Privacy Policy

1) Introduction and Contact Details of the Controller

1.1 We are pleased that you are visiting our website and thank you for your interest. Below we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.

1.2 The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Hunan Harzman Techno Co., Ltd, China (Hunan) Free Trade Zone Area, Changsha, Tel.: +86 136 9179 5963, Email: xiaoshu.li [at] xugor.com. The controller responsible for the processing of personal data is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data.

2) Data Collection When Visiting Our Website

2.1 When using our website for informational purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to the page server (so-called "server log files"). When you access our website, we collect the following data that is technically necessary for us to display the website to you:

Our visited website
Date and time at the time of access
Amount of data sent in bytes
Source/reference from which you reached the page
Browser used
Operating system used
IP address used (if applicable: in anonymized form)

The processing is carried out in accordance with Art. 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to subsequently check the server log files if there are concrete indications of unlawful use.

2.2 For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to us), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the string "https://" and the lock symbol in your browser line.

3) Cookies, Google Analytics and Google Ads (only with consent)

3.1 We use technically necessary cookies on our website to ensure its operation. The legal basis is our legitimate interest in a functioning website pursuant to Art. 6 (1) lit. f GDPR.

3.2 In addition, we use services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") – exclusively if you have given us your consent via the cookie banner.

3.2.1 Google Analytics: Google Analytics uses cookies that enable an analysis of your use of the website. The information generated about the use of this website (including the shortened IP address) is usually transmitted to a Google server and stored there. The transmitted IP address is not merged with other Google data.

3.2.2 Google Ads (conversion tracking and remarketing): If you have consented, we use Google Ads to measure the effectiveness of our advertisements and to show you interest-based advertising. In doing so, cookies may record whether you reached our website via an advertisement and which actions you subsequently took.

3.3 The legal basis for the processing mentioned under 3.2 is exclusively your consent pursuant to Art. 6 (1) lit. a GDPR. Consent is voluntary and can be withdrawn or adjusted at any time with effect for the future. If no consent is given, no analysis or marketing cookies are set; the website remains fully usable.

4) Data processing outside the European Union (China)

4.1 Our company is based in the People's Republic of China. If you contact us via the contact form or by e-mail, your details are processed on servers or in mailboxes that may also be located in the People's Republic of China.

4.2 There is no adequacy decision of the European Commission for the People's Republic of China. The level of data protection there is not comparable to the GDPR, and Chinese authorities may under certain circumstances access personal data. As suitable safeguards within the meaning of Art. 44 et seq. GDPR, we agree standard data protection clauses with our service providers where possible and limit processing to what is necessary to handle your enquiry.

4.3 Processing takes place exclusively for the purpose of handling your enquiry as well as for the initiation and performance of a contract. The legal bases are Art. 6 (1) lit. b GDPR and your consent pursuant to Art. 6 (1) lit. a GDPR. By submitting your data to us, you consent to processing in the People's Republic of China.

5) Contacting Us

When contacting us (e.g. via contact form or email), personal data is collected. Which data is collected when using a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. The legal basis for processing this data is our legitimate interest in responding to your request in accordance with Art. 6(1)(f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6(1)(b) GDPR. Your data will be deleted after final processing of your inquiry. This is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

6) Rights of the Data Subject

6.1 The applicable data protection law grants you the following data subject rights (rights of access and intervention) vis-à-vis us as the controller with regard to the processing of your personal data, whereby reference is made to the stated legal basis for the respective exercise requirements:

Right of access pursuant to Art. 15 GDPR;
Right to rectification pursuant to Art. 16 GDPR;
Right to erasure pursuant to Art. 17 GDPR;
Right to restriction of processing pursuant to Art. 18 GDPR;
Right to notification pursuant to Art. 19 GDPR;
Right to data portability pursuant to Art. 20 GDPR;
Right to withdraw consent pursuant to Art. 7(3) GDPR;
Right to lodge a complaint pursuant to Art. 77 GDPR.

6.2 RIGHT TO OBJECT

IF WE PROCESS YOUR PERSONAL DATA IN THE CONTEXT OF A BALANCING OF INTERESTS ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, WITH EFFECT FOR THE FUTURE. IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE DATA CONCERNED. HOWEVER, FURTHER PROCESSING IS RESERVED IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FUNDAMENTAL FREEDOMS, OR IF THE PROCESSING SERVES THE ASSERTION, EXERCISE OR DEFENCE OF LEGAL CLAIMS.

IF YOUR PERSONAL DATA IS PROCESSED BY US FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING. YOU CAN EXERCISE THE OBJECTION AS DESCRIBED ABOVE. IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

7) Duration of Storage of Personal Data

The duration of storage of personal data is determined by the respective legal basis, the processing purpose and – if applicable – additionally by the respective statutory retention period (e.g. commercial and tax retention periods).

When processing personal data on the basis of express consent pursuant to Art. 6(1)(a) GDPR, the data concerned will be stored until you withdraw your consent.

If there are statutory retention periods for data processed in the context of legal or quasi-legal obligations on the basis of Art. 6(1)(b) GDPR, this data will be routinely deleted after expiry of the retention periods, provided it is no longer required for contract fulfilment or contract initiation and/or we no longer have a legitimate interest in further storage.

When processing personal data on the basis of Art. 6(1)(f) GDPR, this data will be stored until you exercise your right to object pursuant to Art. 21(1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims.

When processing personal data for the purpose of direct marketing on the basis of Art. 6(1)(f) GDPR, this data will be stored until you exercise your right to object pursuant to Art. 21(2) GDPR.

Unless otherwise stated in the other information in this declaration on specific processing situations, stored personal data will otherwise be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.