Privacy Policy
Effective Date: [2026.02.11]
Version: V2.0

1. Introduction

PINGBO TECHNOLOGY LIMITED (hereinafter referred to as "we") fully recognizes the importance of your personal information and consistently adheres to the principles of "legality, legitimacy, necessity, and good faith" in protecting the security of your personal information and your privacy rights.

This Privacy Policy applies solely to your access, browsing, and use of our official website (plugos.net), and is not related to any product features. Please carefully review this Policy prior to accessing our official website and using our services, in particular the bold-faced clauses that are closely related to your legitimate rights and interests. Your continued access to or use of our official website and services shall constitute your full understanding of, and unconditional consent to, our processing of your personal information in accordance with the terms of this Policy. If you do not agree to this Policy, you may discontinue your use of our official website and services; provided that you may thereby be unable to access certain core services.

2. The personal information we collect

Personal Information refers to any information recorded in electronic or other forms that relates to an identified or identifiable natural person, excluding information that has been anonymized. When you use our website or services or interact with us, we may collect your Personal Information. The specific types of data collected will vary depending on the website and services you use and your interactions with us. You are not obligated to provide Personal Information to us; however, in certain circumstances, if you choose not to do so, we may be unable to provide you with the relevant services, or to respond to or resolve the issues you encounter.

We may also collect aggregated statistical data such as website traffic, application downloads, and product sales to understand how users utilize our products and services. For the purposes of this Policy, such statistical data is deemed Non-Personal Information. We will make efforts to segregate your Personal Information from Non-Personal Information and use the two types of data separately. If Personal Information is combined with Non-Personal Information, it will still be treated as Personal Information.

We collect only personal information to the extent necessary for "realizing service functions, fulfilling contractual obligations, and ensuring user safety," and we do not collect any information irrelevant to the aforementioned purposes. This information is specifically categorized into the following three types:

2.1 Personal information necessary for basic functions

This type of information is a prerequisite for the normal operation of the core services. If you do not provide it, you may not be able to use the corresponding basic functions:

Orders and Transactions

When you purchase products/services on our official website, you are required to provide the recipient's name, E-mail, contact phone number, shipping address (for logistics and delivery), and payment-related information (such as bank card number or payment platform account information). Please note that complete payment information is processed by our cooperating payment institutions, and we do not store full bank card numbers.

Device and Technical Information

Your device (e.g., computer or mobile phone) may automatically send technical information to us, including device model, operating system version, browser type. This information is used to ensure website compatibility and prevent cyber attacks.

You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our services or respond to requests you may have.

This type of information is used to enhance your service experience. If you choose not to provide it, the use of basic functions will not be affected; however, you may not be able to access personalized and convenient services:

Customer support and feedback: When you consult or provide feedback via online customer service, feedback forms, emails, or phone calls, you may need to provide your name, description, E-mail, country or product serial number. This information is used to quickly locate problems and follow up on processing results (e.g., providing product serial numbers for equipment troubleshooting).

2.3 Personal information obtained from third parties

With your explicit authorization, we may obtain your information from legally compliant third parties, including:

3. How we use your personal information

We only use personal information within the scope of this policy statement, and the specific purposes include:

Providing and maintaining services: We collect personal data necessary to deliver our services, which may include data used to improve our offerings, conduct internal audits or data analysis, or perform troubleshooting. Examples include:

Optimizing and improving services: Where applicable, if you opt for personalized services or communications, we will use the information we collect to provide such personalized experiences. For services requiring the use of your personal data, you may review the privacy information displayed when first using the service to learn more about how the relevant service uses this information to deliver personalized experiences.

Security Assurance: We use device information to:

Marketing and Communication: With your consent, we will send you product update notifications and promotional activity reminders (e.g., new product launch emails, holiday discount messages). You may unsubscribe from marketing messages at any time by clicking the "Unsubscribe" link at the bottom of the email.

We do not use algorithms or profiling to make any decisions that would significantly affect you without the opportunity for human review.

We retain personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law. We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy summaries. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal data for the shortest possible period permissible under law.

4. Sharing, Transfer, and Disclosure of Personal Information

We do not share personal data with third parties for their own marketing purposes. We strictly control the external flow of personal information and only share, transfer, or disclose it in accordance with applicable laws, with robust security measures in place at every step:

4.1 Share

Sharing refers to the provision of Personal Information by us to other personal information processors, where both parties independently determine the purposes and methods of processing in their respective personal information handling activities. We generally do not share your Personal Information with external parties, except in the following circumstances:

Sharing with Consent: After obtaining your consent, we will share your information within the scope of your authorization with third parties designated by you;

Sharing under Statutory Circumstances: We may share your Personal Information externally in accordance with the provisions of laws and regulations, the needs of litigation dispute resolution, or the requirements legally imposed by administrative or judicial authorities;

Sharing with Business Partners: We may share your order information, account information, device information, and location information with third parties such as partners to ensure the smooth provision of services to you. However, we will only share your Personal Information for legitimate, necessary, specific, and clear purposes, and will only share the Personal Information necessary to provide the services. Our partners include:

We will conduct a security assessment of the sharing activity and the recipient of the Personal Information, and sign a data protection agreement or a strict confidentiality agreement with the recipient, requiring them to process Personal Information in accordance with this Policy and adopt relevant confidentiality and security measures.

We entrust third parties to provide you with supporting services such as logistics, payment, customer service, and data analysis. We only disclose to them the information necessary to complete the services. Through signing a Data Processing Agreement (DPAs) with the third parties, we restrict their behavior, clarifying that they may only use the information within the authorized scope, adopt security measures such as encryption, shall not re-disclose it to other parties, and we conduct regular compliance reviews of the third parties.

4.2 Transfer

Transfer refers to the conveyance of control over your Personal Information to another company, organization, or individual. We will not transfer your Personal Information to any company, organization, or individual unless we have obtained your express consent, except in the following circumstances:

4.3 Public Disclosure

Public Disclosure refers to the act of releasing information to the public or to an unspecified group of people. In principle, we will not publicly disclose your Personal Information, except in the following circumstances:

5. How We Protect Your Personal Information

5.1 Technical Measures

We employ a variety of technical means to protect the security of your Personal Information, including but not limited to: not offering user registration functionality, encrypting data at rest and in transit, implementing access controls, and setting up firewalls. We enforce strict security management over the servers storing your Personal Information to prevent unauthorized access, tampering, or disclosure of data.

5.2 Organizational and Administrative Measures

We have established comprehensive internal management systems and processes. We conduct privacy protection training for our employees, clarifying their responsibilities and authorities in processing Personal Information. This ensures that employees strictly adhere to this Privacy Policy and applicable laws and regulations, and handle your Personal Information properly.

5.3 Security Incident Response

In the event of a Personal Information security incident, we will immediately activate our contingency plan, take reasonable measures to mitigate the impact, and promptly notify you and the relevant regulatory authorities in accordance with legal requirements. We will inform you of the basic details of the incident, its potential impact, and the measures that have been taken or will be taken.

5.4 Sensitive Personal Information

Sensitive personal information includes financial, precise location, health, biometric data and minors’ information. We process it only as permitted by the Personal Data (Privacy) Ordinance (PDPO), Article 9 of GDPR and CCPA/CPRA, adhering to these regulations’ core requirements and adopting stricter protection measures.

We strive to protect your Personal Information. However, no measure is impenetrable, and no product, service, website, data transmission, computer system, or network connection can be guaranteed to be absolutely secure.

6. The Use of Cookies and Other Tracking Technologies

To optimize your user experience and analyze website traffic, we or our third-party partners may use the following tracking technologies. You may independently manage relevant permissions:

A cookie is a text file stored by a web server on a computer or mobile device, and the content of a cookie can be retrieved and read only by the server that created the cookie. Cookies are unique to the browser or mobile application you are using. The text in a cookie often consists of identifiers, site names, and some numbers and characters.

Similar to cookies, local shared objects (also called "Flash cookies") and HTML5 local storage store information on your device and can record some information about your activities and preferences.

Cookies are categorized as follows:

Necessary cookies: Essential for ensuring basic functions of the official website (e.g., maintaining login status, saving shopping cart contents). These cannot be disabled; disabling them may prevent functions such as order submission and account access.

Function cookies: Remember your preferences (e.g., language settings, font size) so you do not need to reset them on subsequent visits.

Management method: You may disable non-essential cookies through your browser settings (e.g., Chrome: "Settings - Privacy and Security - Cookies and Other Site Data"). However, this may affect your service experience.

If you clear your cookies, you will need to manually reset your user preferences each time you visit this website. Please also note that some of our services may require the use of cookies. Disabling cookies may affect your ability to use all or part of the functionality of these services.

6.2 Other Tracking Technologies

In addition to cookies, we also use web beacons and pixel tags on this website. A web beacon is usually an electronic graphic image embedded into a website or email to identify your device cookies when you browse the website or email. Pixel tags allow us to send emails in a way that is readable to you and find out whether you opened the email or not. For example, when you receive an email from us, it may contain a click-through URL which links to a web page. If you click the link, We will track your visit to help us learn about your preferences for products and services and improve our customer service. You can unsubscribe from our emails if you do not want to be tracked via emails.

Web beacons (transparent GIFs, pixel tags): Embedded in official website pages or marketing emails to count page visits and confirm email open rates. They do not collect personal identification information.

Embedded script: Used to implement functions such as "online customer service pop-ups" and "share buttons." They are only activated when you use the corresponding functions, and the collected information is limited to what is necessary for function implementation.

7. Retention and Security of Personal Information

7.1 Retention

We retain your personal information for no longer than necessary to fulfill the purposes stated in this Policy, unless extending the retention period is required or permitted by law. Data storage periods may vary by scenario, product, and service. Our retention period assessment criteria include:

7.2 Safety Precautions

We adopt a dual approach of "technology + management" to ensure your information security:

Technical protection:

Management standards:

Important Note: Internet transmission is not absolutely secure. Despite the above measures, we cannot completely eliminate the risk of unauthorized access to information. If you detect any account abnormalities (e.g., unrecognized logins, unusual orders), please contact us immediately to freeze your account, and we will assist you in identifying and mitigating risks.

8. Your rights to Personal information

You have the following rights, and we provide convenient channels for exercising them:

8.1 Right of Access and Inquiry

You have the right to access and inquire about your personal information held by us. You may exercise this right through the following method:

Sending an email to support@trustkernel.com to submit an access request (e.g., inquiry about customer service communication records). When submitting the request, please provide sufficient information to verify your identity (e.g., phone number, order number).

We will verify your identity and respond to your request within one month from the date of receiving the valid request. If the request is complex or involves a large amount of data, we may extend the response period by another month, and we will notify you in writing of the extension and the reason for it in advance.

We will provide you with a copy of your personal information free of charge in a commonly used electronic format. If you request additional copies, we may charge a reasonable fee based on the actual administrative costs. If we refuse your access request, we will inform you in writing of the specific reasons and the legal basis therefor, and also inform you of the channel to file a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD).

8.2 Right to Correction and Supplementation

If you find that your personal information we hold is inaccurate (e.g., incorrect delivery address) or incomplete (e.g., missing recipient name), you have the right to request us to correct or supplement it. You may exercise this right through the following method:

Sending an email to support@trustkernel.com to submit a correction request, and attaching relevant supporting documents if necessary. We will verify your identity and process your request within one month from the date of receiving the valid request (extension is possible under complex circumstances, with prior written notification).

If we refuse your correction request, we will inform you in writing of the specific reasons and the legal basis therefor, and also inform you of the channel to file a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD).

8.3 Right to Erasure

You may request the deletion of your personal information in the following circumstances (including but not limited to):

Operation Channel: Send an email to support@trustkernel.com to request the deletion of specific information, and provide sufficient information to verify your identity. We will verify your identity and complete the deletion within one month from the date of receiving the valid request (extension is possible under complex circumstances, with prior written notification).

Notwithstanding the foregoing, we will not delete the information that is required to be retained by law (such as order records for tax filing purposes).

Important Note: After you delete content from public areas of the official website (e.g., comment sections, forums), cached versions or search engine archives of the content may still be visible. We have no control over third-party platforms (such as search engines), and we appreciate your understanding.

8.4 Right to Restriction of Processing

You have the right to request us to restrict the processing of your personal information in the following circumstances:

When the processing of your personal information is restricted, we will only process it with your consent, or for the purpose of exercising, defending or claiming legal rights, or for protecting the rights and interests of other individuals or legal persons, or for the purpose of important public interests of the European Union or a Member State.

Operation Channel: Send an email to support@trustkernel.com to submit a request for restriction of processing, and provide sufficient information to verify your identity. We will verify your identity and respond to your request within one month from the date of receiving the valid request.

8.5 Right to Data Portability

You have the right to obtain your personal information held by us in a structured, commonly used and machine-readable format, and have the right to transmit such personal information to another data controller without hindrance from us, provided that:

If technically feasible, you may request us to directly transmit your personal information to another data controller, and we will try our best to meet such request.

Operation Channel: Send an email to support@trustkernel.com to submit a data portability request, and specify the desired format of the data and the relevant information of the target data controller (if direct transmission is required). We will verify your identity and respond to your request within one month from the date of receiving the valid request.

Revoke Permission Authorization: You may revoke your authorization of the relevant permissions (such as "location" and "camera") by adjusting the settings in your device's operating system. The revocation of consent will not affect the legality and validity of the processing of your personal information conducted by us based on your prior consent before the revocation.

Unsubscribe from Marketing Information: You may opt out of receiving marketing information by clicking the "Unsubscribe" link at the bottom of marketing emails. In addition, you have the right to request us to stop using your personal information for direct marketing purposes at any time, and we will immediately stop such use upon receiving your valid request.

8.7 Right to Object

You have the right to object to our processing of your personal information in the following circumstances:

Operation Channel: Send an email to support@trustkernel.com to submit an objection request, specifying the specific processing activity you object to. We will verify your identity and respond to your request within one month from the date of receiving the valid request.

8.8 Right to Object to Automated Individual Decision-Making, Including Profiling

You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

If we make such a decision, we will ensure that you have the right to obtain human intervention, to express your views and to challenge the decision.

If you believe that we have made a decision based solely on automated processing that affects you, you may send an email to support@trustkernel.com to request human intervention and challenge the decision. We will verify your identity and respond to your request within one month from the date of receiving the valid request.

8.9 Right to Lodge Complaints and Appeals

If you believe that our processing of your personal information violates applicable laws, regulations or this Policy, you may lodge a complaint through the following channels:

We will handle your complaint seriously and provide feedback on the handling result within the time limit specified by applicable laws and regulations.

9. Protection of Minors' Privacy

We value minors' personal information protection. Without a user registration system, we cannot proactively identify ages, we rely on your guardian to fulfill their supervisory responsibilities, our practices are as follows:

Age-Based Consent Requirements:

Rights of Minors and Guardians:

Consequences of Non-Consent or Deletion:

Remedial Measures for Unauthorized Collection:

To ensure a smooth browsing experience, our websites, applications, products and services may contain links to third-party websites, products and services. Our products and services may also use or provide third-party products and services (e.g., pre-installed third-party applications). We have no control over such third parties. You may choose whether to access the links, content, products and services provided by third parties.

We have no control over the privacy or data protection policies of third parties, and such third parties are not bound by this Policy. Before submitting your personal information to any third party, please read and refer to their respective privacy or data protection policies.

11. Updates of the Privacy Policy

We may revise this Policy due to changes in laws and regulations, business adjustments (e.g., adding new service functions), or user needs. The update rules are as follows:

Revision and Notification: Optimizations or changes to the Privacy Policy will be directly updated on the "Privacy Policy" page of the official website, with a new "Effective Date" clearly marked. Your continued access to or use of the official website following the update will constitute your acceptance of the revised Policy;

Recommendation: We recommend that you regularly visit the "Privacy Policy" page on the official website to review the latest version.

12. Contact Us

If you have any questions about this Policy, need to exercise your personal information rights, or provide feedback on privacy-related issues, please contact us through the following channels:

Privacy Protection Email: support@trustkernel.com;

Official website feedback: Open the official website, navigate to "About - Contact Us" and submit your inquiry.

After receiving your request, we will first verify your identity (e.g., verifying your name, phone number, and account information), then process your request in accordance with laws, regulations, and this Policy, and provide feedback on the results within the prescribed time limit.

13. Supplementary Provisions

If any provision of this Privacy Policy is wholly or partially invalid or unenforceable for any reason, the remaining provisions of this Privacy Policy shall remain valid, binding and enforceable.

The headings of all provisions of this Privacy Policy are for ease of reading only and have no actual meaning in themselves and cannot be used as a basis for the interpretation of the meaning of this Privacy Policy and related provisions.

The Company's failure to exercise in a timely manner or insufficient exercise of the rights it enjoys under this policy or in accordance with laws and regulations shall not be regarded as a waiver of such rights, nor shall it affect the Company's exercise of such rights in the future.

We reserve the right to modify, add, delete or update this Privacy Policy.

If you believe that our processing of personal information has harmed your legitimate rights or interests, you may also file a complaint with relevant government authorities. If there is any dispute arising out of this Privacy Policy and our processing of your personal information, you may file a complaint with District Court of the Hong Kong Special Administrative Region.