Privacy Policy

DS Technologies Co., Ltd., registered in Dalian (China), operates https://www.exdollus.com/ The website (hereinafter referred to as “the website”) sells products and sends them to customers (hereinafter referred to as “EXDOLL official”). EXDOLL official confirms the importance of maintaining the confidentiality, integrity, and security of your personal data (“personal data”), and hereby informs you of any personal data you provide to EXDOLL official through this website, as well as any personal data you may provide to EXDOLL official online stores, We will handle it in a manner that complies with the current applicable privacy protection laws and local privacy protection laws that may be applicable from time to time. These laws include the European General Data Protection Regulations (EU) 2016/679 (“GDPR”), the Electronic Commerce Law of the People’s Republic of China, and the principles of conduct and general rules contained in the ethical norms adopted by EXDOLL. Please read and confirm that you have fully understood this privacy policy before using the website. By checking ‘I have read and agree to this privacy policy’ and using the website or providing your personal data through the website in any way, you agree to this privacy policy (if the privacy policy is updated on the website and you continue to use the website, services, or provide your personal data, you continue to agree to this updated privacy policy). If you do not agree to any terms of this privacy policy, you should not use the website and should not provide your personal data to the website. Your agreement to the privacy policy indicates that you have understood the basic functions provided by the website and the necessary personal information required for the operation of the basic functions, and have granted corresponding collection and use authorization. However, it does not mean that you have separately agreed to enable additional functions, process unnecessary personal information, and process sensitive personal information, We will separately seek your consent based on your actual usage. This policy applies to the official website of EXDOLL and the various products and services provided to you in new forms with the development of technology. If we and our affiliated companies use official EXDOLL products or services in our products or services, but do not have an independent privacy policy, then this policy also applies to that part of the products or services. This policy will help you understand the following:

1) The types of personal data that EXDOLL can officially collect and use
2) Protection of personal data of minors
3) Possible methods for collecting and using personal data by EXDOLL officials
4) The purpose and legal basis for the official collection and use of personal data by EXDOLL
5) How does EXDOLL officially share, transfer, and publicly disclose your personal data
6) The global transfer of your personal data
7) How EXDOLL Official Protects Your Personal Data
8) Shelf life
9) Data controller, data protection specialist, and contact information
10) Rights of data subjects
11) Revision of this Privacy Policy

1. The types of personal data that EXDOLL can collect and use officially:

“Personal data” refers to various types of information recorded electronically or in combination with other information that can identify the identity of a specific natural person or reflect the activities of a specific natural person. Based on the information you provide or share, personal data may include:

1) Personal identity information and communication information;
2) Network identity identification information (such as account, IP address or email address and its password, ordinary password, and information related to the above);
3) Voice recognition features (such as telephone call recording information);
4) Personal property information (such as transaction records and account balances, bank accounts and coupon information, etc.);
5) Interest and style preferences;
6) Personal hobbies;
7) Personal online records (such as website browsing records, software usage records, click records);
8) Personal shopping records (online or offline);
9) Address book information;
10) Information describing the basic situation of personal commonly used devices (such as hardware model, operating system type, etc.);
11) Personal location information (including trajectory, precise positioning information, accommodation information, longitude and latitude, etc.); In addition, “sensitive personal data” refers to personal data that, once leaked, illegally provided, or abused, may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment, including: address book, personal phone number, mobile phone number, and network browsing history.

2. Protection of personal data of minors

You must be at least 16 years old (or above, depending on the age requirement of your place of residence) in order to provide personal data to EXDOLL official, and at least 18 years old can you purchase products on our website. If you are a minor, you should obtain the prior written consent of your parents or legal guardians before providing personal data. EXDOLL officially protects the personal data of minors in accordance with relevant domestic laws and regulations. For personal data collected by minors with the consent of their parents or legal guardians, EXDOLL officials only use or publicly disclose this information when permitted by law, with the explicit consent of the minors’ parents or guardians, or when necessary to protect children. If it is found that personal data of a minor has been collected without obtaining verifiable parental consent in advance, EXDOLL will officially disable the minor’s account and delete the data as soon as possible.

3. Possible methods for collecting and using personal data by EXDOLL officials

Browse Data

During its normal operation, the computer systems and software programs used to run our website will collect specific personal data (log files). The transmission of such data is inherent in the use of internet communication protocols. The collection of this information is not intended to create a connection with a specific data subject. However, based on its nature, this information can be processed and integrated by third parties to enable users to be identified. This type of information includes the IP address or domain name of the computer used to access our website, the URI of the requested resource (Uniform Resource Identifier), the request time, the method used to submit the request to the server, the size of the document obtained in the response, the status numerical code (success, error, etc.) of the server’s response, and other parameters related to the user’s operating system and computer environment. This data is only used to obtain anonymous statistical information using our website and ensure its correct operation. Cookies Our website uses cookies to ensure their effective operation and improve services. Cookies are small text documents sent by the website you visit to your computer (usually your browser). It is stored on your computer and will be recognized when you visit those web pages in the future. If you would like to learn more about cookies, the types of cookies used by our browser, how to prevent them from being generated, and how to revoke your consent, please refer to our Cookie Policy.

Personal data voluntarily provided by data subjects

EXDOLL officially collects, processes, and uses personal data provided directly and voluntarily through the website under the following circumstances: (1) You place an order online; (2) Register on our website; And/or (3) you use other available features on the website (such as subscribing to our newsletter, sending requests to our customer service, making an appointment at the store, etc.). EXDOLL officials may also collect, process, and use personal data that you may provide by filling out customer cards (hereinafter referred to as “customer cards”) in our store. The items for personal data collection include personal information (title, name, location, birthday), contact and billing details (postal address, billing address, email, phone number), purchase details, and/or other relevant information that you may decide to provide when communicating with our customer service or sales personnel. The phone number is required for verification when you register our account. When processing your online purchase order, contacting you regarding the shipping requirements for the purchased product, and contacting you for marketing purposes when you agree to section 4 (f) below, an address and phone number are also required. If you do not provide the above detailed information, we will be unable to implement the requested service. In addition, when you voluntarily send an email through our website and/or to the address listed on our website, EXDOLL will collect your email address so that you can respond to any requests and also collect any additional personal data included in your information. If the information you provide contains personal information of other users, you need to ensure that you have obtained legal authorization before providing this personal information to the official EXDOLL. If you call our customer service team or contact you with the detailed information you provide, please note that the call may be recorded for quality assurance and training purposes. In addition, EXDOLL officials may also obtain information about you through authentication or identity verification (for example, when you purchase goods online, you may be requested to provide identification documents). EXDOLL officially uses this information to verify your customer identity, process your order, deliver products and services, and/or handle payment matters. Real name authentication: Based on the necessity of realizing transactions related to the sale of goods on this website and other scenarios that require verification of the true identity of users in accordance with the law (including protecting the rights and interests of minors in accordance with the law, cracking down on telecommunications network fraud, withholding and paying personal income tax, and identifying relevant subjects in administrative law enforcement or judicial litigation), you need to conduct real name or real person authentication. To achieve the authentication purpose, you need to proactively provide relevant real identity information (such as name, ID number, or facial recognition information, which may vary depending on the actual situation, according to the page prompts) and authorize us to conduct information verification through a national authoritative and trustworthy identity authentication agency. We will record and save the authentication information and results in accordance with the law, and this information is only used to complete the authentication purpose, For purposes specified by other laws and regulations, without your express authorization, it will not be used for other purposes. The provision of personal data is optional. However, if you wish to send an order to purchase the products provided on our website, and/or register in the EXDOLL official customer database, and/or use any other services provided on the website, you need to fill out all required fields in the relevant form, otherwise EXDOLL official will not be able to continue providing the services required by the contract. You can clearly choose whether to agree with the official collection, processing, and use of your personal data by EXDOLL for the purposes mentioned in Part 4 (c), (d), (e), and (f) above. If you do not agree, you can still place your order online, but we will not be able to continue achieving the stated purposes, including notifying you of any activities that interest you, and/or sending you any other commercial information about EXDOLL’s official products, services, activities, and projects. You will also not be able to access exclusive additional features reserved for registered members that may help you with your shopping experience. Please note that if you agree to process your personal data for the purposes mentioned in Part 4 (d), (e), and (f), after you register with the EXDOLL official customer database, in order to provide you with the same level of service within China, your personal data will automatically be recognized and shared among all EXDOLL official online stores (located within and outside the People’s Republic of China and the European Union). EXDOLL officials will take all appropriate security and confidentiality measures required by applicable laws to ensure compliance with data protection standards. You may withdraw or modify your consent to the processing of your personal data at any time. You may write to the data controller at the communication address listed in Section 9, or use the “logout” link included in all our commercial electronic communications, and/or use any other appropriate program that EXDOLL may provide to you. Please also note that unless you delete your personal data or no longer agree to the official collection of your personal data by EXDOLL, it will be deemed that you have authorized EXDOLL to use all personal data provided by you during the use of the website. Once you cancel your account, the relevant personal data will be deleted or anonymized after fulfilling any obligations or other legal requirements arising from you.

4. The purpose and legal basis for the official collection and use of personal data by EXDOLL

Your personal data may be used for the following purposes: a) to respond to all your requests and manage your official customer relationship with EXDOLL. (For this purpose, you need to provide the following information: address, name, email, phone number, location, language, and detailed information of your request.) b) To fulfill your online purchase order and perform all related management activities (including administrative management of contracts, delivery of goods, processing payment matters, managing any claims and litigation matters, and preventing fraud), as well as to comply with any applicable legal or regulatory obligations. (For this purpose, you need to provide the following information: address, name, email, postal address, billing address, mobile/phone number, location, language, and detailed information of your request.) c) To send newsletters and other marketing information related to EXDOLL’s official products, services, activities, and projects through email after you subscribe to the service. (For this purpose, you only need to provide the following information: email.) In addition, if you agree to register with the EXDOLL official customer database (as a result of your registration on the website or signing a customer card at the EXDOLL official online store), your personal data will be managed by the EXDOLL official and shared with all EXDOLL official online stores worldwide. It may also be processed and used together with detailed information about your online and/or store purchases for the following purposes: d) To confirm your identity as an official registered customer of EXDOLL and provide global customer customization and after-sales services based on this, while also allowing you to obtain exclusive services and benefits reserved for registered members (such as saving shopping order history, faster online checkout, simpler product repair and warranty procedures, commercial discounts, pre-sales, and other promotional activities, etc.). e) Analysis: Conduct individual or group research, surveys, data analysis, and related market research on your preferences for other official EXDOLL brands, products, and services, in order to provide personalized services and promote cultural and entertainment activities based on customer interests. f) Marketing: To contact and/or send you (via email, phone, email, and any other form of electronic or digital communication, including social networking platforms and other instant messaging applications) information and promotions related to other official brands, products, and services of EXDOLL, including commercial nature, newsletters, advertisements, catalogs, and event invitations. For the purposes mentioned in sections (d), (e), and (f), you are required to provide the following information: address, name, location, and (if you register through a website) phone number, email, and password. If you, as a registered member, place a purchase order, your purchase details (including exchanges, refunds, and repairs) will automatically be uploaded from the data saved in your account. If you provide the following additional information, it will help us provide you with better service and experience: date of birth. But if you do not provide this information, it will not affect the basic functions of using this service The processing of personal data related to sections (a), (c), and (d) is necessary for providing the services requested by the data subject. The processing of section (b) is necessary for the execution of contracts or pre contract measures signed with data subjects, as well as for the fulfillment of legal obligations of an administrative or financial nature. In addition, the data processing related to sections (e) and (f) is based on the prior consent of the data subject. If EXDOLL officials use your data for other purposes not covered by this privacy policy, or if information collected for specific purposes is used for other purposes, your explicit consent will be sought in advance. You are fully aware that EXDOLL officials do not need to obtain your consent for the collection, processing, and use of personal data under the following circumstances.

• Related to national security and national defense security;
• Related to public safety, public health, and major public interests;
• Related to criminal investigation, prosecution, trial, and execution of judgments;
• For the purpose of maintaining the life and property of the data subject or other individuals, but it is difficult to obtain the consent of the data subject;
• The collected information has been made public by the data subject;
• Collect information from legitimate and publicly disclosed sources, such as legitimate news reports, government information disclosure, etc;
• Necessary for maintaining the safety and stable operation of the website and provided services, such as repairing the website or services;
• Necessary for legitimate news reporting;
• Other situations stipulated by laws and regulations.

5. How does EXDOLL officially share, transfer, and publicly disclose your personal data

Shared Data

Your personal data will not be used for promotional purposes by third parties unrelated to the official EXDOLL, or for promotional purposes of products, services, or projects by entities other than EXDOLL official members. Meanwhile, your personal data will not be disclosed to unknown individuals under any circumstances. However, other entities may act as data processors on behalf of EXDOLL’s official processing of your personal data when necessary and/or helpful for the above purposes, including companies, consulting firms Business firms (such as service providers, correspondents, IT technicians, companies officially hired by EXDOLL to arrange and/or manage their products or services, etc.) (“service providers”). However, EXDOLL officially only shares necessary personal data, and this sharing is limited to the purpose of this privacy policy statement. In addition, EXDOLL will only share your personal data for legitimate, appropriate, necessary, specific, and clear purposes. The official branches and service providers of EXDOLL are not authorized to use the shared personal data for any other purpose. The official transfer of EXDOLL will not transfer your personal data to any company, organization or individual, except for the following situations: – transfer with explicit consent- In the event of an official merger, acquisition, or bankruptcy liquidation involving personal data transfer, EXDOLL will require new companies or organizations holding your personal data to continue to be bound by this privacy policy. Otherwise, relevant companies, organizations, and individuals should obtain your explicit consent. The official disclosure of EXDOLL will only publicly disclose your personal data in the following circumstances, subject to compliance with safety precautions:

• According to the disclosure method explicitly agreed upon by you, disclose the personal data specified by you according to your needs;
• Your personal data is required by laws, regulations, administrative enforcement, or the judiciary.

Sharing, transferring, and publicly disclosing your personal data does not require your prior consent in the following situations:

• Related to national security and national defense security;
• Related to public safety, public health, and major public interests;
• Related to criminal investigation, prosecution, trial, and execution of judgments;
• For the purpose of maintaining the life and property of the data subject or other individuals, but it is difficult to obtain the consent of the data subject;
• The collected information has been made public by the data subject;
• Collect information from legitimate and publicly disclosed sources, such as legitimate news reports, government information disclosure, etc;

Please note that according to applicable laws, if EXDOLL takes technical and other necessary measures to process personal data, resulting in the anonymization of the data or the removal of personally identifiable information from the data, the sharing, transfer, and disclosure of such anonymous information does not require your notice or consent.

6. The transfer of your data globally

The personal data collected and generated by EXDOLL officially within the territory of the People’s Republic of China will be stored within the territory of the People’s Republic of China. However, due to the official global network of EXDOLL, your personal data may be transferred to foreign countries according to applicable legal procedures, including countries outside the People’s Republic of China and places where EXDOLL’s official use of data benefits from the European Union, by adopting all appropriate security measures to ensure that the appropriate level of data security is achieved.

7. How EXDOLL Official Protects Your Personal Data

EXDOLL has officially used security measures that comply with industry standards to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. For example, when exchanging data between your browser and server, it is protected by SSL protocol encryption; EXDOLL official also provides a secure browsing method for websites using the HTTPS protocol; EXDOLL officially uses encryption technology to enhance the security of personal data; EXDOLL officially uses trusted protection mechanisms to prevent malicious attacks on personal data; And EXDOLL will deploy an access control mechanism to ensure that only authorized personnel can access personal data. Your personal data will be processed through appropriate electronic or automated methods and computer tools, or manually presented on printed text, limited to its collection purpose and ensuring the security and confidentiality of any processed information. Your personal data will only be processed by authorized EXDOLL official internal employees in accordance with their respective job responsibilities. EXDOLL officials will take reasonable and feasible measures to avoid collecting irrelevant personal data. EXDOLL will only retain your personal data for the period necessary to achieve the purpose of this privacy policy (unless otherwise specified by law for mandatory retention periods). The Internet is not an absolutely secure environment. When using the website, please use complex passwords to help EXDOLL official ensure the security of your account. The EXDOLL official will make every effort to ensure the security of any information you send us. If the physical, technical, or management protective facilities of the EXDOLL official are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of the information, and causing damage to your legitimate rights and interests, the EXDOLL official will bear corresponding legal responsibilities. After a personal data security incident occurs, EXDOLL will promptly notify you in accordance with relevant laws and regulations. The notification content should include but not be limited to: the nature and potential impact of the security incident, measures taken or to be taken, suggestions on how to reduce risks, and possible remedial measures for you. EXDOLL will inform you through email, letter, phone call, push notifications, and other means. When it is difficult to inform individual information subjects one by one, EXDOLL will take reasonable and effective measures to publish announcements. At the same time, EXDOLL will also report all personal data security incidents in accordance with regulatory requirements.

8. Retention Period

Your personal data will be processed and stored for the period required for its collection purpose, while meeting the storage period required by applicable laws, or, where applicable, until you revoke your consent to data processing. When the above period ends and there is no legal or commercial purpose for storing your personal data, the data will be automatically permanently erased or anonymized. Specifically, regarding the data processing of registered members in the official customer database of EXDOLL, the retention periods are as follows: personal data collected for the purpose of customer management, providing personalized services and privileges reserved for registered members, will be saved for 7 years from the date of your last interaction with the official customer database of EXDOLL; And the purchase details will be saved for 3 years from the date of purchase.

9. Data controller, data protection specialist, and contact information

To manage and execute your online purchase orders related to sections 4 (a) and (b) above, the data controller is DS Technologies Co., Ltd

Jinpu New Area, Dalian City, Liaoning Province, People’s Republic of China
Email address: [email protected]

For the purpose of data processing in sections 4 (c) to (f) above, the data controller is DS Technologies Co., Ltd

If you wish to exercise your rights or receive any information about your rights and/or this privacy policy, please write to EXDOLL’s official company at the address/email address listed above, contact the data controller or official data protection officer.

10. Rights of data subjects

Please note that you may exercise your following rights in accordance with applicable privacy laws by contacting the data controller listed in section 9 above, including:

• Accessing and correcting your personal data
• Improve or delete your personal data

In the following situations, you can request EXDOLL to delete personal data:

• If EXDOLL’s official processing of personal data violates laws and regulations;
• If EXDOLL officially collects and uses your personal data without your consent;
• If EXDOLL’s official processing of personal data violates the agreement with you;
• If you cancel your official EXDOLL account;
• If EXDOLL officially closes the website.

If EXDOLL approves your deletion request, it will also notify other entities that have obtained your personal data from EXDOLL and require them to delete the relevant data in a timely manner, unless otherwise specified by laws and regulations, or if these entities have obtained your independent authorization. When you delete information from the EXDOLL official service, the EXDOLL official may not immediately delete the corresponding information in the backup system, but will delete it during backup updates. You may withdraw your consent to our processing of your personal data at any time by contacting the data controller listed in section 9 above, or by using any other suitable program that EXDOLL may provide to you. For security reasons, EXDOLL officials may require you to provide a written request or prove your identity through other means. EXDOLL officials will respond to your request within 30 days after receiving your feedback and confirming your identity. Please understand that each business function requires some basic personal data to be completed. When you withdraw your consent, the EXDOLL official will no longer be able to provide you with services corresponding to the withdrawal of consent, and will not process your relevant personal data. However, your decision to withdraw your consent will not affect the personal data processing previously carried out based on your authorization. For your reasonable requests, EXDOLL officials do not charge any fees in principle, but for repeated requests that exceed reasonable limits, EXDOLL officials will charge a certain fee depending on the situation. For requests that are unfounded, require excessive technical means (such as developing new systems or fundamentally changing existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical (such as involving information stored on backup tapes), EXDOLL officials may refuse them. In the following situations, according to legal and regulatory requirements, EXDOLL officials will not be able to respond to your request:

• Related to national security and national defense security;
• Related to public safety, public health, and major public interests;
• Related to criminal investigation, prosecution, and trial;
• There is sufficient evidence to indicate that you have subjective malice or abuse of power;
• Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
• Involving trade secrets.

If you are not satisfied with the official response from EXDOLL, especially if you believe that EXDOLL’s personal data processing behavior has damaged your legitimate rights, you can file a complaint with the competent regulatory authority or seek a solution by filing a lawsuit with the court in the area where EXDOLL’s official company is located, namely the People’s Court of Dalian Economic and Technological Development Zone.

11. Modifications to this Privacy Policy

EXDOLL reserves the right to modify this privacy policy at any time. However, EXDOLL will officially announce any changes to this privacy policy on the website. For major changes, EXDOLL will also provide more prominent notifications (including notifying you through websites or even pop-up reminders). The current effective privacy policy is the version published on our website.

Last update: March 2023