Last Updated: July 1, [2026]
Effective Date: July 7, [2029]
Version Number: [V1]

[Zhejiang Sunny Smart Technology Co., Ltd.] (Registered Address: [No. 67-69, Fengle Road, Yangming Subdistrict, Yuyao City, Zhejiang Province], Contact Information: [Yue Jinxin zlyuejx@sunnyoptical.com], hereinafter referred to as “we”) is the operator of [Official Website]. We place great importance on protecting the personal information and privacy of our users (hereinafter referred to as “you”). When you use the 【Official Website】, we will process your relevant personal information. To fully explain how we process your personal information, we have formulated the 【Official Website】 Privacy Policy (hereinafter referred to as “this Privacy Policy” or “this Policy”), and we commit to processing your personal information strictly in accordance with this Privacy Policy.

We hereby remind you:
This Privacy Policy applies to information collected through the products or services (collectively referred to as “Services”) that we provide to you via the 【Official Website】. If a specific service on the [Official Website] has separate rules governing the processing of personal information, those separate rules shall take precedence; for matters not covered by such rules, this Privacy Policy shall apply. However, this Policy does not apply to information collected by third parties integrated into the [Official Website]; if you use services provided by a third party, you will be subject to that third party’s privacy policy (rather than this Policy).

 

This Privacy Policy will help you understand the following:
I. How we collect your personal information
II. How we use your personal information
III. How we store your personal information
IV. How we entrust the processing of, provide to third parties, transfer, and publicly disclose your personal information
V. How we protect your personal information
VI. How you can manage your personal information
VII. How we handle the personal information of minors
VIII. How this Privacy Policy is updated
IX. How to contact us

 

I. How We Collect Your Personal Information
(1) Situations in Which We Collect Personal Information

When you use the [Official Website], we will collect your personal information in the following ways:

1. Customer Service

When you submit a complaint, suggestion, or issue to us, in order to contact you, resolve your issue as quickly as possible, or document the resolution plan and outcome, we may collect records of your communications or phone calls with us, the account information you provide, the contact information you provide, and any information you provide to substantiate relevant facts. If you do not provide this information, your complaints, suggestions, and feedback may not be handled in a timely and effective manner; however, this will not affect your normal use of our other services. 
2. Product Feedback
When you use the product feedback feature, you are required to provide us with your name, product number, mobile phone number or email address, the details of your inquiry, and any relevant attachments. We collect this information to process your product inquiries or issue reports and to contact you promptly. Among these, your mobile phone number or email address is required; if you do not provide it, we will be unable to respond to your feedback. If you choose not to provide the remaining information, it will not affect your normal use of our other services.

(3) Explanation of Cases Where Consent Is Not Required Due to Other Legitimate GroundsIn accordance with relevant laws and regulations, we may process your personal information without obtaining your consent in the following circumstances:
1. When necessary for the conclusion or performance of a contract to which you are a party;
2. When necessary to fulfill statutory duties or legal obligations;
3. When necessary to respond to a public health emergency or to protect the life, health, and property of individuals in an emergency;
4. When processing personal information within a reasonable scope for activities such as news reporting and public oversight in the public interest;
5. When processing personal information that you have voluntarily disclosed or that has been otherwise lawfully disclosed, within a reasonable scope as provided by law;
6. Other circumstances as provided by laws and administrative regulations.

 

II. How We Use Your Personal Information

1. We will collect and use your personal information solely for the purposes and within the scope specified in this Privacy Policy. As our services are upgraded and updated, we may adjust the business functions described in this Privacy Policy and the types of personal information we collect and use. When new features or services are related to those we currently provide, the personal information collected and used will be directly or reasonably related to the original purpose of processing.
2. If we intend to use your personal information in contexts that are not directly or reasonably related to the original purpose of processing, for purposes not specified in this Privacy Policy, or if information collected for a specific purpose is to be used for other purposes, we will notify you by updating this Privacy Policy, relevant product pages, and other privacy documents, as well as through various means such as pop-up windows, in-app messages, and push notifications. We will also seek your prior consent or ensure that other lawful grounds exist.
3. The sensitive personal information we collect is clearly marked in this Privacy Policy. If your sensitive personal information is disclosed, tampered with, or used unlawfully, it may result in harm to your personal safety or property. To prevent the disclosure or unlawful use of your sensitive personal information, we have implemented appropriate technical and organizational safeguards to ensure the security of your information to the best of our ability.
4. If the information you provide contains the personal information of others, you must ensure that you have obtained valid consent from the relevant individuals before providing such personal information to us. If the information involves a child’s personal information, you must obtain valid consent from the child’s legal guardian before providing it. In such cases, the guardian has the right to contact us through the channels specified in this Privacy Policy to request the correction or deletion of content involving the child’s personal information. If the information you provide infringes upon another person’s right to privacy, personal information, trade secrets, or any other lawful rights and interests, or causes harm to the state, public interests, or others, you shall bear full responsibility on your own, and we assume no liability for this.
5. Please note that the personal information you provide when using the services we offer will remain authorized for our use throughout the period you use our services, unless you delete it or opt out of our collection through system settings.
6. We will compile statistics on the usage of the services we provide and may share these statistical data with the public or third parties for the purposes of product development, service optimization, and security assurance. However, these statistical data do not contain any personally identifiable information about you. When we display your personal information, we will apply de-identification techniques—including masking and obscuring—in accordance with actual business functions to anonymize your information and protect its security.

 

III. How We Store Your Personal Information
(1) Retention Period
We will retain your personal information for the minimum retention period necessary to fulfill the purposes set forth in this Privacy Policy and as required by law. Upon expiration of the aforementioned period, we will delete or anonymize your personal information.

(2) Storage Location
Personal information that we collect and generate through our operations within China is stored within China. If it becomes necessary to transfer your personal information outside of China, we will comply with the legal requirements regarding the cross-border transfer of personal information prior to such transfer.

IV. How We Outsource the Processing, Provide to Third Parties, Transfer, and Disclose Your Personal Information
(1) Outsourcing of Processing

We do not entrust third parties to process your personal information on our behalf. Such entrusted processing is subject to the purposes stated in this Privacy Policy, and we prohibit the entrusted parties from using the data for unauthorized purposes through written agreements, on-site audits, and other means.

 

(2) Provision to External Parties
We will not disclose your personal information to third parties.

(3) Transfer

As our business grows, we may engage in mergers, acquisitions, or reorganizations, which may result in the transfer of your personal information. We will require the transferee to continue protecting your personal information in accordance with the law and this Privacy Policy. If the transferee changes the original purpose or method of processing, we will require the transferee to obtain your consent again.

(4) Public Disclosure
As a general rule, we do not publicly disclose your personal information. If it is necessary to publicly disclose your personal information, we will obtain your separate consent or meet other conditions required by law.

V. How We Protect Your Personal Information

We take the security of personal information very seriously and take all reasonable and feasible measures to protect your personal information:
1. We have implemented industry-standard data protection technologies and management measures, such as network isolation, data encryption, and employee access controls, to prevent unauthorized access, disclosure, alteration, loss, or destruction of your personal information.
2. Please be aware that, although we will do our best to ensure or guarantee the security of any information you send to us, the internet is not 100% secure, and we assume no liability for any risks or losses arising from or related to this.
3. In the unfortunate event of a personal information security incident, we will promptly notify you in accordance with legal and regulatory requirements regarding: the basic details of the security incident and its potential impact; the remedial measures we have taken or will take; recommendations for you to independently prevent and mitigate risks; and remedial measures for you. We will promptly notify you of the relevant details of the incident via app push notifications, email, text message, or phone call. When it is impractical to notify each data subject individually, we will issue a public announcement through reasonable and effective means. At the same time, we will proactively report the handling of personal information security incidents to the regulatory authorities as required.

 

VI. How Can You Manage Your Personal Information?
While using the [Official Website], you may access, copy, transfer, correct, supplement, or delete your personal information, as well as exercise your rights to modify the scope of your authorization and consent, or delete your account.

(1) Accessing, Copying, and Transferring Your Personal Information

You may contact us through the methods specified in this policy to access, copy, or transfer your personal information.

(2) Correcting or Supplementing Your Personal Information

If you discover that the personal information we process about you is incorrect or incomplete, you have the right to request that we correct or supplement it. You may correct or supplement your personal information by following the steps outlined in the section titled “(I) Inquiries, Copies, and Transfer of Your Personal Information,” or by contacting us using the contact information provided in this Privacy Policy.

(3) Deleting Your Personal Information

In the following situations, you may submit a request to us to delete your personal information:

1. The purpose of processing stated in this policy has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose of processing;
2. Where the processing of your personal information is based on your consent, and you withdraw that consent;
3. The retention period for your personal information has expired;
4. We have collected, used, stored, provided to third parties, or disclosed your personal information in violation of laws, administrative regulations, or our agreement with you;
5. You no longer use our services;
6. We cease to provide products or services;
7. Other circumstances as provided by laws and regulations.

(IV) Changes to the Scope of Your Authorization and Consent
You may contact us using the methods specified in the policy to change the scope of your consent or withdraw your authorization.

(5) Account Closure 

We do not have a separate account system.

(6) Regulating Automated Decision-Making

We do not use automated decision-making to provide our services.

(7) Right to Provide Explanations
If you have any questions about our personal information processing policies, you may contact us using the contact information provided in this Privacy Policy, and we will explain our personal information processing policies to you.

(8) Other Rights Regarding Personal Information
Subject to applicable laws, your immediate family members may exercise the aforementioned rights—including the right to access, copy, correct, and delete—with respect to your personal information after your passing; however, you may contact us to make alternative arrangements.

(9) Responding to your request as described above  
To ensure security, you may be required to submit a written request or otherwise verify your identity. We may ask you to verify your identity before processing your request. We will respond within fifteen days or within the timeframe specified by law. 

In principle, we do not charge a fee for your reasonable requests. For requests that are groundless, repetitive, or exceed reasonable limits, we may charge a reasonable fee at our discretion. 

In the following situations, we will be unable to respond to your request: 

1. Related to our fulfillment of obligations prescribed by law; 
2. Directly related to national security or defense security; 
3. Directly related to public safety, public health, or major public interests; 
4. Directly related to criminal investigations, prosecutions, trials, and the enforcement of judgments; 
5. We have sufficient evidence indicating that the user has acted with malicious intent or has abused their rights; 
6. Where it is necessary to protect the vital legitimate rights and interests of the user or other individuals—such as life and property—but it is difficult to obtain the individual’s consent; 
7. Where complying with the user’s request would result in serious harm to the legitimate rights and interests of the user, other individuals, or organizations; 
8. Where trade secrets are involved.

 

VII. How We Handle the Personal Information of Minors
Our products and services are not intended for minors or children. If you are a minor or a child, please stop using our products and services immediately.

 

 

VIII. How This Privacy Policy Is Updated
Our Privacy Policy may be updated from time to time. We will post information regarding changes to this Privacy Policy on the relevant product pages. For significant changes, we will also provide more prominent notifications (such as through pop-up windows or in-app messages) to explain the specific changes to the Privacy Policy and obtain your consent. 
We will not curtail your rights under this Privacy Policy without your express consent.For the purposes of this Privacy Policy, “material changes” include, but are not limited to: significant changes to our service model; changes in the circumstances under which personal information is provided to third parties, transferred, or publicly disclosed; significant changes to your rights regarding the processing of your personal information and how you exercise those rights; changes to our contact information and complaint channels; and instances where a personal information security impact assessment report indicates a high risk.
We will also archive previous versions of this Privacy Policy for your reference.

 

IX. How to Contact Us1.

If you have any questions regarding this Privacy Policy or the protection of personal information, you may contact us through the following channels:
Contact information for the Personal Information Protection Officer: [zlyuejx@sunnyoptical.com]
Other contact information: [13136107100]
2. Generally, we will respond within fifteen days or within the timeframe prescribed by law. If you are dissatisfied with our response—particularly if our processing of personal information has infringed upon your lawful rights and interests, and we continue to refuse to make improvements after receiving your feedback—you may also file a complaint or report with regulatory authorities such as the Cyberspace Administration, the Ministry of Industry and Information Technology, the Public Security Bureau, and the Market Supervision Administration, or seek resolution by filing a lawsuit with the court having jurisdiction over the defendant’s place of residence.