Personal Information Protection Policy
Initial Effective Date:17/11/2023
Last Updated Date:10/10/2025
This Website Privacy Policy ("Privacy Policy") applies to UGREEN GROUP LIMITED and its affiliates (AMERICA UGREEN LIMITED,HONG KONG UGREEN LIMITED,UGREEN JAPAN CO., LTD. and UGREEN GROUP GMBH) hereinafter referred to as “Ugreen,” “we,” “us,” and “our”. We recognize that privacy is an ongoing responsibility and will therefore update this Privacy Policy from time to time update this Privacy Notice as we adopt new personal data practices or adopt new privacy policies.
This Privacy Policy describes how Ugreen collects and uses the personal information you provide on our website located at: ugnas.com (“Website”). This Privacy Policy does not govern the use of Ugreen products or services offered under contract to Ugreen customers. To view our Product Privacy Policy, click here.
This policy is intended to help you understand:
1. WHAT PERSONAL DATA WE COLLECT AND HOW WE USE IT
2. HOW WE DISCLOSE YOUR PERSONAL DATA
3. HOW WE PROTECT YOUR PERSONAL DATA
4. DATA RETENTION
5. HOW WE SHARE, ASSIGN, AND DISCLOSE YOUR PERSONAL INFORMATION
6. YOUR RIGHTS
7. CHILDREN'S PRIVACY
8. UPDATE
9. CONTACT INFORMATION
1.WHAT PERSONAL DATA WE COLLECT AND HOW WE USE IT
A. Data that you provide to us directly and voluntarily
(1)Apply for an experience account
You can apply for a Green Link Private Cloud Experience account to experience our private cloud services before the official purchase, for which you need to provide your mobile phone number and submit a temporary verification code, which is to meet the national requirements on the network real name system.
(2)Vulnerability submission
If you find or believe that you have found a potential security vulnerability or security incident in the use of NAS services, we thank you for reporting it to us. In order to facilitate us to locate, verify and handle the vulnerability and security incident more accurately, please provide us with the vulnerability name, vulnerability classification, vulnerability type and vulnerability details. You can choose whether to upload attachments (such as relevant screenshots, etc.). In order for us to get in touch with you, please also provide your email address, we will not use your email address for other purposes. We collect and use this information based on your consent.
(3)Marketing Communications And Subscriptions
You can provide your email address to subscribe to our news, newsletters, product updates, and other marketing information. We promise to use your email address only to send the content you request and not for any other purposes. You can unsubscribe by clicking “unsubscribe”.
Apart from sending marketing-related information, we may also use your email address to send you questionnaire. The purpose of the questionnaire survey is to collect your feelings, preferences and suggestions on the use of UGREEN products, so that we can improve and optimize the products.
We will respect your choice and process your request promptly upon receipt.
(4) From UGOS System To UGOS Pro System Of Nas Device
If you want to switch your NAS device from UGOS system to UGOS Pro system, you need to fill in the device serial number, phone number of device administrator, and temporary verification code for cloud verification. The cloud will push firmware upgrade information in batches based on the successfully applied device serial number.
(5) Feedback submission
To better understand your experience with our products and to continuously improve and optimize relevant product features, you may contact us through the Feedback function. When submitting your feedback, you are required to provide your contact method (WeChat ID, mobile phone number, or email address) so that we may, when necessary, reach out to you regarding your feedback for verification, clarification, or response purposes.
B. Data that we collect automatically
We’ll store small data files using cookies or similar technologist on your terminal devices subject to the legal requirements when you browse our website. By using cookies or similar technologies, we may collect your device type, IP address (country or region), NAS device initialization status, the number of NAS devices found on the local area network, and operational usage data (such as the time you stay on our website, pages accessed to, source URLs, language preferences, etc.). Such information collected is used to ensure the security and efficiency of the website, analyze website statistics, optimize user experience, and troubleshoot issues such as crashes and delays. You can manage or delete cookies according to your preferences. If you choose to reject or clear all saved cookies, you may need to reset your preferences each time of your access.
2. HOW WE DISCLOSE YOUR PERSONAL DATA
We do not share your information with a third party for their independent use unless: (1)you request , (2) you authorize it, or (3) it is required by law.
3. HOW WE PROTECT YOUR PERSONAL DATA
We take appropriate technical and organizational measures to ensure the security of your personal data.
We have taken appropriate security measures to protect your personal data and prevent unauthorized access, manipulation, damage or loss. We use encryption techniques to secure the transmission of your personal data. We use appropriate encryption, access control and identity verification technologies for stored personal data. We also appropriately restrict the access rights of our employees. In addition, we regularly create backup copies of personal data in order to be able to restore access to this data in the event of physical or technical incidents.
To address potential risks of leakage, damage and loss of personal data (referred to as “personal data security incidents"), we have developed a contingency plan for such incidents and conduct regular drills.
While we strive to protect your personal data, no internet transmission method or security system is perfect and we cannot guarantee that your data will be secure in all circumstances. You are often in the best position to protect yourself online. It is your responsibility to protect your login ID and password from access by third parties and to choose strong passwords.
4. DATA RETENTION
We will retain Personal Data where we have a justifiable business need to do so and/or for as long as is needed to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (e.g. for anti-money laundering, accounting or other purposes). When we do not have no justifiable business need to process your personal data, we will either delete it or, if this is not possible (e.g. because your personal data has been stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible.
5. HOW WE SHARE, ASSIGN, AND DISCLOSE YOUR PERSONAL INFORMATION
5.1.Sharing
Your personal information will not be shared with any entities other than UGREEN or its affiliates, except under the following circumstances:
(1) We receive your or your guardian's explicit authorization or consent.
(2) Judicial or administrative agencies demand disclosure as part of legal proceedings;
(3) We engage in legal action or arbitration against a user to protect our legal rights;
(4) Such sharing is necessitated by the service agreement or usage rules between you and UGREEN;
(5) To prevent infringement of the legal rights of UGREEN, its affiliates, users of our service, and the public to the extent permitted by law;
(6) The sharing complies with agreements made between you and third parties.
(7) The information is utilized for academic research purposes.
5.2.Assignment
We will not transfer your personal information to any company, organization, or individual outside of UGREEN's affiliates, except under the following circumstances:
(1)With your express prior authorization and consent;
(2) To comply with legal obligations, legal proceedings, mandatory government directives, and court orders;
(3) In cases of mergers, separations, bankruptcy liquidation, or acquisition/sale of our or our affiliates' business, your personal information may be transferred as part of the transaction. We will ensure confidentiality during the transfer and require the successor entity to adhere to this privacy policy, or otherwise, seek your reauthorization.
5.3.Disclosure
We will only publicly disclose your personal information under the following circumstances:
(1) With your express prior consent;
(2) In compliance with laws, legal proceedings, lawsuits, or government orders.
5.4.Exceptions to Obtaining Your Consent when Sharing, Assigning, or Disclosing Your Personal Data
Please be aware that in certain instances, we may share, assign, or disclose your personal data without prior authorization or consent:
(1) The request is directly related to national defense and security;
(2) The request is related to public security, public health, and other material public interests;
(3) In circumstances directly involving criminal investigations, prosecutions, trials, or court order execution;
(4) To protect vital legal rights, such as the life and property of the data subject or other individuals, when obtaining consent is not possible;
(5) If the personal data has been publicly disclosed by the data subject;
(6) Personal data obtained from legally disclosed information sources, including without limitation news reports, government information disclosure, and other legal channels.
6.YOUR RIGHTS
Your Rights include :
(1) Access and portability. You may ask us to confirm whether we are processing your personal data, provide you with details about what we have collectted and how we process your personal information,and, in some limited circumstances, 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.
(2)Rectification or correction. You may ask us to correct any inaccurate or incomplete personal data that we hold about you.
(3)Erasure or deletion. You may ask us to delete the personal data that we hold about you.
(4)Objection to processing including marketing and automated decision-making. You may request that we stop processing your personal data for specific purposes including marketing and profiling.
(5) Restrict the Processing or disclosure of Personal Information
You have the right to restrict the Processing or disclosure of their Personal Information where appropriate and in accordance with applicable law(for example, where you believe that the personal data we hold about you is not accurate or lawfully held),such as , blocking, or deletion of unnecessary or excessive personal information, or personal information not processed in compliance with those laws.
(6)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.
(7)Withdraw Consent
We process most of your personal information on the basis of your consent. You have the right to give your consent ,and you also have the right to withdraw your consent.
(8)Account Closure
If you have registered an account, you have the same right to close your account.
This Policy does not create, extend, or modify rights , you may have all or some of the above rights, or other rights, under applicable law. These rights are not absolute and are subject to conditions or limitations as specified in applicable laws. If you would like to exercise any of the above rights, please contact us using the details in the end of this Policy. We will process your request in accordance with applicable privacy and data protection laws. To protect your privacy and security, we may take steps to verify your identity before dealing with the request.
Reasonable requests are typically processed free of charge. We reserve the right to deny requests that are unjustifiably repetitive, technically burdensome (such as by necessitating the development of new systems or fundamentally amending current practices), infringe on others' legal rights, or are impractical (such as requests involving data on backup tapes).If denied, we will notify you of the reasons for the denial and you have the right to appeal the denial , file a complaint,or seek other remedies consistent with applicable law.
7.PRIVACY FOR CHILDREN
We do not knowingly attempt to solicit or receive information from children. If you are a parent of a child and believe that your child has provided us with information about themselves, please contact us using the information in the Contact Us section below.
8.UPDATE
We may update this Privacy Policy if applicable law and our business practices change. When this policy is updated, we will notify you via a pop-up window on our website or we will seek your consent again.
9. CONTACT INFORMATION
If you have any questions or concerns about this Privacy Policy, please contact us at service@ugreen.com.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.