NAS Community PRIVACY POLICY

PRIVACY POLICY

 

Initial Effective Date: 07 November, 2025        

Last Updated Date: 07 November, 2025               

 

 

Welcome to the Official UGREEN NAS Community (the "Community")! This Privacy Policy explains how UGREEN GROUP LIMITED ("UGREEN," we," "us," or "our") collects, stores, uses, shares, and protects personal data when you use our services ("Services"), including when you:

● Visit our Official UGREEN NAS Community at https://community.ugreen.com or any website of ours that links to this Privacy Policy.

● Engage with us in other related ways, including any marketing or events.

 

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal data is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at DPO@ugreen.com.

 

 

SUMMARY OF KEY POINTS

● What personal data do we process? When you visit, use, or navigate our Services, we may process personal data depending on how you interact with the Services. This includes data you provide (e.g., email, posts, report details, Creator application information), data collected automatically (e.g., IP address, usage logs, report timestamps, Voucher redemption data). We do not collect any personal data from third parties.

● Do we process any sensitive personal data? No.

● How do we process your data? To provide, and administer our Services, communicate with you, ensure security, prevent fraud, and comply with law. We process your data only when we have a valid legal reason to do so.

● When and with whom do we share personal data? With service providers (e.g., hosting, analytics, AI moderation), affiliates, and in specific situations like business transfers.

● How do we keep your data safe? We have organizational and technical processes in place to protect your personal data. However, no system is 100% secure.

● What are your rights? Depending on your place of residence, you have rights under applicable laws. Please see the jurisdiction-specific Appendices at the end of this Policy. 

● How do you exercise your rights? The easiest way to exercise your rights is by visiting our website service that allows users to view/edit/delete your personal data, or by contacting us.

 

 

TABLE OF CONTENTS

1. WHAT DATA DO WE COLLECT?

2. HOW DO WE PROCESS YOUR DATA?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

5. IS YOUR DATA TRANSFERRED INTERNATIONALLY?

6. HOW LONG DO WE KEEP YOUR DATA?

7. HOW DO WE KEEP YOUR DATA SAFE?

8. DO WE COLLECT DATA FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. DO WE MAKE UPDATES TO THIS POLICY?

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

APPENDICES

APPENDIX A: ADDITIONAL PROVISIONS FOR EUROPEAN ECONOMIC AREA (EEA) RESIDENTS

APPENDIX B: ADDITIONAL PROVISIONS FOR UNITED STATES RESIDENTS

APPENDIX C: ADDITIONAL PROVISIONS FOR JAPAN RESIDENTS

 

 

1. WHAT DATA DO WE COLLECT?

Personal data you provide to us

The personal information we collect may include the following:

 

 

Data automatically collected

The following information may be automatically generated and collected when you use our Services.

 

 

 

Data collected from third-party resources

Our Services offer you the ability to register and log in using your third-party social media account details. Where you choose to do this, we will receive certain profile data about you from your social media provider (e.g., name, email address, profile picture).

 

Sensitive data

We do not collect sensitive personal data.

 

 

2. HOW DO WE PROCESS YOUR DATA?

We process data for the following purposes.

Function	Data Type	Purposes
Account & Security	Email Address, Passwords, Verification Code, Dynamic Passcode (e.g., Google Authenticator), IP Address, Login Location, Timestamps (Registration/Login), Registration Source Channel, Login Method, Session Token, Open ID, Login Logs, Username, Bio, Gender, Profile Picture, Level of NAS Experience, NAS product Model, Interest Tags	To create an account and for identity verification during login, password recovery, and other security-related processes. To ensure account security and detect suspicious activity. To track and analyze user acquisition channels. To manage user sessions and verify identity across different login methods; and to complete user profiles to better introduce yourself to other users.
Community Profile & Content	Post Title, Body, Multimedia Attachments, Board/Section Selection, Topic Tags, Comment Text/Attachments, Reply Text, Forwarding Text, Like, Favorite, Post/Comment Unique ID, Parent Comment ID, User ID, Creation & Update Timestamps, View Count (Page Views / Unique Visitors), Interaction Timestamps & Associated User IDs (Likes, etc.), Like, Reply, Report Counts, Multimedia File Information, Interaction Settings (e.g., Allow Comments)	To constitute the core content of a user's post/comment. To categorize content. To allow users to interact and have discussions. To facilitate conversation context. To add context when sharing. To express approval or save content.
Search	Search Keywords	To allow users to find relevant content on the platform.
Points/Voucher Activities	Email Address (for Voucher confirmation), Voucher ID, Voucher Stock Change Record, Redemption Order ID, Redeeming User ID, Redemption Timestamps, Points Consumed	To confirm Voucher redemption, manage Voucher inventory on the Community.
Creator Program Participation	Identifiers (e.g., Name, Email, Shipping Address only for loaners/gifts, Social Media Handles), Location, Creative Direction, Professional Information (e.g., Creator Portfolio, Content Links), Likeness for promotion, Application Timestamps, Historical Content Creation Data, Engagement and Influence Data, Moderation Workflow Records	To verify eligibility; manage applications; manage loaner program/gifts; contact creators; track performance; fulfill promotional purposes.
Referral Program	Referrer ID, Referred email (optional), Post ID, Registration status/timestamps.	To confirm successful referrals; attribute points; prevent fraud.
Reporting and Appeals	Report Reason/Type, Appeal Reason, Reported/Appealed Object Identifier, Supporting Evidence (e.g., screenshots, recordings), Supplementary Information, Violation History	To receive, process, and investigate user-submitted reports and appeals, confirm violations, maintain an evidence trail for decisions, track moderator responsibility for specific cases, analyze potentially malicious reports.
Content Moderation	User Content (including your posts, comments, chat messages, usernames, and some of your profile information, as well as related metadata, in the form of text, links, images, or video), DeviceToken, DeviceId, AccountId, User Content Url, OssObjectName, DataId, Referer, LiveId	To protect the safety of the Community and our users, which includes blocking suspected spammers, addressing abuse, restricting certain content and enforcing our rights, the Terms and Conditions and our other terms and policies, as well as comply with applicable law.
Platform Management	Navigation Item Click Counts, User/Device ID, Timestamps, Points Transaction Log (ID, Type, Amount, Reason, Timestamp, Expiration Date), Board/Section Post Counts & Visit Volume, Activity Participant Count, Voucher Redemption Count	To analyze user behavior and identify popular features. To calculate rankings for leaderboards. To maintain an accurate record of points history. To evaluate the activity of different content categories. To measure event success. To display metrics on user profiles. To conduct voucher inventory management.

 

 

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such data to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal data. This means that they cannot do anything with your personal data unless we have instructed them to do it. They will also not share your personal data with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

 

The categories of service providers we may share personal data with are as follows:

● Website Hosting Service Providers (e.g., Shopify).

● Analytics Implementation Services (e.g., Google).

● Identity Provider (e.g., Google).

● AI Content Moderation Provider (e.g., Alibaba Cloud).

 

We also may need to share your personal data in the following situations:

● Business Transfers. We may share or transfer your data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

● Affiliates. We may share your data with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

 

 

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather data when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Please see our Cookie Notice for full details.

 

5. IS YOUR DATA TRANSFERRED INTERNATIONALLY?

Our servers are located in Singapore. Please be aware that your data may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal data (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?" above), including facilities in China and other countries.

For residents in certain jurisdictions, we rely on specific legal mechanisms for data transfers. Please refer to the corresponding appendix for details.

 

6. HOW LONG DO WE KEEP YOUR DATA?

We will only keep your personal data for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, audit, or other legal requirements). For example, if you violate our policies and your account is suspended or banned, we may store the identifiers used to create the account (such as email address, to prevent you from creating new accounts).

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

 

7. HOW DO WE KEEP YOUR DATA SAFE?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we process. However, no electronic transmission or storage technology can be guaranteed to be 100% secure. Although we will do our best to protect your personal data, transmission of personal data to and from our Services is at your own risk.

 

8. DO WE COLLECT DATA FROM MINORS?

By using the Services, you represent that you are 18 years of age or older (depending on the age of majority in your jurisdiction). We do not knowingly collect personal data from anyone under that age ("Minors"). If we learn that personal data from Minors has been collected, we will take reasonable measures to promptly delete such data as required by law. If you become aware of any data we may have collected from Minors, please contact us at DPO@ugreen.com.

 

9. WHAT ARE YOUR PRIVACY RIGHTS?

In some jurisdictions, you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal data, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal data; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal data.

For specific rights applicable to your jurisdiction, please see the Appendices below.

Withdrawing your consent: If we rely on your consent for specific processing activities (like marketing emails), you have the right to withdraw that consent at any time. You can typically do this through methods like using unsubscribe links or adjusting your settings. For withdrawing consent related to the core service provision, this generally requires account deletion (see below) or contacting us.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send or by contacting us.

Exercising Your Rights (General): The easiest way to review or update your personal data is typically through your account settings on the Community website. For requests regarding access, restriction, portability, or objection, please contact us using the details in Section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?".

Requesting Account Deletion: You may request the deletion of your Community account and associated personal data through one of the following methods:

l Navigate to "Settings" -> "Privacy and Security" -> "Delete Account" on the UGREEN Community website and submit your request through the provided interface.

l Send an email to communityservice@ugreen.com with the subject line "Account Deletion Request" and include necessary identity verification materials as requested.

We will process verified account deletion requests within 30 calendar days of receipt. Upon completion, we will send a confirmation notice to your registered email address.

Please note: As stated in Section "HOW LONG DO WE KEEP YOUR DATA?" and detailed in relevant program rules (like the Community Points Rules), account deletion is irreversible. It results in the immediate termination of participation in associated programs and the forfeiture of benefits like unused Points and Vouchers.

 

 

10. DO WE MAKE UPDATES TO THIS POLICY?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your data.

 

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact us by emailing DPO@ugreen.com, or by post at:

UGREEN GROUP LIMITED

4/F, Plant 6, 1F-6/F, Block 7, YuAn Zone Gaofeng Community, Dalang Street

Longhua District, Shenzhen, China

518000     

 

 

APPENDIX A: ADDITIONAL PROVISIONS FOR EUROPEAN ECONOMIC AREA (EEA) RESIDENTS

This section applies to you if you are a resident of the European Economic Area (EEA). In the event of any conflict or inconsistency between this Appendix and the main body of this Policy, this Appendix shall prevail.

 

Controller Information

The Controller of your data is UGREEN GROUP LIMITED.

 

Collection, Use, Disclosure, and Retention

For the categories of personal data we process, the purposes of the processing, the categories of recipients of the personal data, and the criteria used to determine the period for which the personal data will be stored, please refer to the following sections of the main body of this Policy, respectively:

l WHAT DATA DO WE COLLECT?

l HOW DO WE PROCESS YOUR DATA?

l WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

 

Legal Bases for Processing

The General Data Protection Regulation (GDPR) requires us to explain the valid legal bases we rely on in order to process your personal data. As such, we may rely on the following legal bases:

Consent. We may process your data if you have given us permission (i.e., consent) to use your personal data for a specific purpose. You can withdraw your consent at any time.

Performance of a Contract. We may process your personal data when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services. (This is the primary basis for processing data related to Account Login, Content Creation, and Creator Program administration).

Legitimate Interests. We may process your data when it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights.

Legal Obligations. We may process your data where it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body.

Vital Interests. We may process your data where it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

 

Your Rights

As residents in the EEA, UK, and Switzerland, you are entitled to the following rights regarding the personal data we process as a personal data controller:

l Access and portability. You may ask us to confirm whether we are processing your personal data, provide you with details about such processing, and give you a copy of your personal data. You may ask us to provide your personal data in a structured, commonly used, machine-readable format, or you can ask to have it ported directly to another controller.

l Erasure or deletion. You may ask us to delete the personal data that we hold about you.

l Rectification or correction. You may ask us to correct any inaccurate or incomplete personal data that we hold about you.

l Objection to processing. You may request that we stop processing your personal data for specific purposes including marketing and profiling.

l Restriction of processing. You may request that we restrict the processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).

l Lodge a complaint to your local Data Protection Authority. You may have the right to lodge a complaint with your national Data Protection Authority or equivalent regulatory body.

l Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us or updating your preferences. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent.

l Automated decision-making. We do not employ solely automated decision-making, as a matter of course, that results in automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you. Automated decisions are decisions made automatically based on computer determinations (using software algorithms), without human review. If you are to be subjected to automated decision making, we will make it clear at the time and you have the right to contest the decision, to express your point of view, and to require a human review of the decision.

To exercise these rights, you may follow the procedures outlined in Section "WHAT ARE YOUR PRIVACY RIGHTS?" of this Policy, or contact us using the contact information provided in Section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?".

 

International Data Transfer

Our servers are located in Singapore. Please be aware that your information including Email Address, Passwords, Registration Timestamps, Registration Source Channel, Registration IP Address, and Logs may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see Section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), including facilities in China for operation and maintenance purposes. The European Commission has not issued an adequacy decision for China.

We implement appropriate safeguards, such as Standard Contractual Clauses (“SCCs”) and technical/organizational security measures. If you wish to obtain a copy of the SCCs, please contact us through the contact information in Section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?".

 

APPENDIX B: ADDITIONAL PROVISIONS FOR UNITED STATES RESIDENTS

This section applies to you if you are a resident of the United States. In the event of any conflict or inconsistency between this Appendix and the main body of this Policy, this Appendix shall prevail.

 

Categories of Personal Data We Collect

For a comprehensive inventory of all personal data we process, please refer to the Section "WHAT DATA DO WE COLLECT?"

 

Sources of Personal Data

Learn more about the sources of personal data we collect in Section "WHAT DATA DO WE COLLECT?".

 

How We Use and Share Personal Data

Learn more about how we use your personal data in the Section "HOW DO WE PROCESS YOUR DATA?".

 

We may disclose your personal data to our service providers pursuant to a written contract. We may use your personal data for our own business purposes, such as for internal research. This is not considered to be "selling" of your personal data.

 

We do not, and have not in the past 12 months, sold or shared any personal information. For the purposes of this section, "sale" means the disclosure of personal information to a third party for monetary or other valuable consideration, and "sharing" means the disclosure of personal information to a third party for cross-context behavioral advertising, whether or not for monetary consideration.

 

Your Rights

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal data we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal data. You may also have the right to withdraw your consent to our processing of your personal data. These rights may be limited in some circumstances by applicable law.

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

l Right to know whether or not we are processing your personal data.

l Right to access your personal data.

l Right to correct inaccuracies in your personal data.

l Right to request the deletion of your personal data.

l Right to obtain a copy of the personal data you previously shared with us.

l Right to non-discrimination for exercising your rights.

l Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").

 

How to Exercise Your Rights

To exercise these rights, you may follow the procedures outlined in Section "WHAT ARE YOUR PRIVACY RIGHTS?" of this Policy, or contact us using the contact information provided in Section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?".

 

Request Verification

Upon receiving your request, we will need to verify your identity to determine that you are the same person about whom we have the data in our system. We will only use personal data provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the data already maintained by us, we may request that you provide additional data for the purposes of verifying your identity and for security or fraud-prevention purposes.

 

If you submit the request through an authorized agent, we may need to collect additional data to verify your identity before processing your request and the agent will need to provide a written, signed permission from you to submit such request on your behalf.

 

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing DPO@ugreen.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

 

California "Shine the Light" Law

California Civil Code Section 1798.83, also known as the "Shine the Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, data about categories of personal data (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the Section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?".

 

 

APPENDIX C: ADDITIONAL PROVISIONS FOR JAPAN RESIDENTS

This section applies to you if you are a resident of Japan. In the event of any conflict or inconsistency between this Appendix and the main body of this Policy, this Appendix shall prevail.

 

Business Operator Information

Name of Business: UGREEN GROUP LIMITED

Address: 4/F, Plant 6, 1F-6/F, Block 7, YuAn Zone Gaofeng Community, Dalang Street

Longhua District, Shenzhen, China

Representative: Leijie LI

 

Purposes of Use

For information on the purposes of use of the personal information we handle, please refer to Section "WHAT DATA DO WE COLLECT?" and Section "HOW DO WE PROCESS YOUR DATA?". If we use your personal data for new purposes, we will seek additional consent from you.

 

Your Rights

We respect your rights regarding your personal information as a user in Japan. This section outlines your specific rights under Japan's Act on the Protection of Personal Information (APPI) and the procedures for exercising them.

Right to Disclosure.

You have the right to request information about:

l The personal data we hold about you.

l Our records of when and to which third parties we have provided your personal data.

Right to Correction, Addition, or Deletion

If the personal data we hold about you is inaccurate, you have the right to request that we correct, add to, or delete it.

Right to Cease Use, Delete, or Stop Third-Party Provision

You have the right to request that we stop using or deleting your personal data, or stop providing it to third parties under certain conditions, such as:

l If your data is used for purposes other than those we stated.

l If your data was collected through improper means.

l If your data was provided to third parties in violation of the APPI.

l If we no longer need to use your data.

This right also applies in situations where a data breach has occurred or your rights might be harmed.

Right to Request Information on Protective Measures

You also have the right to request more detailed information about the measures we take to protect your data, specifically:

l Security Control Measures: A summary of the measures we implement to keep your data safe.

l Cross-Border Transfers: When we transfer your data to third parties in other countries, you can request information about the data protection systems of that country and the measures the recipient takes to protect your data.

To exercise these rights, you may follow the procedures outlined in Section "WHAT ARE YOUR PRIVACY RIGHTS?" of this Policy, or contact us using the contact information provided in Section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?".

 

Cross-Border Transfer

Your personal data may be shared with the entities described in Section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?". If those recipient entities are outside of Japan, we will implement reasonable endeavors to require recipients located outside Japan protect it in a way that provides comparable safeguards to those under the APPI, such as via contractual data protection obligations or because the recipient is subject to laws of another country with comparable protections. Specifically, we take Equivalent Action specified under Article 28 (1) of the APPI to protect your personal data transferred outside of Japan.