This Policy does not apply where MEFERI processes Personal Information on behalf of our Customers as a Data Processor (e.g., in the provision of MEFERI Shadowalk MDM/EMM Cloud Solution or cloud-hosted components of the CIAO Intelligent Shopper Assistant). Such processing is governed by our Data Processing Agreement (DPA), available here

Please read this Policy carefully. By using our Sites or providing Personal Information to us, you acknowledge that you have read, understood, and agree to the terms of this Policy.

1. Data Controller and EU Representative

Data Controller:

MEFERI Technologies Co., Ltd.

Unit 3-2, Building 4, No. 2555, Section 2, Huanglong Avenue, Shuangliu District, Chengdu 610000, Sichuan, P.R. China

Email:  legal@meferi.com

EU Representative (pursuant to Article 27 GDPR):

MEFERI Poland Sp. z o.o.

Ul. Modelarska 18/2, 40-142 Katowice, Poland

Email:  poland@meferi.com (for inquiries from data subjects and supervisory authorities in the EU)

2. Information We Collect

We may collect Personal Information directly from you, automatically when you use our Sites, and from other sources. “Personal Information” means any information that identifies or can be used to identify an individual.

2.1 Information You Provide to Us Directly:

We collect Personal Information that you voluntarily provide to us when you:

Register for an account on our portals (e.g., partner portal portal.meferi.com, support portal support.meferi.com).

Fill in forms on our Sites (e.g., contact forms, information request forms, newsletter subscription forms, callback request forms).

Communicate with us (e.g., via email, phone, or support services).

Participate in surveys, contests, or promotions.

Register for events.

The types of Personal Information you may provide include:

Contact Details: First name, last name, middle name (if applicable), email address (personal or business), phone number (personal or business).

Professional Information: Company name, job title, industry.

Account Data: Username, password (hashed).

Delivery Information: Address (e.g., for sending bonus gifts or materials).

Communication Content: Any information you share in your communications with us.

Company Information (when acting on behalf of a company): Name, registration numbers, addresses, phone and fax numbers, website, bank details, name of chief executive. Please note that information about a legal entity itself is not Personal Information but may be linked to the Personal Information of a contact person.

2.2 Information We Collect Automatically:

When you visit our Sites, we may automatically collect certain information from your device or browser, including:

Log and Usage Data: IP address, browser type and version, browser language settings (which may be used to automatically display Site content in your preferred language), operating system, device information, pages you visited on our Sites, the time and date of your visit, time spent on those pages, referring URLs, clickstream data, and other statistics.

Location Information: We may derive approximate location from your IP address.

Cookies and Similar Tracking Technologies: We use cookies and similar tracking technologies to collect and track information and to improve and analyze our Sites. See the “Cookies and Tracking Technologies” section below for more details. This may include information collected via Google Analytics, Yandex.Metrika, and UTM parameters in links.

2.3 Information We Obtain from Other Sources:

We may receive Personal Information about you from other sources, such as:

Social Media and Third-Party Authentication Platforms: If you choose to log in to our Sites or portals using your account on a third-party platform (e.g., social media networks like Facebook, X (formerly Twitter), Instagram, LinkedIn, YouTube, or authentication services like Google), we may access certain information from your profile on that platform. The type of information we access depends on your privacy settings on the respective platform and that platform’s privacy policy. We encourage you to review the privacy policy and settings of the relevant third-party platform.

Publicly Available Sources and Third-Party Data Providers: We may obtain information from public databases or third-party data providers to verify or supplement the information we hold.

3. How We Use Your Personal Information (Purposes of Processing)

We use the Personal Information we collect for various purposes, including:

Providing and Maintaining our Sites: To operate our Sites, ensure their security, and provide you with access to their features.

Responding to Your Inquiries and Providing Support: To respond to your comments, questions, and requests, and to provide customer service and support.

Managing Accounts: To create and manage your accounts on our portals.

Personalizing Your Experience: To understand your preferences and personalize your experience on our Sites, including displaying content in your preferred language.

Marketing Communications: To send you newsletters, promotional materials, and information about MEFERI products, services, offers, and events that we believe may interest you. Such communications will be sent to you only with your explicit consent (e.g., by checking a specific box on a form on our Site), where required by law, or, in some limited B2B communication contexts, based on our legitimate interests provided your right to object is respected. You can opt-out of receiving these communications at any time (e.g., by following the “unsubscribe” link in an email or by adjusting your account settings, if applicable).

Analytics and Site Improvement: To monitor and analyze usage trends and activities on our Sites to improve their functionality, design, and content.

Security and Fraud Prevention: To protect our Sites, systems, and users from fraud, unauthorized access, and other illegal activities.

Compliance with Legal Obligations: To comply with applicable legal and regulatory requirements, court orders, or government requests.

Managing Events and Promotions: To administer your participation in events, contests, or promotions.

4. Legal Basis for Processing Personal Information (for EEA/UK Users)

If you are in the European Economic Area (EEA) or the UK, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect Personal Information from you only:

Where we have your consent to do so (e.g., to receive marketing communications or for the use of certain cookies).

Where we need the Personal Information to perform a contract with you (e.g., to provide you with access to a portal you registered for).

Where the processing is in our legitimate interests (or those of a third party) and not overridden by your data protection interests or fundamental rights and freedoms (e.g., to improve our Sites, prevent fraud, secure our systems, respond to your inquiries, conduct direct marketing to existing contacts with an opt-out).

Where we have a legal obligation to collect or disclose Personal Information.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided below.

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies (e.g., web beacons, pixels, tags, and scripts) to collect and use Personal Information about you, including to understand Site usage, improve the content and offerings on our Sites, and to serve you relevant advertising.

What are cookies: Cookies are small text files that websites place on your device as you are browsing. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Types of cookies we use:

Strictly Necessary Cookies: These cookies are essential for the Sites to function and cannot be switched off in our systems.

Analytical/Performance Cookies: These cookies allow us to recognize and count the number of visitors and to see how visitors move around our Sites when they are using them. This helps us to improve the way our Sites work. We use Google Analytics and Yandex.Metrika.

Google Analytics Privacy Policy:  https://policies.google.com/privacy

Yandex.Metrika Privacy Policy:  https://yandex.ru/legal/confidential/

Functionality Cookies: These cookies are used to recognize you when you return to our Sites and enable us to personalize our content for you (e.g., remembering your language or region choice).

Targeting/Advertising Cookies: These cookies may be set through our Sites by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

Managing Cookies: Most web browsers allow some control of most cookies through the browser settings. You can set your browser to block all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Sites may become inaccessible or not function properly. On your first visit to our Sites, we may also present you with a cookie consent banner where you can manage your preferences.

6. How We Share Your Personal Information

We may share your Personal Information with the following categories of recipients:

Service Providers: Third-party companies and individuals who provide services on our behalf or assist us in operating our Sites and conducting our business (e.g., website hosting (including Amazon Web Services as identified in our Sub-processor List for our site infrastructure), email service providers for marketing, analytics providers, CRM providers, support services). These service providers have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Affiliates: To our affiliated companies (e.g., MEFERI Poland Sp. z o.o.) within our corporate group for purposes consistent with this Privacy Policy, such as providing localized support or fulfilling representative functions.

Law Enforcement, Regulatory Bodies, Government Agencies, Courts or other Third Parties: If we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

Potential Buyers (and their agents and advisers): In connection with any proposed or actual purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Information only for the purposes disclosed in this Privacy Policy.

With Your Consent: To any other third party with your prior consent.

7. 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.

Specifically, our Site servers may be located in various jurisdictions (e.g., in the EEA via AWS, as outlined in our Sub-processor List for our site infrastructure), and our parent company is in China. Our third-party service providers and partners also operate globally. This means that when we collect your Personal Information, we may process it in any of these countries.

Where we transfer your Personal Information from the EEA/UK to countries outside of them that have not been determined by the European Commission to provide an adequate level of data protection, we take appropriate steps to ensure that your Personal Information is protected in accordance with this Policy and applicable data protection law. These measures include using the European Commission’s Standard Contractual Clauses for transfers of Personal Information among our group companies and with our third-party service providers, or relying on other lawful transfer mechanisms. The role of our EU Representative also facilitates compliance.

8. Data Security

We have implemented appropriate technical and organizational security measures designed to protect the Personal Information we process. These measures are designed to provide a level of security appropriate to the risk of processing your Personal Information. However, please remember that no method of transmission over the Internet, or method of electronic storage is 100% secure.

9. Data Retention

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

10. Your Data Protection Rights

If you are a resident of the European Economic Area (EEA) or the UK, you have the following data protection rights:

Right of Access: You have the right to request access to your Personal Information that we hold.

Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Information about you.

Right to Erasure (‘Right to be Forgotten’): You have the right to request the deletion of your Personal Information under certain circumstances.

Right to Restrict Processing: You have the right to request the restriction of processing of your Personal Information under certain circumstances.

Right to Data Portability: You have the right to receive the Personal Information you have provided to us in a structured, commonly used, and machine-readable format, and have the right to transmit those data to another controller under certain circumstances.

Right to Object to Processing: You have the right to object to the processing of your Personal Information under certain circumstances, particularly where we process your data based on legitimate interests or for direct marketing purposes.

Right to Withdraw Consent: If we are collecting and processing your Personal Information with your consent, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

Right to Lodge a Complaint: You have the right to lodge a complaint with a data protection supervisory authority about our collection and use of your Personal Information. For more information, please contact your local data protection supervisory authority.

To exercise any of these rights, please contact us at  legal@meferi.com or our EU Representative at poland@meferi.com if you are in the EU. We will respond to your request in accordance with applicable data protection laws. We may ask you to verify your identity before responding to such requests.

11. Children’s Privacy

Our Sites are not intended for children under the age of 16, and we do not knowingly collect Personal Information from children under 16. If you are under 16, please do not use or provide any information on these Sites. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

12. Links to Other Websites

Our Sites may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date at the top of this Privacy Policy. For material changes, we may provide more prominent notice (such as by adding a statement to our homepages or sending you an email notification). You are advised to review this Privacy Policy periodically for any changes.

14. Terms of Service

Please note that your use of our Sites is also governed by our Terms of Service, which will be available at Terms of Service . This Privacy Policy is an integral part of our Terms of Service.

15. Contact Us

If you have any questions or concerns about this Privacy Policy or our data processing practices, please contact us:

MEFERI Technologies Co., Ltd. (Headquarters / Data Controller)

Address: Unit 3-2, Building 4, No. 2555, Section 2, Huanglong Avenue, Shuangliu District, Chengdu 610000, Sichuan, P.R. China

Email for privacy inquiries:  legal@meferi.com

MEFERI Poland Sp. z o.o. (EU Representative)

Address: Ul. Modelarska 18/2, 40-142 Katowice, Poland

Email for privacy inquiries from data subjects and supervisory authorities in the

EU:  poland@meferi.com