Privacy Policy

# Privacy Policy

**Effective Date: March 23, 2025**

## 1. Introduction

This Privacy Policy ("Policy") sets forth the manner in which personal information is collected, used, disclosed, and safeguarded when you ("User," "you," or "your") access or utilize our website or marketplace services (collectively, the "Services") for the procurement of Chromebooks and other hardware products intended for educational purposes.

## 2. Corporate Identity

We operate as a specialized provider of technology hardware solutions, with particular emphasis on Chromebooks and related educational technology products, serving both individual students and educational institutions (hereinafter referred to as "the Company," "we," "us," or "our").

## 3. Information Collection Practices

### 3.1 Information Voluntarily Provided

In the course of your interactions with our Services, we may collect the following categories of personal information that you voluntarily provide:

- Personal identifiers (including but not limited to name, email address, telephone number, postal address)

- Financial information (including billing details and payment instrument information)

- Institutional affiliation data (for purchases made on behalf of educational entities)

- Authentication credentials and user preferences

- Transaction history and product interest indicators

- Customer service correspondence and feedback submissions

### 3.2 Information Collected Through Automated Means

Our technological infrastructure may automatically collect certain information when you access our Services, including:

- Device specifications (including device type, operating system version, browser configuration)

- Internet Protocol address and geolocation data

- Website navigation patterns and usage metrics

- Cookies, web beacons, and analogous tracking technologies

- Referral source identifiers and session duration statistics

## 4. Utilization of Collected Information

The Company processes your personal information for the following specified purposes:

- Execution and fulfillment of commercial transactions

- Administration of user accounts and provision of customer assistance

- Facilitation of secure financial transaction processing

- Customization of user experience based on demonstrated preferences

- Transmission of transactional notifications and status updates

- Distribution of marketing communications (subject to applicable legal requirements)

- Enhancement of Services through analytical insights

- Adherence to legal and regulatory obligations

- Prevention and detection of fraudulent activities

## 5. Legal Basis for Information Processing

Our processing activities are predicated upon the following legal foundations:

- Execution of contractual obligations between the Company and the User

- Pursuit of legitimate commercial interests of the Company

- Express consent provided by the User, where specifically solicited

- Fulfillment of legal and regulatory requirements

## 6. Information Disclosure Practices

### 6.1 Service Providers

The Company may disclose personal information to third-party vendors and service providers who perform functions on our behalf, including payment processing entities, logistics providers, and information technology service providers, all of whom are contractually obligated to process personal information in accordance with our instructions and applicable data protection laws.

### 6.2 Educational Institutions

In the context of institutional procurement, order information may be shared with duly authorized representatives of the purchasing educational institution.

### 6.3 Legal Compliance

The Company reserves the right to disclose personal information when required by law, court order, or other legal process, or when reasonably necessary to protect our legal rights or the safety and security of others.

### 6.4 Corporate Transactions

In connection with a corporate merger, consolidation, restructuring, sale of substantially all of our assets, or other corporate reorganization, personal information may be transferred as a business asset.

## 7. Data Retention Policy

The Company retains personal information for the duration necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is mandated by applicable law, regulatory requirements, or legitimate business needs.

## 8. User Privacy Rights

Subject to applicable jurisdictional laws, Users may be entitled to exercise the following rights with respect to their personal information:

- Right to access and obtain a copy of personal information

- Right to rectification of inaccurate or incomplete personal information

- Right to erasure of personal information

- Right to object to or restrict certain processing activities

- Right to data portability

- Right to withdraw previously granted consent

- Right to file a complaint with the appropriate supervisory authority

To exercise any applicable rights, Users may submit a request utilizing the contact information provided in Section 14 of this Policy.

## 9. Children's Privacy Protections

The Company's Services are not directed toward individuals under the age of sixteen (16). The Company does not knowingly collect personal information from individuals under sixteen (16) years of age. In the event the Company becomes aware of having collected personal information from an individual under sixteen (16) years of age, such information will be promptly deleted. If you believe the Company possesses information from or about an individual under sixteen (16) years of age, please contact the Company immediately.

## 10. Security Measures

The Company implements commercially reasonable technical, administrative, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. Nevertheless, no electronic transmission or storage technology is completely secure, and the Company cannot guarantee the absolute security of information transmitted to or through our Services.

## 11. Cookies and Tracking Technologies

The Company employs cookies and similar tracking technologies to enhance site functionality, analyze usage patterns, and personalize content. Users may manage cookie preferences through their browser settings or other available controls.

## 12. Third-Party Links

The Company's website may contain hyperlinks to external websites operated by third parties. The Company exercises no control over these third-party websites and bears no responsibility for their content or privacy practices. Users are advised to review the privacy policies of any external websites they visit.

## 13. International Data Transfers

Personal information may be transferred to and processed in countries other than the User's country of residence. These countries may have different data protection laws than those in the User's jurisdiction. The Company shall ensure that appropriate safeguards are implemented to protect personal information in accordance with applicable law when transferring such information internationally.

## 14. Policy Amendments

The Company reserves the right to modify this Privacy Policy at any time, at its sole discretion. Material changes to this Policy will be communicated by posting the revised Policy on our website with an updated Effective Date. Users are encouraged to periodically review this Policy to remain informed of our information practices.

## 15. Contact Information

For inquiries, concerns, or requests regarding this Privacy Policy or the Company's data processing practices, please contact:

[Legal Name of Company]  

[Registered Address]  

[Official Email Address for Privacy Inquiries]  

[Telephone Number]

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This Privacy Policy is designed to provide transparency regarding our data processing practices and to comply with applicable privacy laws, including but not limited to the General Data Protection Regulation (EU) 2016/679, the California Consumer Privacy Act of 2018, and other applicable state and international data protection regulations.