Shokz Health Privacy Policy

INTRODUCTION

Your (“you”) privacy is important to Shokz Health INC and its affiliated entities under common ownership and control within the Shokz Health family of companies (collectively, “Shokz Health Health”, “we”, “our” or “us”). This privacy policy (“Privacy Policy”) applies to the information we collect about you in the course of our business in the US and Canada, including through Shokz Health websites (Shokz Health.com and ca.Shokz Health.com) and electronic forms, services, marketing activities, research, retail locations, and other online or offline offerings or services operated by or on behalf of Shokz Health (collectively, the “Site(s)” or “Services”). This Privacy Policy can provide privacy details on how we manage your personal information for all Shokz Health Sites or Services, unless a separate privacy policy is provided for a specific Shokz Health product or service.

By using the Services, you agree to this Privacy Policy and that your personal information may be transferred to or accessed by entities around the world (mainly in the United States) to perform processing activities such as those described in this Privacy Policy in connection with your use of our products and services. Residents of Canada and certain states, such as California, may have additional personal information rights and notices. Please see Section 11 (Additional Information for Certain Jurisdictions) below for more information.

If you have questions or concerns regarding our Privacy Policy or practices, please contact us at privacy@shokzhear.com.cn We will be happy to address them directly.

This Privacy Policy contains the following sections:

1. The Information We Collect and Sources of Information

In order to provide our Services to you, we will collect your personal information directly from you, automatically when you use our Services or interact with us, and from third parties. We will only collect the information that is necessary for its specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

Please be aware that certain information or data collected through our Services may be processed locally on your device. Such information or data will not be transmitted to our servers for collection, storage, sharing, or sale. For instance, sound data, where data is only processed locally on products and shall be available only to and for the function required for the service or radio equipment to operate.

We may collect the following categories of information (which may or may not be personal information):

A. Information you provide directly to us or upload

When you use our Services, you may provide certain information to us. Some of the most common categories of information we collect directly from you include:

Identifiers, such as contact information, including name, address, telephone number, email address, postcode. If you represent an entity, we may further require your occupation or representative position information regarding such an entity.

General location information, We may collect your general location information,such as zip code, to performance our service,.

Any other information you choose to directly provide to Shokz Health in connection with your use of the Services.

B. Information that occurred or was collected online automatically

When you use our Services, we may automatically collect certain information. We use a variety of third-party technologies, including cookies and similar tools, to assist in collecting this information. Some of the information we automatically collect when you use our Services includes:

Online Activity and Browsing Information, such as links clicked, page views, purchases, searches, items viewed within the Site, information uploaded, items you add to your cart, the state or country from which you accessed the Site and your interactions within the Site. For more information, please see Cookies and Similar Technologies below.

Information related to your device or SIM card, such as your IP address, device type, browser type and network status.

2. How We Use Your Information

We may use your personal information to, for example, provide customer service, improve Site functionality and user experience, improve our products and services, and/or communicate with you.

In detail, we may use your information for the following purposes:

To Provide the Features of the Site and the Services You Request. When you use our Site, we will use your personal information to provide the requested product or service. For example, if you contact our consumer services, submit a request, or file a warranty claim, we will use information about you, such as your contact details, order number, or the product you have purchased, to help you resolve a problem or question. If you use our "Find a Store" feature, we may use your geographic location, with your consent, to show you nearby retail locations. If you participate in a promotion, we will use the contact information you give us to communicate with you about the promotion.

To Communicate with You. We use your personal information to keep in touch with you regarding your orders, products and services. This includes:

• Responding to your inquiries and following up on the feedback you have chosen to provide, for which we may use the personal information you have provided and keep records of the correspondence.
• Sending you marketing communications, with your consent, about our products, services, and events.

To Comply with Legal Obligations and for Security and Fraud Prevention. We may also access and use your personal information, including the content of your communications, to respond to lawful requests or legal processes, to protect the rights or property of Shokz Health or our customers (including the enforcement of our agreements or policies governing your use of our Sites and Services), and to comply with court orders, governmental requests, and applicable law. In addition, we may need to keep some personal information as evidence in case of a dispute, complaint, or audit.

Other purposes. We may also use your personal information in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.

3. Cookies and Similar Technologies

Like many websites, we use cookies, tracking pixels and other tracking technologies (collectively referred to as "Cookies"). Cookies are files stored on your computer's hard drive by your browser to enable the Website to remember you, your actions and preferences (such as login, language, font size and other display preferences) over a period of time. This allows us to optimize the shopping experience, hold selections in a shopping cart when a user leaves the website without checking out and send you reminder e-mails or messages via SMS about your shopping orders and other shopping opportunities. We also use Cookies to gather statistical information about the use of the website in order to improve its design and functionality, understand how the website is used, and assist us with resolving questions.

We use the following categories of Cookies on our Services:

Strictly Required Cookies. These cookies are required for the website to run and cannot be switched off. Such cookies are only set in response to actions made by you such as language, currency, login session, and privacy preferences, and do not gather information about you for marketing purposes.

Performance Cookies. These cookies collect passive information about how you use our Services, including web pages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing.

Targeting cookies. These cookies, which are proprietary to Shokz Health, serve advertisements on our Services that are solely related to your activities on our Services. These cookies do not collect or use information about your activities on other websites or services. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites.

Functional Cookies. These cookies enable our website to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. Before using these cookies, we will ask you for permission to activate the function. While these cookies can be disabled, this may result in less functionality during your use of our Services.

If you cannot find the cookies banner, please follow these steps to ensure that you can access important information about our cookie usage and consent:

• Refresh the Page.
• Check Your Browser Settings.
• Check Ad Blockers or Browser Extensions.
• Update Your Browser.
• Try a Different Browser.

4. How We Share and Disclose Your Information

We promise that we are not in the business of selling your personal information to others, which means that we will not exchange your personal information for monetary consideration. We share customers' personal information with Shokz Health’s affiliates, service providers or partners, in order to conduct business operations smoothly in providing you with the full capabilities of our products and services.

The parties with whom we may share or disclose your personal information include:

Shokz Health Affiliated Entities. We may disclose personal information within our affiliated entities under common ownership and control within the Shokz Health family of companies who are essential to maintaining our worldwide brand and service, enabling our global management, and enhancing our Services and your customer experience.

Third-Party Service Providers. We engage third-party companies and individuals to perform functions on our behalf. We may disclose your personal information to these providers so they can perform their services. These service providers have access only to the personal information needed to perform their functions and are contractually obligated to maintain its confidentiality and security. The types of service providers we use include:

• Customer Support and Communication Platforms. We use third parties to provide customer support services, including live chat functionality, platforms for managing returns, and systems for sending communications related to your orders and inquiries.
• Website Functionality Providers. We use specialized services to power certain features of our site, such as mapping services for the "Find a Store" feature and accessibility services to enhance user experience.

Government, Courts and Law Enforcement. We may disclose information about you to these parties to comply with legal obligations as described above.

Business Transfers. As we continue to develop our business, we may engage in transactions with other companies regarding the purchase or sale of a business, parts of a business or our assets. We may disclose your information as part of, or in contemplation of, such transactions. If a portion or all of Shokz Health’s assets are transferred to a third party in connection with such transactions, your information may be among the transferred assets.

With Your Consent. We may disclose your personal information to any other third party where you have provided your consent.

5. Security and Retention of Your Information

A. Security Safeguards

We are committed to ensuring that your personal information is secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect on Shokz Health websites.

We will take all practicable steps to safeguard your personal information. However, you should be aware that despite our efforts, no data transferred over the Internet is guaranteed to be 100% secure, and for this reason we cannot guarantee the security or integrity of any personal information that is transferred from you or to you via the Internet. You can help keep your data safe by taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

We regularly monitor our Services for possible vulnerabilities and attacks. If you have any concerns about the security of our Services, please contact us as detailed in the Contact Us section below so they may be addressed and resolved in a timely and effective manner.

B. Retention of Your Information

We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Privacy Policy. We will delete, anonymize or de-identify information when it is no longer needed to fulfill these purposes unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons why we are unable to fully delete, anonymize or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing of your information.

6. International Data Transfers and Storage

Shokz Health is a global company. To offer our services, we may need to transfer your personal information to locations outside of the jurisdiction in which you reside.

As a global company, personal information we collect from you may be primarily transferred to, stored, and processed out of your country of residence. In addition, your information may be processed in other countries where our affiliated entities or third-party service providers have operations.

These countries may have data protection laws that are different from, and potentially less protective than, the laws of your country of residence. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy and in accordance with applicable law, implementing appropriate safeguards to protect your information.

If you would like more information about our international data transfer practices and the safeguards we have in place, please contact us using the details in the 'Contact Us' section below.

7. Your Rights and Choices

Shokz Health recognizes that privacy concerns differ from person to person. Therefore, we provide you with the ability to exercise certain controls and choices regarding our collection, use, and disclosure of your information. Your legal rights to exercise such controls and choices vary based on the laws of your jurisdiction.

A. Privacy Rights

The privacy rights you may have include the following:

Right to know and access your personal information. You may have the right to know what personal information we collect about you, including the categories of personal information, the sources from and purposes for which we collect it, and the types of recipients we disclose it to, and to request a copy of the specific pieces of personal information that we maintain about you.

Right to correct your personal information. Right to correct inaccurate personal information that we maintain about you.

Right to delete your personal information. You may request the deletion of the personal information that we have collected about you, subject to certain exceptions. We may not delete all of your personal information if one of the following exceptions applies:

Transactional: to complete a transaction for which the personal information was collected, provide a product or service requested by you, or perform a contract we have with you;

Security: to detect data security incidents; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action

Error Correction: to debug or repair any errors;

Legal: to protect against fraud, harassment, malicious or deceptive activities,or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; to assist another party with any of its obligations under applicable privacy laws; or

Internal Use: to use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).

B. Exercising Your Rights and Choices

You may submit privacy rights requests and manage your privacy choices in several ways.

Access, Correction, and Deletion of your Personal Information. You have the right to request to know more about and access your personal information (including in a portable format), request deletion of your personal information , and request correction of inaccurate personal information.

To protect the privacy and security of your personal information, you may be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to, correction of, or deletion of your personal information, we shall proceed to respond to your request within any timeframe set out under applicable data protection laws. A copy of your personal information collected and processed by us will be provided to you upon your request free of charge (up to twice a year).

Only you or a person you are formally authorized to act on your behalf may make a verifiable consumer request related to your personal information. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.

If you wish to make multiple requests under this section, we recommend sending the deletion request last, as we will not be able to fulfill your other requests once we have deleted your information. We will maintain a record of your request to know or request to delete.

To exercise your rights, you may contact us at privacy@shokzhear.com.cn

Please note, that opting out or unsubscribing may not prevent you from receiving communications about your orders, products, or other important notices such as changes to our terms and policies, which are not marketing in nature.

Appeal for Shokz Health’s Response. We are concerned about your personal information and would like to hear from you if you are not satisfied with our responses to your requests. We have established an internal appeal mechanism, as the laws in some jurisdictions require, to review whether our decision about the prior request is correct.

If you feel unsatisfied with our responses to your right requests, please contact us at privacy@shokzhear.com.cn adding [APPEAL REQUEST] in the email title. We will shortly commence the appeal proceeding in accordance with applicable laws and regulations.

8. Children's Privacy

Our Sites and services are not intended for or directed to persons under age of 16. We do not knowingly collect or maintain information from those we know are under age of 16 except with the consent from parents or guardians. If notified by a parent or guardian or discovered by other means, that a child under the age of 16 has provided his or her personal data to Shokz Health, we will cancel the child’s account, if any, and delete the child’s personal data under our control,

9. Third-Party Links and Features

Our Privacy Policy does not apply to products and services offered by a third party. Shokz Health products and services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use the personal information that they collect from you. Our Privacy Policy does not apply to other sites linked to our Services.

10. Updates to the Privacy Policy

We keep our Privacy Policy under regular review and may update this Privacy Policy to reflect changes to our information practices. In that case, the “last updated” at the top of this page will also change. We encourage you to periodically review this page for the latest information on our privacy practices. By continuing the use of products and services on the websites or software, you are confirming that you have read and understood the latest version of the Privacy Policy. If there are material changes to this Privacy Policy or to how Shokz Health will use your personal information, we will provide you with additional notice (such as by adding a statement to the Website or sending you a notification).

11. Contact Us

If you have any comments or questions about this Privacy Policy or any questions relating to our collection, use or disclosure of your personal information, please contact us at privacy@shokzhear.com.cn, or give your feedback through our Contact Us page on the website.

In addition, Shokz Health set up a Data Protection Officer (DPO) in charge the data protection, our DPO can be contacted via the email address below or via our postal address:

Shokz Health INC

Attention: Shokz Health Data Protection Officer

Email: privacy@shokzhear.com.cn

12. Additional Information for Certain Jurisdictions

Information for California Residents

This section supplements the information contained in our Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act (CPRA).

A. Personal Information We Collect, Use, and Disclose

The CCPA requires us to disclose information about the categories of personal information we collect and how we use and disclose it. The following table summarizes our personal information handling practices over the preceding 12 months. The categories used in the table are those defined by the CCPA. The information we collect, our purposes for collection, and the third parties to whom we disclose information are described in more detail in Sections 1, 2, and 4 of this Privacy Policy.

Sale and Sharing of Personal Information

Shokz Health does not “sell” your personal information in exchange for monetary consideration. However, the CCPA defines “selling” and “sharing” broadly. Our use of online advertising and analytics tools may result in the disclosure of your information to our third-party partners, which may be considered “sharing” for the purpose of cross-context behavioral advertising under the CCPA.

In the preceding 12 months, Shokz Health has “Shared” the following categories of personal information with the categories of third parties listed below for the business purpose of providing advertising for our products that is more relevant to your interests:

• Categories of Personal Information Shared: Identifiers; Commercial Information; Internet or Other Electronic Network Activity Information; Inferences.
• Categories of Third Parties with Whom Information was Shared: Marketing Partners; Online Analytics Partners.

We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

Use and Disclosure of Sensitive Personal Information

Through our interactions with you and in order to provide you with the Shokz Health product or fulfil your request. We may collect Identifiers Information as described above. Under applicable privacy laws this may be considered “sensitive information.” Recipients of this data include service providers and payment processing providers. For categories of sensitive personal information that we collect, we will use or disclose it subject to relevant law, including the CCPA. Please note, we do not disclose sensitive information for purposes other than those specified under the CCPA Regulations in §7027(m).

Your California Privacy Rights

As a California resident, you have the following rights with respect to your personal information:

• The Right to Know. You have the right to request that we disclose to you the personal information we have collected, used, disclosed, and sold or shared about you.
• The Right to Delete. You have the right to request that we delete personal information we have collected from you, subject to certain exceptions.
• The Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.
• The Right to Opt-Out of Sale / Sharing. You have the right to direct us not to sell or share your personal information.
• The Right to Limit Use and Disclosure of Sensitive Personal Information. We only use and disclose your sensitive personal information for permitted purposes under the CCPA, you do not need to exercise the Right to Limit additionally..
• The Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt out of sales.

How to Exercise Your Rights

You may submit a request to exercise your rights to know, delete, or correct by:

• Emailing us at privacy@shokzhear.com.cn

To optout of the “sharing” of your personal information, please visit the "Do not sell/share my information" link at the footer of our websites and follow the instructions. You can also opt out by emailing us at privacy@Shokz Health.com Some of our marketing and analytics partners may also provide with their own opt-out tool, which may also enable you to opt out. For example, you may, exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout/.

Verification Process: To protect your privacy, we will take steps to verify your identity before fulfilling your request. We will verify your request by asking you to provide information that matches the information we have on file for you. The information we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.

Authorized Agents: You may designate an authorized agent to make a request on your behalf. We will require the authorized agent to provide proof of your written permission to make the request, and we will also need to verify your own identity directly with us before processing the agent's request.

Opt-Out Preference Signals (Global Privacy Control): Our websites are configured to process browser-based opt-out preference signals, such as the Global Privacy Control (GPC). When we detect such a signal from your browser, we will automatically treat it as a valid request to opt out of the “sharing” of your personal information for the browser and device you are using. For more information on GPC, please visit https://globalprivacycontrol.org/.

California “Shine the Light” disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. We do not currently disclose your personal information to third parties for their own direct marketing purposes.