Privacy Policy

Effective Date: December 9, 2025

I. Who We Are

This website is operated by Gramuu New Energy (Hangzhou) Co., Ltd. (hereinafter referred to as "we" or "Gramuu"), registered address: Room 201, Building 6, Xixi Chenyue, Intersection of Fengshu Road and Shuanglong Street, Jiangcun Subdistrict, Xihu District, Hangzhou City, Zhejiang Province, China. This policy explains how we collect, use, store, share, and protect your personal information when you visit www.gramuu.com and its related products/services.

II. What Information We Collect

1. Information you provide: Name, phone number, email address, company/position, address, billing information, etc.
2. Automatically collected information: IP address, browser type, operating system, access date, referring/exit pages, Cookie identifiers.
3. Third-party sources: Social media platforms such as WeChat/QQ/DingTalk (only when you authorize login, we obtain your avatar, nickname, and OpenID).

III. Purpose of Collection

• To provide you with product information, quotations, contracts, or after-sales service;
• To send you marketing information (only with your explicit consent);
• To conduct website traffic analysis and optimize user experience;
• To fulfill legal obligations (such as tax and accounting archiving).

IV. Legal Basis (primarily based on China's Personal Information Protection Law)

• Obtaining your consent;
• To fulfill a contract or provide pre-contractual services at your request;
• To fulfill legal and regulatory obligations;
• Legitimate interests (such as fraud prevention, product improvement).

V. How We Use Cookies

We use Session Cookies to maintain login status and use analytical Cookies (such as Google Analytics, Baidu Statistics) to analyze access behavior. You can refuse or delete Cookies in your browser settings, but some functions may not be available.

VI. Information Sharing, Transfer, and Disclosure

1. Internal sharing: Limited to necessary employees and subject to the principle of least privilege.
2. Third-party service providers: Cloud hosting (Alibaba Cloud), CRM system (such as Salesforce), email sending platform (such as SendCloud). We have signed data processing agreements with them to ensure compliance with laws and regulations.
3. Legal disclosure: We may disclose your information to the extent necessary in accordance with the requirements of courts and government authorities.
4. Mergers/Acquisitions: In the event of an asset transfer, the recipient of the information must continue to be bound by this policy.

VII. Information Storage and Cross-border Transfer

Data is stored on cloud servers within mainland China. If cross-border transfer is required for business purposes, we will obtain your separate authorization and conduct a security assessment in accordance with the law.

VIII. Information Retention Period

• Potential customer information: If no cooperation occurs and there is no interaction within 2 years, the information will be deleted or anonymized;
• Contract/Order information: Retained for 10 years from the date of transaction completion to meet tax and accounting record requirements;
• Marketing subscription data: Deleted within 30 days after you unsubscribe or withdraw your consent.

IX. Your Rights

According to the Chinese Personal Information Protection Law, you have the right to:

1. Access and copy your personal information;
2. Correct incomplete or inaccurate information;
3. Delete your personal information (except where laws and regulations specify a different retention period);
4. Withdraw consent or cancel your account;
5. Request us to explain our information processing rules.

To exercise the above rights, please submit your request through the channels listed in "XIII. Contact Us," and we will respond within 15 business days.

X. Information of Minors

Our products/services are intended for individuals aged 18 and above. If you are a minor under the age of 14, please read this policy with your guardian and obtain their consent before providing any information. If we discover that we have collected information from a minor without consent, we will delete it as soon as possible.

XI. Information Security Measures

We employ measures such as SSL encrypted transmission, database hierarchical access control, the principle of least privilege, off-site backup, and bastion host operation and maintenance auditing to prevent unauthorized access, disclosure, use, modification, damage, or loss of data. However, the internet is not absolutely secure. In the event of a security incident, we will promptly fulfill our reporting and notification obligations.

XII. Policy Updates

We may update this policy from time to time. The revised version will be published on the "Privacy Policy" link at the bottom of our official website and will indicate the "effective date," without separate notification. If the changes involve significant adjustments to your rights, we will seek your renewed consent through pop-ups, emails, or text messages.

XIII. Contact Us

• Data Protection Officer (DPO): Francis Fang
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• Mailing Address: Room 201, Building 6, Xixi Chenyue, Intersection of Fengshu Rd. and Shuanglong Street, Jiangcun Subdistrict, Xihu District, Hangzhou, Zhejiang, China

If you are not satisfied with our response, and a personal information protection regulatory authority exists in your region, you have the right to file a complaint or report to that authority.

Appendix: Cookie List