register an account, we ask you to provide corresponding personal information, including your name, account, password, email, and contact phone number, among others.

(2) Contact and business-lead information. When you contact us through website forms, online consultation, offline events, phone, or email; participate in our marketing activities; subscribe to technical materials; or request a product demo or quote, you may leave your contact information, including your name, company name, job title, industry, email, phone number, and region.

1.1.2 Information Obtained During Your Interaction With Us or Use of Our Products and Services

(1) Device and network information. We collect information about the device you use when accessing CoolCode products and services, such as device type, device name or model, device identifiers, operating system type and version, browser type and version, screen resolution, language settings, IP address, and network service provider, among other technical details that vary by product.

(2) Interaction records. Such information is submitted directly by you when you use our website, products, or services, or interact with us — for example, the information requests you provide, the content of your inquiries, and the questions or information you supply to obtain customer support, as well as communication records generated through online or phone channels, email, and participation in online or offline events. If you use our AI smart assistant, the conversation content (the questions you enter and the session context) will be collected to respond to your inquiries and continuously improve service quality.

(3) Log information. When you use CoolCode products and services or view content provided by CoolCode, CoolCode automatically collects and stores necessary log information, such as the time of each access, the accessed page paths, the client IP address, and event information (such as errors, crashes, restarts, and upgrades).

1.1.3 Third-Party Sources and Public Information

Where permitted by law, we may also obtain relevant data from public or commercial third parties or public sources.

CoolCode may also collect and use non-identifying data (such as aggregated website visit statistics), and will endeavor to segregate personal information from non-identifying data. If personal information is mixed with non-identifying data, it will still be treated as personal information.

1.2 How CoolCode Uses Your Personal Information

(1) Creating an account: providing identity authentication, permission management, and important notifications.

(2) Responding to your interaction requests: responding to inquiries, sending subscribed materials, and arranging demos and business introductions.

(3) Recommending relevant content, products, or services to you: with your consent, sending marketing information, inviting you to events, and providing personalized content.

If you do not wish to receive such information, you may unsubscribe at any time via the SMS prompt or other methods we provide.

(4) Other cases: troubleshooting errors; protecting the security of our products, services, and customers or users, and executing and improving our loss-prevention and anti-fraud programs; and complying with and enforcing applicable legal requirements, relevant industry standards, or our policies.

2.1 Cookies

To ensure the website operates normally, we sometimes store small data files called Cookies on your computer or mobile device. A Cookie is a plain-text file stored by a web server on a computer or mobile device; its content can only be retrieved or read by the server that created it.

With Cookies, a website can save user preferences, such as the language, font size, and other browsing preferences of a computer or mobile device. CoolCode enables Cookies for the same purpose as most websites — to improve user experience. CoolCode will not use Cookies for any purpose beyond those described in this policy. You may manage or delete Cookies according to your preferences; most browsers offer a function to block Cookies, but if you do so, you will need to change your user settings manually on each visit to our website.

2.2 Web Beacons and Pixel Tags

In addition to Cookies, we use other similar technologies such as web beacons and pixel tags on our website. For example, an email sent by CoolCode may contain a click URL linking to CoolCode website content; if you click that link, CoolCode tracks the click to help us understand your product and service preferences and improve customer service. A web beacon is typically a transparent image embedded in a website or email. If you do not wish your activities to be tracked in this way, you may unsubscribe from CoolCode’s mailing list at any time.

Your use of our website means you agree to the use of Cookies, web beacons, and pixel tags as described above.

Generally, CoolCode will not disclose your personal information to outside parties, except in the following circumstances:

1. When certain services are provided by CoolCode’s authorized partners, CoolCode will share your personal information with such partners as described in this policy (for example, entrusting a partner to handle hotlines, send emails, or provide technical support on CoolCode’s behalf), and will require the partner to use your personal information solely to provide services to you on CoolCode’s behalf;
2. We may disclose personal information among CoolCode’s affiliated companies, only for specific, explicit, and legitimate purposes, and only disclosing the information necessary to provide the services;
3. Where required by applicable law or in response to legal process, CoolCode may also disclose your personal information to relevant law-enforcement or other government authorities. In certain jurisdictions, if CoolCode is involved in a reorganization, merger, bankruptcy, or liquidation proceeding, your personal information may also be disclosed to the transacting party;
4. CoolCode may also disclose your data where there is a reasonable need — for example, to perform a contract, or where we believe disclosure is necessary and appropriate to prevent bodily harm or property loss or to investigate possible or actual illegal conduct.

It should be noted: when our smart access control, face-recognition terminals, turnstiles, and other products are deployed at a customer’s site (such as a property manager, enterprise, or campus), the customer typically determines the purposes and means of processing personal information and is the personal information processor, while CoolCode acts as an entrusted processor that processes data only on the customer’s instructions. In such scenarios, the applicable data-processing rules are governed by the customer’s own privacy policy and the data-processing agreement between the customer and CoolCode.

You should ensure that all personal information you submit is accurate. CoolCode will endeavor to maintain the accuracy and completeness of personal information and update it promptly.

Where required by applicable law, you may have the right to: (1) access and copy specific personal information we hold about you; (2) request that we update or correct inaccurate personal information; (3) refuse or restrict our use of your personal information; (4) request that we delete your personal information; and (5) request an explanation of our personal-information processing rules. If you wish to exercise these rights, please contact us as described in Section 11. To safeguard security, you may be required to submit a written request, and we will verify your identity as required by local law. If we have reasonable grounds to believe a request is fraudulent, impracticable, or infringes on the privacy rights of others, we may decline to process it.

Where required by applicable law, when CoolCode processes your personal information based on your consent, you also have the right to withdraw your consent at any time. However, withdrawal of consent will not affect the lawfulness and validity of processing carried out before the withdrawal, nor will it affect our processing of your personal information on the basis of other appropriate legitimate grounds.

CoolCode attaches great importance to the security of personal information. We adopt appropriate physical, administrative, and technical safeguards to protect your personal information against unauthorized access, disclosure, use, modification, damage, or loss. For example, we use encryption to ensure data confidentiality; we deploy protective mechanisms against malicious attacks; we implement access-control mechanisms to ensure only authorized personnel can access personal information; and we conduct security and privacy-protection training to raise employee awareness. We strive to protect your personal information, but please note that no security measure can be perfect.

We will retain your personal information for the period necessary to achieve the purposes described in this policy, unless a longer retention period is required or permitted by law. Criteria for determining the retention period include: the time needed to fulfill the business purpose (including providing products and services, maintaining transaction and business records, controlling and improving product and service performance and quality, ensuring system and service security, and addressing possible user inquiries or complaints and locating problems); whether you have agreed to a longer retention period; and whether laws, contracts, or other requirements impose special data-retention obligations. We will retain your registration information for as long as your account is necessary to provide you with services. You may also choose to close your account; after closure, we will stop providing products and services based on that account and, absent special legal requirements, delete the corresponding personal information or anonymize it.

Local browser drafts: When you fill out forms on our website (such as “Business Inquiry” or “Book a Demo”), to avoid losing your input due to a network interruption or a failed submission, we temporarily cache your draft (including contact details such as name, phone, and email) in your browser’s local storage (localStorage) on your own device. This draft is never uploaded to our servers. It is stored only in the browser you are using, with an automatic cleanup period of 30 days; it is cleared automatically after that period or once the submission succeeds. You can manually delete these drafts at any time by clearing this website’s data in your browser.

Our products, website, and services are primarily intended for adults. Without the consent of a parent or guardian, children (minors under the age of 14) may not create their own user accounts. Where we collect a child’s personal information with parental consent, we will use or disclose such data only to the extent permitted by law, with the explicit consent of a parent or guardian, or as necessary to protect the child. If CoolCode discovers that it has collected a child’s personal information without verifiable prior parental consent, it will seek to delete the relevant data as soon as possible.

To ensure a smooth browsing experience, you may receive content or links from third parties outside CoolCode and its partners (hereinafter "third parties"). CoolCode has no control over such third parties. You may choose whether to access links, content, products, or services provided by third parties.

CoolCode cannot control the privacy and data-protection policies of third parties, and such third parties are not bound by this policy. Before submitting personal information to a third party, please refer to that third party’s privacy policy.

CoolCode is an IoT enterprise focused on the domestic market; your information is primarily stored and processed within mainland China. If, due to future business needs (for example, using cloud services located outside China, or cross-border technical support), a cross-border transfer of personal information occurs, we will strictly comply with the requirements of applicable laws such as the Personal Information Protection Law — fulfilling our legal obligations of notification, separate consent, cross-border security assessment, or the conclusion of standard contracts, and adopting security measures such as encryption and de-identification to ensure the security of your personal information during any cross-border transfer.

CoolCode reserves the right to update or modify this policy from time to time. If our privacy policy changes, we will publish the latest version here. If we make material changes to the privacy policy, we may also notify you of the changes through different channels — for example, by posting a notice on our website or sending you a separate notice.