Welcome to Wingleam (hereinafter referred to as “our site” or “we”), an e-commerce platform specializing in the sales of overseas pearl products. We are well aware of the importance of your personal information security and privacy protection. This privacy policy aims to provide detailed information on how we collect, use, store, transmit, and disclose your personal information, as well as the relevant rights and protection measures you enjoy. This policy applies to all users (including member users) who access, register, and use the services of this website. Whether you access this website through a computer, mobile, or other terminal device, it is deemed that you have read, understood, and agreed to all the terms of this policy. If you do not agree with this policy, please do not access or use the services of this website.

This privacy policy strictly complies with privacy protection laws and regulations in major regions around the world, such as the European Union General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), to ensure that your personal information is processed in a legal, legitimate, necessary, and honest manner, effectively protecting your privacy rights.

1、 Definition and Explanation

• Personal information: refers to various information related to identified or identifiable natural persons recorded in electronic or other ways, excluding anonymized information, including but not limited to name, email address, contact information, account information, etc.
• Sensitive personal information: refers to personal information that, once leaked, illegally provided, or abused, may endanger personal and property safety, and is highly likely to cause damage to personal reputation, physical and mental health, or discriminatory treatment. The sensitive personal information involved on this website mainly includes payment information, bank card numbers, etc.
• User/Member: Refers to natural persons who access, register, and use the services of this website, including regular visitors and registered members.
• Data processing: refers to a series of operations such as collecting, storing, using, processing, transmitting, providing, disclosing, and deleting personal information.
• Anonymization processing: refers to the process of removing identification information from personal information through technical means, so that the processed data cannot identify specific natural persons and cannot be recovered through reasonable means.

2、 The personal information we collect

We only collect personal information that you voluntarily provide or generate through the use of our services for legitimate purposes such as providing our services, optimizing user experience, and ensuring transaction security. We do not collect information unrelated to our services. The specific collection scope is as follows:

（1） Information collected when registering as a member

When you register as a member of this website, in order to complete account creation, identity verification, and provide subsequent services, we will collect the following information that you voluntarily fill in:

• Basic identity information: name, gender, nationality, date of birth Email、 Contact phone number (optional);
• Core account information: username, password set (to be stored in encrypted form), email address (required for account login, verification code reception, and service notification sending);
• Preference information: The pearl product preferences you have selected (such as pearl category, style, price, etc., optional) are used to provide you with personalized recommendation services.

You have the right to choose not to provide optional information, but this may affect your enjoyment of some personalized services, but it does not affect your use of the core shopping functions of this site.

（2） Information collected during the use of services on this website

When you use our website to browse, shop, place orders, review and other services, we will automatically collect the following service related information:

• Transaction information: Your order information (order number, purchased product, order time, order amount, payment method, shipping address, recipient and contact phone number), payment information (only collect payment channel name, not complete bank card number, payment password and other sensitive payment information, which is directly processed by third-party payment institutions);
• Browsing and behavioral information: The pearl product pages you browse, search keywords, dwell time, click operations, products added to the shopping cart, favorite products, etc. are used to analyze your shopping preferences, optimize product recommendations, and website experience;
• Device and network information: The terminal device information (device model, operating system, browser type, unique device identifier) and network information (IP address, IP geographic location, network type, access operator) used by you to access this website are used to ensure account security, prevent fraud, and optimize website compatibility.

（3） Information collected through third parties

If you log in to this website through a third-party account (such as Google, Facebook, YouTube, Instagram, Pinterest, etc.), we will obtain your basic account information (such as third-party account nickname, email address) from the third party with your authorization, in order to quickly complete account registration and login on this website. You can cancel this authorization at any time in your account settings.

We will not actively collect your personal information from third parties who have no cooperative relationship with this website, nor will we sell or rent your personal information to any third party who has no cooperative relationship.

（4） Information not collected

We will not collect sensitive information such as your race, religious beliefs, political views, medical and health information, biometric information, etc. that is not related to the sales and services of our products on this site, unless you voluntarily provide and explicitly agree to our use.

3、 Purpose and Usage of Personal Information Collection

We collect your personal information only for the following legitimate purposes, and the use method complies with legal and regulatory requirements, and does not exceed the reasonable scope related to the collection purpose:

（1） Account management and identity verification

Use your username, password, email address, and other information to complete account login, identity verification, ensure account security, and prevent account theft; We provide services such as account information inquiry, modification, and cancellation, and handle inquiries and complaints related to your account.

（2） Provide core shopping services

1. Based on your order information, shipping address, etc., process your order, payment, shipping, logistics tracking and other transaction processes to ensure that you can smoothly purchase pearl products on this website;

2. Through your email address, we will send you necessary service information such as order confirmation, logistics notifications, and after-sales service reminders (such as return and exchange progress) to ensure that you are informed of the transaction status in a timely manner.

（3） Optimize user experience and personalized services

1. Analyze your browsing behavior, shopping preferences, and other information to recommend pearl products that meet your needs (such as new products, popular styles, personalized combinations), improving your shopping efficiency and experience;

2. Based on your usage habits, optimize the page design, functional layout, loading speed, etc. of this website to provide you with a more convenient and smooth access experience;

3. Conduct user surveys (such as pearl product satisfaction surveys), collect your feedback, and use it to improve product quality and service levels.

（4） Marketing and Promotion Services

With your explicit consent, we will send you marketing content such as pearl product promotion information, new product launch notifications, promotional activity reminders, etc. through your email address. You can unsubscribe at any time in your account settings or stop receiving such marketing information through the “unsubscribe” link in the marketing email. After unsubscribing, we will no longer send you relevant marketing content and will not affect your use of other services on this site.

（5） Security and compliance requirements

1. Utilize your device information, network information, login records, etc. to detect, prevent, and respond to security risks such as account theft, fraud, and network attacks, ensuring the security of your account and transactions;

To fulfill the obligations stipulated by laws and regulations (such as tax declaration, auditing, and responding to regulatory inspections), keep and use relevant personal information, and ensure the compliance of the operation of this website.

（6） Other lawful purposes

Subject to your consent, it may be used for other legitimate purposes related to the services provided on this website, such as assisting in resolving transaction disputes, providing after-sales service, recommending relevant products from partners to you (with your separate consent), etc.

4、 Storage and Protection of Personal Information

（1） Storage method and expiration date

1. Storage location: We store your personal information on servers that comply with GDPR, CCPA, and other regulatory requirements. The servers are distributed in overseas regions such as the European Union and the United States (reasonably allocated according to your location) to ensure that data storage complies with local privacy protection regulations;

2. Storage period: We only store your personal information for the shortest period necessary to achieve the collection purpose, as follows:

• Account information: During the duration of your account, we will continue to store your core account information (username, encrypted password, email address) for account management purposes; If you cancel your account, we will delete or anonymize your account information within 15 working days after account cancellation (except for those required by laws and regulations to be retained);
• Transaction information: In order to fulfill transaction obligations, respond to transaction disputes, and comply with tax and regulatory requirements, we will store your transaction information for at least 5 years, and after 5 years, it will be deleted or anonymized;
• Browsing and behavioral information: Only stored for 6 months, after which it will be automatically deleted or anonymized. The anonymized data used to optimize the service will be retained for a long time, but it does not contain any personally identifiable information;
• Marketing related information: After you unsubscribe from marketing content, we will immediately stop using your email address for marketing and delete relevant marketing records within 30 working days (excluding those required by laws and regulations to be retained).

（2） Security protection measures

We take dual measures of technology and management to ensure the security of your personal information and prevent risks such as information leakage, tampering, loss, and abuse. The specific measures are as follows:

• Technical protection: Use AES-256 encryption standard to encrypt and store your personal information (especially passwords and email addresses); Using technologies such as firewalls and intrusion detection systems to prevent network attacks; Regularly conduct security checks and vulnerability repairs on servers to ensure the security of the storage environment;
• Management protection: Establish a strict personal information management system, clarify the permissions of personnel in each position, only authorized personnel can access your personal information, and access records can be traced; Provide privacy protection training to employees, enhance their awareness of privacy protection, and strictly prohibit employees from collecting, leaking, or abusing user personal information without authorization;
• Emergency response: Establish an emergency response mechanism for personal information leakage. In the event of a security incident such as personal information leakage or tampering, we will immediately initiate emergency procedures, take remedial measures, and notify you and relevant regulatory agencies within the time limit required by laws and regulations.

Please note that although we have taken the above security measures, there is some uncertainty in the Internet environment, and we cannot fully guarantee the absolute security of your personal information. You should keep your account password, email verification code, and other information safe and not disclose them to others. If you find any abnormalities in your account, please contact us promptly for handling.

5、 Transmission and Disclosure of Personal Information

We will not transfer or disclose your personal information arbitrarily, and will only do so under the following legal circumstances, and will take necessary measures to ensure the security of your information:

（1） Transmission to third-party service providers

In order to ensure the normal operation of our website services, we will transfer some of your personal information to our cooperating third-party service providers. These third parties can only use your personal information within the scope of providing services to us and must comply with our privacy protection requirements. They are not allowed to use it for other purposes without authorization. Mainly includes:

• Payment service provider: In order to complete the payment process, we will transmit your order information and shipping information (excluding sensitive information such as passwords) to payment service providers (such as PayPal, Stripe, etc.) for payment verification and transaction processing;
• Logistics service provider: In order to complete the delivery of goods, we will transmit your shipping address, recipient, contact phone number and other information to the logistics service provider for logistics tracking and delivery;
• Technical service providers: In order to optimize website performance and provide customer service, we will transmit your device information, browsing information, consultation records, etc. to technical service providers (such as server hosting providers, customer service system providers) for technical support and service optimization;
• Marketing service provider: With your consent, we will transmit your email address to the marketing service provider for sending marketing content, and the marketing service provider must comply with relevant privacy regulations and not disclose your information.

（2） Disclosure in accordance with the law

We may disclose your personal information in accordance with the law without obtaining your prior consent in the following situations:

• Comply with the provisions of laws and regulations, and respond to the legitimate requests of government agencies and judicial organs (such as court summons and regulatory inspections);
• To protect your legitimate rights and interests, personal safety or property safety, or to protect the legitimate rights and interests of this website and other users, disclose relevant information in emergency situations;
• To fulfill the legal obligations of this website, such as tax declaration, auditing, etc., disclose necessary personal information to relevant regulatory authorities;
• In the event of a merger, acquisition, bankruptcy liquidation, or asset transfer on this website, your personal information and related assets will be transferred to the transferee, and the transferee must continue to comply with the provisions of this privacy policy and notify you before the transfer (except where required by laws and regulations not to notify).

（3） Cross border transmission

Due to the fact that this website is aimed at overseas users, your personal information may be transferred across borders to regions such as the European Union and the United States. We will strictly comply with the cross-border data transmission regulations in relevant regions, take necessary safeguard measures (such as signing standard contract terms), ensure the security of your personal information during cross-border transmission, and comply with the requirements of GDPR, CCPA and other regulations for cross-border data transmission.

6、 Your personal information rights

According to overseas privacy regulations such as GDPR and CCPA, you have the following personal information rights, and we will provide you with convenient ways to help you exercise these rights:

（1） Right to know

You have the right to know all the information about our collection, use, storage, transmission, and disclosure of your personal information, including the purpose, scope, usage method, storage period, third-party service providers, etc. This privacy policy has detailed the relevant content, and you can also consult our customer service for relevant details at any time.

（2） Access rights

You have the right to access your personal information, including your account information, transaction information, browsing history, etc. You can log in to your account on this website and view your relevant information in the “Personal Center”; If you need to obtain a more detailed copy of your personal information, you can apply to us through customer service channels, and we will respond to your request within 15 working days (GDPR requires a maximum of 30 days).

（3） Right to correction

If you find that your personal information is incorrect or incomplete (such as incorrect name, shipping address, email address), you have the right to request us to correct it. You can modify relevant information on your own in the “Personal Center” by logging into your account on this website; For those that cannot be modified by yourself, you can submit a correction request through customer service channels. We will complete the correction within 7 working days after verifying your identity.

（4） Right to deletion (right to be forgotten)

In the following circumstances, you have the right to request us to delete your personal information. We will complete the deletion within 15 working days after verifying your identity (except for those required by laws and regulations to be retained):

• Our purpose of collecting and using your personal information has been achieved and no longer requires storage;
• You have withdrawn your consent to the collection and use of personal information;
• We will no longer provide services to you;
• You have cancelled your account on this website;
• We collect and use your personal information in violation of laws, regulations or the provisions of this privacy policy.

（5） Right to withdraw consent

You have the right to withdraw your previous consent regarding the collection, use, and disclosure of personal information (such as marketing information push, third-party account authorization, etc.). After revoking your consent, we will immediately cease the relevant information processing activities, but it does not affect the legality of the information processing based on your consent before revocation, nor does it affect your use of the core services of this website. You can withdraw your consent through the following methods:

• Cancel marketing information push: Use the “unsubscribe” link in the marketing email or log in to your account to turn off marketing push in “Settings”;
• Cancel third-party account authorization: Log in to the account in the “Binding Settings” and unlink it from the third-party account;
• Withdrawal of other consent: Submit a request to withdraw consent to us through customer service channels.

（6） Right of portability

You have the right to request that we provide you with a copy of your personal information in machine-readable format (such as CSV, JSON), or transmit it to other service providers you specify (subject to legal and regulatory requirements). You can submit an application through the customer service channel, and we will respond and process it within 15 working days.

（7） Limit or refuse processing rights

You have the right to request that we restrict or refuse to process your personal information (such as suspecting that your personal information is incorrect, or that our information processing behavior is illegal or irregular). You can apply through customer service channels, and after verification, we will limit or stop the relevant information processing behavior according to the actual situation and notify you in a timely manner.

（8） Right to complain

If you believe that our personal information processing behavior violates laws and regulations or this privacy policy, or that your personal information rights have been infringed upon, you have the right to file a complaint with our customer service or the privacy protection regulatory agency in your region (such as the European Union's data protection agency or the California privacy regulatory agency).

（9） Explanation of Exercise of Rights

To ensure the security of your personal information, when you exercise the above rights, we may require you to provide identity verification information (such as account password, email verification code) to confirm your identity and prevent others from using your identity to exercise their rights. We will not lower the quality of your services or charge additional fees due to your exercise of personal information rights (except as otherwise provided by laws and regulations).

7、 The use of cookies and similar technologies

To optimize your browsing experience, record your browsing preferences, and ensure website security, we use cookies and similar technologies (such as pixel tags, local storage). Cookie is a small text file sent by a website to your terminal device, used to identify your device and record your usage habits.

• The purpose of using cookies is to record your login status and avoid duplicate logins; Analyze your browsing behavior and recommend personalized pearl products for you; Optimize website performance and fix issues during use; Prevent fraud and ensure account security.
• Cookie management: You can choose to accept, reject, or delete cookies through your browser settings. If you refuse all cookies, it may affect your use of some features of this site (such as automatic login, personalized recommendations), but it does not affect your core shopping functions.

Third party cookies: Our cooperating third-party service providers (such as marketing and analytics service providers) may use cookies to collect your relevant information for providing us with services. The use of third-party cookies is subject to the third-party privacy policy, and we do not assume any responsibility for it.

8、 Privacy Protection for Minors

This website does not provide services to minors under the age of 16, and we do not intentionally collect personal information from minors under the age of 16. If you are a minor (under 16 years old), please do not register or use the services of this website; If a minor registers and provides personal information without the consent of their guardian, and their guardian discovers this, they can contact us through customer service channels. We will immediately delete the minor's personal information and cancel their account.

9、 Update and Notification of Privacy Policy

With the update of global privacy regulations and the development of our website's business, we may modify and update this privacy policy. The revised privacy policy will be prominently displayed on this website (such as at the bottom of the homepage) and marked with the update date.

If there are significant changes to the privacy policy (such as changes in the scope of collection, purpose of use, or disclosure methods), we will notify you through your email address to ensure that you are aware of the modified content. By continuing to access or use the services of this website, it is deemed that you have read, understood, and agreed to the revised privacy policy; If you do not agree with the modified content, please do not continue to use the services of this website and you may cancel your account.

10、 Contact Us

If you have any questions, suggestions, or need to exercise your personal information rights or file complaints regarding this privacy policy, you can contact us through the following methods:

• 电子邮箱：personalshopper@wingleam.com
• Customer service hotline:
• Company Address:

We will respond and handle your inquiry, application or complaint within 15 working days to ensure that your issue is properly resolved.

11、 Other terms

This privacy policy is the core agreement between our website and you regarding personal information protection, and together with our website's terms of service, order terms, etc., constitutes the complete agreement for your use of our website's services. If this privacy policy conflicts with relevant laws and regulations, the laws and regulations shall prevail; If there is a conflict between this privacy policy and other agreement terms on this website, this privacy policy shall prevail.

This privacy policy shall come into effect from the date of publication.

wingleam

Release date: April 1, 2026