1. Introduction

This Privacy Policy describes how Zhuzhou Sanda Electronic Manufacturing Co., Ltd. ("we", "us", or "SANDA Electronic") collects, uses, discloses, and protects your personal information when you visit our website at www.peltieraircooler.com (the "Site").

We respect your privacy and are committed to protecting your personal data. This policy is drafted in compliance with the Personal Information Protection Law (PIPL) of the People's Republic of China, the Data Security Law (DSL), and the Cybersecurity Law (CSL), as well as applicable international data protection regulations including the GDPR where applicable.

2. Information We Collect

2.1 Personal Information You Provide

When you contact us via the inquiry form, chat widget, or email, we may collect:

• Name — to address you properly
• Email address — to respond to your inquiry
• Phone number (optional) — for direct communication
• Company name (optional) — to understand your business needs
• Message content — the details you provide in your inquiry

2.2 Information Collected Automatically

When you visit our Site, we may automatically collect:

• IP address — for security and analytics purposes
• Browser type and version — to optimize site performance
• Device information — operating system, screen resolution
• Pages visited and time spent — to improve user experience
• Referral source — how you found our website

2.3 Cookies and Similar Technologies

We use the following types of cookies:

• Strictly Necessary Cookies — essential for the website to function properly (e.g., remembering your cookie consent preference). These cannot be disabled.
• Analytics Cookies — help us understand how visitors interact with the website by collecting anonymous information (e.g., Google Analytics). You may opt out of these cookies.
• Functional Cookies — enable enhanced functionality and personalization, such as remembering your form inputs. You may opt out of these cookies.

You can manage your cookie preferences via our Cookie Settings or your browser settings. Please note that disabling certain cookies may affect the functionality of the Site.

2.4 Children's Privacy

Our Site is not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately. If we become aware that we have collected personal information from a child under 16 without parental consent, we will take steps to remove that information from our servers.

3. How We Use Your Information

We process your personal information on the following legal bases under PIPL and other applicable laws:

• Consent — when you voluntarily submit an inquiry form or subscribe to communications
• Contractual Necessity — to respond to your inquiries and provide requested services
• Legitimate Interests — to improve our website, products, and services, and to prevent fraud
• Legal Obligation — to comply with applicable laws and regulations

Specific purposes for which we use your information include:

• Responding to your inquiries and providing customer support
• Processing and fulfilling your requests for product information or quotations
• Sending technical documentation and product catalogs (only with your consent)
• Improving our website functionality and user experience
• Analyzing website traffic and user behavior to optimize our services
• Complying with legal and regulatory requirements

4. How We Share Your Information

We do not sell your personal information to third parties. We may share your information only in the following circumstances:

• Service Providers — we may share information with trusted third-party service providers who assist us in operating our website, conducting our business, or servicing you. These providers are bound by contractual obligations to keep your information confidential and to use it only for the purposes for which it was disclosed.
• Business Transfers — if we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information.
• Legal Requirements — we may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court order, government investigation).

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption — data transmitted between your browser and our servers is encrypted using SSL/TLS protocols
• Access Controls — access to personal data is restricted to authorized personnel only, based on role-based permissions
• Regular Security Assessments — we conduct periodic security reviews and vulnerability assessments
• Employee Training — our staff receives regular training on data protection and privacy best practices

Data Breach Notification: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, affected individuals, in accordance with applicable law (including PIPL Article 57 and GDPR Article 33).

Notwithstanding these measures, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

6. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• Inquiry data — retained for up to 3 years after the last interaction, unless a longer retention period is required by law
• Account data (if applicable) — retained for the duration of the business relationship plus 5 years to comply with statutory limitation periods
• Website analytics data — retained for up to 26 months in anonymized form
• Cookie data — retained according to the cookie type (session cookies are deleted when you close your browser; persistent cookies expire after their specified duration, up to 12 months)

When personal information is no longer needed, we will securely delete or anonymize it in accordance with our data retention policy and applicable legal requirements.

7. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information. To exercise any of these rights, please contact us using the details in Section 10. We will respond to your request within 30 days of receipt, subject to identity verification requirements.

• Right of Access — you have the right to request a copy of the personal information we hold about you
• Right to Rectification — you have the right to request that we correct any inaccurate or incomplete personal information
• Right to Erasure ("Right to be Forgotten") — you have the right to request that we delete your personal information, subject to certain legal exceptions
• Right to Restrict Processing — you have the right to request that we restrict the processing of your personal information under certain circumstances
• Right to Data Portability — you have the right to request that we transfer your personal information to another organization, where technically feasible
• Right to Withdraw Consent — where processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal
• Right to Object — you have the right to object to the processing of your personal information for direct marketing purposes or where processing is based on legitimate interests

Identity Verification: To protect your personal information, we may require you to verify your identity before processing your request. This may involve providing a copy of a government-issued ID and a signed declaration.

If you are not satisfied with our response, you have the right to lodge a complaint with the competent data protection authority in your jurisdiction.

8. International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.

Where we transfer your personal information outside of the People's Republic of China, we ensure that such transfers comply with the cross-border data transfer requirements under PIPL Chapter III, including:

• Conducting a personal information protection impact assessment (PIPIA) before the transfer
• Obtaining your separate consent for the cross-border transfer
• Ensuring that the recipient country has an adequate level of data protection, or that appropriate safeguards (such as standard contractual clauses) are in place
• Complying with any applicable data export security assessment requirements

Where we transfer your personal information outside of the European Economic Area (EEA), we ensure that such transfers comply with GDPR Chapter V, using appropriate safeguards such as the European Commission's Standard Contractual Clauses (SCCs) or an adequacy decision by the European Commission.

9. Third-Party Links

Our Site may contain links to third-party websites, plugins, or applications (e.g., our social media pages on Facebook, LinkedIn, Instagram, YouTube). Clicking on those links may allow the third party to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies, practices, or content.

We encourage you to read the privacy policy of every website you visit. This Privacy Policy does not apply to any third-party websites or services. Your interactions with those websites are subject to their own privacy policies and terms of service.

10. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

We have designated a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any concerns about our use of your personal information, you can contact our DPO at: info@sandacool.com (subject line: "Data Protection Inquiry").

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal or regulatory requirements, or improvements to our services. When we make changes, we will:

• Post the updated policy on this page with a new "Last Updated" date
• Notify you of material changes via email (if you have provided your email address and consented to receiving communications) or through a prominent notice on our Site
• Obtain your fresh consent where required by applicable law (e.g., for material changes to the purposes of processing or types of data collected)

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.