Privacy Policy

Privacy Policy for U.S. E-Commerce Independent Website

Effective Date: [07/11/2026]
Last Updated: [07/11/2026]

This Privacy Policy applies to the independent website www.ultlink.com operated by Shenzhen Xianjitong Intelligent Technology Co., Ltd. (hereinafter referred to as "we", "us" or "our"), and governs all users located in the United States who access or use this website. This Policy complies with applicable U.S. federal and state privacy laws and regulations, including but not limited to the California Privacy Rights Act (CPRA), the Children's Online Privacy Protection Act (COPPA), and the Controlling the Assault of Non-Solicited Pornography And Marketing Act (CAN-SPAM). It clearly sets forth how we collect, use, disclose and protect your personal information, as well as the privacy rights available to you.

1. Scope of Information We Collect

We collect personal information only to the extent necessary to provide products and services, optimize website experience and conduct legitimate marketing, in accordance with the principle of data minimization. Depending on how you interact with the website, we may collect the following categories of information:

1.1 Information You Voluntarily Provide

• Account registration information: full name, email address, account password you create, and contact phone number;
• Order transaction information: shipping address, billing address, contact phone number, details of purchased items, and order notes;
• Payment information: your selected payment method and billing address. We do not store complete credit card numbers, CVV codes or other sensitive payment details directly; such data is processed exclusively by compliant third-party payment service providers;
• Customer service communication information: inquiry content and contact information you submit via contact forms, email or live chat;
• Marketing subscription information: email address and phone number you provide when you voluntarily subscribe to email or SMS marketing;
• Other voluntarily submitted information: content you fill in when participating in sweepstakes, surveys or reviews.

1.2 Automatically Collected Information

When you visit this website, we and our third-party partners automatically collect the following technical information:

• Device information: device model, operating system, browser type and version, and screen resolution;
• Access logs: IP address, access time, pages visited, duration of stay, referral source, and click behavior;
• Location information: approximate geographic location (city/state level) derived from IP address; we do not collect precise geolocation data;
• Information collected via cookies and similar tracking technologies, as detailed in the "Cookies and Tracking Technologies" section of this Policy.

1.3 Sensitive Personal Information (SPI)

As defined under the California CPRA, the sensitive personal information we may collect includes:

• Payment card-related information (processed by third-party payment service providers; we do not retain full card numbers);
• Account login credentials (password);
• Precise billing and shipping address information.

We use sensitive personal information solely for statutory or business-necessary purposes such as order fulfillment and account security protection, and will not use it to infer user characteristics or for other secondary purposes.

2. Purposes of Information Use

We use the collected personal information for the following legitimate commercial and business purposes:

2.1 Core Service Fulfillment (Contractual Necessity)

• Process and fulfill your orders, complete payment settlement, logistics delivery and after-sales returns/exchanges;
• Create and maintain your user account, and provide order inquiry and history record services;
• Respond to your customer service inquiries and after-sales requests, and resolve transaction-related issues.

2.2 Website Operation and Optimization

• Maintain the secure and stable operation of the website, troubleshoot faults, and prevent fraud and malicious attacks;
• Analyze website traffic and user behavior to optimize page layout, product display and user experience;
• Conduct internal data analysis, statistics and product research and development.

2.3 Marketing and Promotion (Conducted Only Under Legitimate Premises)

• Send order notifications, logistics reminders, new product launches, promotional events and other emails/SMS to subscribed users;
• Serve personalized and retargeting advertisements, and display relevant products based on your browsing and purchase preferences;
• Run sweepstakes, surveys and membership activities to improve user service experience.

2.4 Compliance and Legal Obligations

• Comply with applicable tax, accounting, customs and other relevant laws and regulations, and retain transaction vouchers;
• Respond to legitimate requests from judicial authorities and regulatory departments;
• Safeguard our legitimate rights and interests, and prevent, investigate fraud and illegal activities.

3. Information Disclosure and Sharing

We do not sell your personal information for monetary compensation. However, in the following scenarios, we may disclose or share your personal information with third parties. Among them, information sharing for cross-site behavioral targeted advertising falls within the definition of "share" under the California CPRA.

3.1 Disclosure to Service Providers (Business Purposes)

We engage vetted third-party service providers to deliver professional services. Service providers may only process your information within the scope of our authorization and are bound by data confidentiality and security obligations. The main categories of service providers include:

• Payment service providers: [e.g. Stripe, PayPal, Shopify Payments, etc.], for order payment processing;
• Logistics service providers: [e.g. USPS, UPS, third-party overseas warehouses, etc.], for product delivery and logistics tracking;
• Website technical service providers: [e.g. website building platforms, CDN providers, cloud storage providers, etc.], for website operation and technical maintenance;
• Data analytics service providers: [e.g. Google Analytics, etc.], for website traffic and user behavior statistical analysis;
• Customer service and marketing tool providers: [e.g. email marketing platforms, live chat tools, etc.], for customer communication and marketing outreach.

3.2 Information Sharing Related to Targeted Advertising

We cooperate with third-party advertising platforms to display personalized advertisements to you on third-party websites and platforms. Such cross-site behavioral tracking constitutes "sharing of personal information" as defined under the CPRA.
Cooperating advertising platforms include but are not limited to: [e.g. Google Ads, Meta/Facebook Ads, TikTok Ads, etc.].
You have the right to opt out of such information sharing at any time, as detailed in the "California Consumer Privacy Rights" section.

3.3 Statutory and Rights Protection Scenarios

• Comply with mandatory requirements of laws, regulations, judicial procedures or government authorities;
• Protect the personal and property safety and legitimate rights and interests of us, users and the public;
• In the event of corporate merger, acquisition, asset transfer or similar transactions, information may be transferred as part of the assets, and we will notify you in advance.

3.4 Other Scenarios With Your Consent

Except for the above circumstances, we will inform you in advance and obtain your explicit consent before disclosing your personal information to third parties.

4. Cookies and Tracking Technologies

We use cookies, pixel tags, local storage and similar technologies to ensure website operation, optimize experience and conduct marketing analysis.

4.1 Cookie Categories

• Strictly Necessary Cookies: Essential for website operation, used to maintain shopping cart status, login status, security verification, etc., and cannot be disabled via settings;
• Functional Cookies: Used to remember your language, currency, browsing preferences and other settings to improve user experience;
• Analytics Cookies: Collect statistics on website visits, page stay time and conversion data to help us optimize the website;
• Advertising Cookies: Set by third-party advertising platforms, used to build your interest profile and deliver personalized retargeting advertisements.

4.2 Your Control

• You may disable or delete cookies through your browser settings. Please note that some website functions may not work properly after disabling;
• You may opt out of third-party advertising tracking through the following official channels:
• Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout
• Digital Advertising Alliance (DAA) Opt-Out Page: https://optout.aboutads.info
• Network Advertising Initiative (NAI) Opt-Out Page: https://optout.networkadvertising.org
• We support the Global Privacy Control (GPC)signal: when you enable the GPC signal in your browser, we will automatically recognize it and default to turning off targeted advertising data sharing for you, with no additional action required.

5. California Consumer Privacy Rights

If you are a California resident, you are entitled to the following privacy rights under the California Privacy Rights Act (CPRA):

5.1 Right to Know

You have the right to request that we disclose the categories and specific contents of your personal information we have collected, used, disclosed, sold or shared within the past 12 months.

5.2 Right to Delete

You have the right to request that we delete your personal information held by us, except for information subject to statutory retention obligations (e.g. order data necessary for tax accounting).

5.3 Right to Correct

You have the right to request that we correct inaccurate personal information about you.

5.4 Right to Opt Out of Sale/Sharing

You have the right to request that we stop selling or sharing your personal information with third parties (i.e. information sharing for cross-site targeted advertising) at any time.

How to exercise:

• Click the "Do Not Sell or Share My Personal Information"link in the website footer to submit an opt-out request online;
• Enable the browser GPC (Global Privacy Control) signal, and the system will automatically recognize and execute the opt-out.

5.5 Right to Limit Sensitive Personal Information Processing

You have the right to request that we limit the use and disclosure of your sensitive personal information, retaining only processing necessary for statutory or business purposes.

5.6 Right to Data Portability

You have the right to request that we provide you with a copy of your personal information held by us in a machine-readable format.

5.7 Non-Discrimination Principle

We will not discriminate against you for exercising the above privacy rights, including but not limited to charging different prices, providing different service quality, or denying you access to website services.

5.8 How to Exercise Your Rights and Procedures

• Submission channels: Send an email to [Privacy Contact Email], or submit your request online via the privacy request portal in the website footer;
• Identity verification: Upon receipt of your request, we will verify your identity through your registered account email or reserved phone number to ensure information security;
• Response time limit: We will respond within 45 days of receiving the request. For complex cases, the period may be extended by an additional 45 days, and we will notify you in advance of the extension;
• Authorized agent: You may designate an authorized agent to exercise your rights on your behalf. The agent must provide a signed authorization letter from you, and we will also verify your identity.

6. Federal-Specific Compliance Statements

6.1 Children's Privacy Protection (COPPA)

This website is intended for general adult consumers and is not directed at children under the age of 13. We do not knowingly collect personal information from children under 13 years of age. If you believe we have inadvertently collected information from a child, please contact us immediately and we will promptly delete the relevant data.

6.2 Email Marketing Compliance (CAN-SPAM)

• We only send marketing emails to users who have voluntarily subscribed or have an existing transaction relationship with us;
• Every marketing email includes a clear and convenient one-click unsubscribe link, and unsubscribe requests will take effect within 10 business days;
• We do not use false sender information or misleading email subject lines.

6.3 SMS Marketing Compliance (TCPA)

• Marketing SMS are only sent to numbers for which you have provided express written consent to subscribe, and are not bundled as a mandatory condition for placing orders or registering;
• You may unsubscribe at any time by replying "STOP", and sending will cease immediately upon unsubscription;
• You will not receive marketing SMS from us if you have not voluntarily subscribed.

6.4 Data Breach Notification

In the event of a security breach involving your personal information, we will notify affected users and relevant regulatory authorities within the statutory time limit in accordance with applicable U.S. federal and state laws, and take necessary remedial measures.

7. Data Retention Period

We retain your personal information only for the period necessary to fulfill the purposes for which it was collected:

• Account information: retained until you cancel your account; after cancellation, necessary data will be retained in accordance with statutory obligations;
• Order and transaction data: retained for 3–7 years in accordance with U.S. tax and accounting legal requirements;
• Marketing subscription data: retained until you actively unsubscribe, and marketing use will cease immediately upon unsubscription;
• Website access logs and technical data: retained for no more than 12 months; anonymized data may be retained long-term for statistical analysis.

Upon expiration of the statutory retention period, we will delete or anonymize personal information.

8. Data Security

We adopt industry-standard technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration or destruction, including but not limited to:

• Full-site HTTPS/SSL encrypted data transmission;
• Encrypted storage of account passwords, with support for two-factor authentication;
• Employee data access rights assigned on a minimum-necessary basis;
• Regular security inspections and vulnerability remediation;
• All third-party service providers are required to meet corresponding data security standards.

Please note, however, that no internet environment is absolutely secure. While we strive to the best of our ability to protect information security, we cannot guarantee absolute security.

9. Policy Updates

We may revise this Privacy Policy from time to time in response to updates to laws and regulations, business adjustments or changes to website functions. The revised Policy will be published on this page with an updated effective date at the top. For material changes, we will provide advance notice via website announcement, email or other reasonable means. We recommend that you review this Policy periodically to stay informed of the latest privacy protection rules.

10. Contact Us

If you have any questions, comments or requests regarding this Privacy Policy, or if you wish to exercise your privacy rights, you may contact us through the following channels:

• Privacy Contact: [Name/Department in Charge]
• Contact Email: [Dedicated Privacy Email, e.g. [privacy@shturl.cc/Jb97]](privacy@shturl.cc/Jb97])
• Contact Address: [Company Registered/Office Address]
• Contact Phone: [Contact Phone Number]

Instructions for Use

1. Please replace all placeholder content marked with []with your actual business information;
2. If you do not use certain third-party tools (e.g. specific advertising platforms or marketing tools), you may delete the corresponding statements;
3. If your business covers only certain U.S. states, compliance with California CPRA standards will satisfy the core requirements of most state privacy laws;
4. This template is a general compliance reference document and does not constitute formal legal advice. For high-risk businesses, it is recommended to consult a U.S. local compliance lawyer for customized review.