Privacy policy

Last updated: October 13th, 2025

SunnyWhale INC. (registered address: 732 S 6TH ST, STE R, Las Vegas, NV, 89101, USA ) and its affiliates (collectively, "SunnyWhale" , "we", "us", and "our") are well aware of the importance of information security to users ("you", and "your"). We attach great importance to and respect your privacy. Through this policy, you can learn about the personal information we collect when you use our products/services, how we collect, store, protect, and use it, as well as how we provide you with access, updates, deletion, and protection of this information. We hope that before using our products/services, you will carefully read the "Privacy Policy of SunnyWhale" ("this Policy"), confirm that you fully understand the contents of this Policy, and make appropriate choices. If you choose to use our products/services, you will be deemed to have fully understood and fully agreed to all the contents of this Policy and agreed to be bound by this Policy.

This Policy applies to the products/services we provide to you through SunnyWhale APP, official website, etc., and does not apply to the products/services for which we have set independent privacy policies.

The purpose of formulating this Policy is to help you understand the following:

• What Personal Information do we collect
• How We Use Your Personal Information
• How We Store Your Personal Information
• How We Protect Your Personal Information
• How We Entrust Processing, Share, Transfer, and Disclose Your Personal Information
• Your Rights in Personal Information Processing Activities
• Shopify
• How This Policy Is Updated
• Protection of Personal Information of Minors

1. What Personal Information do we collect

1.1 Collection of your Personal Information

Personal information refers to various information recorded by electronic or other means relating to identified or identifiable natural persons, excluding anonymized information. In the process of using SunnyWhale services, we will collect the information you actively provide or generate due to the use of products/services in the following ways to provide you with products/services, optimize our products/services, and ensure the security of your information. SunnyWhale will only collect and use your personal information for the purposes stated in this Policy, and you should ensure that all personal information submitted is accurate.

We may collect personal data from you and regarding you, which includes both the information you provide and data collected automatically; we also generate personal data about you under specific circumstances, such as records of your interactions with us, and we may collect and process the following types of such data:

• Account Registration and Login: Name, phone number, verification code, position, address, and contact number.
• Activity Registration: Name, phone number, position, and company-related data such as company name, address, contact number, industry, and demand details.
• Order and Shipping Information: the total number of your orders, the number of your paid orders, your total payment amount, the date of your first order, the date of your last order, order notes, billing information (such as first name, last name, full name, company, address, city, state code, zip code, state name, postcode, country code, country name, email, and phone number), and shipping address.
• Services Usage Information: IP address, and operational behavior data gathered during your interaction with our Services (such as clicks, searches, timestamps, browsing history, video playback records, buffering status, and purchase history).
• Review and Feedback Information: product review details (including name, email, review title, text, and photos you submitted as review content, rating records, and review like/dislike history), and the information you provided to us when using feedback-related services within our Services.
• Customer Service-Related Information: for example, information used to verify your identity (name, email address, phone number, product purchase channel, product series name, product model, and order number), the content of message communications, contact information (address, contact numbers, and mailing information for customer service) you choose to provide us, and other information required to handle your requests (such as the required service category and product serial number).
• Distributors' Contact Information: Name, position, email address, phone number, company information (company name, country, website), sales channels, and the name of the sales representative.

1.2 How We Use Cookies and Similar Technologies

Cookies and similar device information identification technologies are commonly used in the Internet. When you use our products/services, we may use relevant technologies to send one or more cookies or anonymous identifiers ("Cookies") to your device to collect, identify, and store information about your access and use of our products/services. We mainly use cookies to ensure the security and efficient operation of products and services, help you have a more convenient access experience, improve product services, and simplify the steps and processes of filling out forms. We will not use cookies for any purposes other than those described in this privacy policy.

You can also manage cookies through your browser settings. However, please note that if you disable cookies, you may not be able to enjoy the best service experience, and some services may not be able to function properly.

2. How We Use Your Personal Information

Subject to applicable law, the purposes for which we process personal data and the legal bases for conducting such processing are as follows:

• Online Shopping: We process your Account Information, Order, Payment and Shipping Information, and Review Information to provide you with online shopping-related functions (e.g., placing orders, delivering products, and submitting product reviews). This processing is necessary for performing our contract with you.
• User Account Management: We process your Account Information to provide you with user account management-related functions (e.g., account registration, account cancellation, account login, and updating account information). This processing is necessary for performing our contract with you.
• Ensuring Security and Stable Operation: We process data including your region, network provider, device type, operating system, browser type, screen resolution, viewing history, access source, access date, mouse clicks, mouse hovers, dwell time, and video playback records to identify abnormal account statuses, ensure the stability and security of our Services, and plan improvements or upgrades to our Services. We have legitimate interests in conducting this processing to safeguard the security and ongoing stability of the Services—provided that such legitimate interests are not overridden by your interests, fundamental rights, or freedoms.
• Marketing and User Preference Analysis: We process certain parts of your Account Information (e.g., email, address), Order Information, and Services Usage Information to provide you with marketing campaigns and analyze user preferences. As required by applicable law, we will seek your consent prior to conducting this processing activity.
• Customer Service and Support: When you consult us about any issues via online customer service or use hotline services for inquiries or complaints, we will process certain parts of your Account Information and Customer Service-Related Information. Additionally, we may collect other information you provide to offer services such as troubleshooting and online customer support. This processing is necessary for performing our contract with you.
• User Surveys: We process your email to send you survey questionnaires. Furthermore, we will use your name and Feedback Information to complete survey activities. We will seek your consent prior to conducting this processing activity.
• Distributor Cooperation: We use Distributors’ Contact Information to facilitate relevant cooperation by getting in touch with distributor contacts. This processing is based on the consent of the distributor contacts.
• Investigations: We process certain parts of your Account Information in the following cases: (1) when it is necessary to comply with a legal obligation (particularly with respect to applicable employment law); or (2) when we have a legitimate interest in conducting such processing to detect and protect against fraud—provided that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

3. How We Store Your Personal Information

Generally speaking, we will only retain the personal information you provide for the duration necessary to achieve the intended purposes. Depending on the products or services you use, the storage period for your personal information may vary. When our products or services cease operations, we will notify you through push notifications, announcements, and other forms, and delete your personal information or anonymize it within a reasonable period of time.

4. How We Protect Your Personal Information

We strive to provide protection for the security of user information and adopt industry-standard practices to safeguard your personal information against loss, improper use, unauthorized access, or disclosure. We will use various security protection measures within reasonable security levels to ensure the safety of information. For example, we use encryption technology, anonymization, and other methods to protect your personal information. We have established specialized management systems, processes, and organizations to ensure information security. For example, we strictly limit the scope of personnel accessing information, require them to comply with confidentiality obligations, and conduct audits. If there is an unfortunate personal information leakage or other security incident, we will activate an emergency plan to prevent further expansion of such security incidents, and notify you through push notifications, announcements, and other means.

Although we have taken necessary measures to protect your personal information, given the limitations and relativity of network security technology, as well as the unpredictability of harm to network security caused by computer viruses, network intrusion, and attacks, you understand and agree that: under no circumstances will we be liable for the above situations and other actions that we cannot predict or control (such as normal equipment maintenance of information networks, information network connection failures, computer, communication or other system failures, power failures, strikes, labor disputes, riots, uprisings, disturbances, insufficient productivity or production materials, fires, floods, storms, explosions, wars, government actions, orders from judicial or administrative authorities, third-party reasons, etc.) that cause inability to provide services or delays in service, but we will do our best to minimize the losses and impacts caused to you as a result.

5. How We Entrust Processing, Share, Transfer, and Disclose Your Personal Information

We may entrust a third party to process your personal information. In this case, we will agree with the third-party trustee on the purpose, term, processing method, type of personal information, protection measures, and the rights and obligations of both parties. We will supervise the personal information processing activities of the trustee to prevent harm to your personal information rights and interests.

We will not share the personal information you provide, except for the following cases: sharing with affiliated companies of SunnyWhale; sharing with product/service providers, such as logistics delivery services, payment services, and operator services. We will require companies, organizations, and individuals sharing personal information to sign strict confidentiality agreements and process personal information according to this policy and related confidentiality and security measures. If there are other situations where we need to share your personal information, we will require the third party to obtain your consent for the above behavior.

Without your explicit consent, we will not transfer your personal information to any company, organization, or individual. As our business continues to develop, we may merge, acquire, transfer assets, go bankrupt, or liquidate. If personal information transfer is involved, we will inform you of the name and contact information of the recipient before transferring your personal information, and require the company, organization or individual receiving your personal information to continue to be bound by this Policy, otherwise, we will ask the company, organization or individual to re-seek your consent.

We will not publicly disclose the collected personal information, except with your separate consent or in accordance with laws, legal procedures, lawsuits or requirements of public and government authorities.

6. Your Rights in Personal Information Processing Activities

When required by applicable laws, you may have the right to: (1) Access, review, and copy your specific personal information held by us; (2) Request us to update or correct your inaccurate personal information; (3) Restrict our use of data or withdraw your consent to future processing of data; (4) Request us to delete your personal information; (5) Request us to explain the rules for processing personal information. If you want to exercise these rights, you can log in to your online account or contact us. For security reasons, you may need to provide a written request or prove your identity in other ways. We may refuse to process requests that we have reasonable grounds to believe are fraudulent, impossible to perform, or infringe upon the privacy rights of others. We may also refuse requests that are frivolous, 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 otherwise unreasonable.

When required by applicable laws, you also have the right to withdraw your consent at any time. Please understand that because each function and service require necessary personal information to be completed, we will be unable to continue providing you with the products or services corresponding to the withdrawn consent or authorized scope changes. However, your decision to withdraw consent or authorization will not affect the personal information processing conducted based on your previous consent or authorization.

7. Shopify

Our store is hosted on Shopify Inc., which provides us with an online e-commerce platform to sell our products and services to you. Your data is stored via Shopify’s data storage systems, databases, and the general Shopify application, with Shopify housing your data on a secure server behind a firewall.

Payment: If you select a direct payment gateway to finalize your purchase, Shopify stores your credit card data—this data is encrypted in accordance with the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only for the period necessary to complete your purchase transaction; once this process is finished, your purchase transaction information is deleted.

All direct payment gateways comply with the standards established by PCI-DSS, which is overseen by the PCI Security Standards Council—a collaborative initiative of brands including Visa, MasterCard, American Express, and Discover. PCI-DSS requirements assist in ensuring the secure handling of credit card information by our store and its service providers.

For additional information, you may also refer to Shopify’s Terms of Service (https://www.shopify.com/legal/terms) or Privacy Statement (https://www.shopify.com/legal/privacy).

8. How This Policy Is Updated

SunnyWhale reserves the right to update or modify this policy from time to time. In the event of changes to relevant laws and regulations or changes to our services, if we need to modify the contents of this policy, we will notify you of the updated terms through push notifications, pop-up windows, or other forms when you log in or use relevant services. If you do not agree with the new modified content, please stop using the services provided in this policy immediately. If you choose to continue using the relevant services, it will be deemed that you fully agree to and accept the new modified content. If objective circumstances and changes in business policies require us to suspend or terminate relevant services, we will notify you in a timely manner, and we ask for your understanding and agreement.

9. Protection Of Personal Information of Minors

Our Services are intended solely for adults. If you do not meet the legal adult age requirement in your jurisdiction, please do not use our Services. If you are unsure whether you meet this age requirement, please consult your guardian to confirm. If you are a parent or guardian and learn that a minor is using our Services, please contact us using the contact details provided in Section 9 below to terminate the relevant provision of Services