Privacy Policy

This Policy takes effect from the date of updating.

Last updated: 29 August, 2024


Spacewalker Technology Hong Kong Co., Limited and its affiliates (hereinafter referred to as “Mova” or “We”) respect and protect your privacy. This Privacy Policy (hereinafter referred to as “this Policy”) specifies how we collect, use, disclose, share, transfer, and store the information about you when you use our websites.
We are fully aware of the importance of personal data to you. We will do our best to protect your personal data. We are committed to maintaining your trust in us. We promise to abide by the following principles to protect your personal data: legality, legitimacy, necessity and integrity, consistency of rights and responsibilities, clear purpose, choice and consent, minimum adequacy, ensuring security, subject participation, openness, and transparency, among others. At the same time, we promise that we will take corresponding security protection measures to protect your personal data according to the proper security standards in your country.

 

Please read and understand this Policy carefully before using our services. Should you have any questions, please contact us through  privacy@mova-tech.com. The privacy department and personnel will give a reply according to the time specified by law. Suppose you are not satisfied with our reply. In that case, especially when you think how we deal with your personal data has undermined your legitimate rights and interests, you can also resort to external channels such as filing a lawsuit to the court with jurisdiction and complaining to the competent regulatory authority.

This Policy will help you understand the following contents:

I How We Collect and Use Your Personal Data
II Cookies and Other Technologies
III How We Conduct the Entrusted Processing, Sharing, Transferring,and Public Disclosure of Your Personal Data
IV How We Store and Protect Your Personal Data
V Your Rights
VI Minors
VII Transfer of Personal Data Between Countries
VIII Contact Us
IX Update of This Privacy Policy

I How We Collect and Use Your Personal Data

Personal data refers to all information related to identified or identifiable natural persons as recorded by electronic or other means, excluding information after anonymization.

1. Essential Functions That Require Collecting and Using Your Personal Data

The purpose of collecting personal data is to provide you with products and/or services. At the same time, we ensure that we comply with relevant laws, regulations, and other normative documents. Expressly, for the following occasions, you must agree to provide the following types of information so that we can safely and effectively realize this basic function. Otherwise, you may not be able to enjoy the corresponding services.

(1) Product/Service Information Displaying

When you browse our websites, to display our products and/or services to you, we may collect your IP address, device-related information you use to access the website (such as the type of browser used, operating system information), language used or country, accessing date and time, etc.

2. Additional Features That Require the Collection and Use of Your Personal Data

Our websites may support one or more of the following additional functions to enable you to enjoy more features and enhance your user experience. Please confirm whether the website you visit has these additional functions. We may collect and use your personal data when you use the following additional features. You can still use the aforementioned basic functions if you do not provide personal data. However, you may be unable to use additional functions to provide more excellent services. These additional features include:

(1) Account Management

When you create a Mova account through our websites to engage with our services, we may collect certain personal information, such as your name, username, email address, and password.

(2) Order Service

When you order products on our websites, we may collect your order information like shipping address, billing information, phone number, and other necessary information to process your order, deliver your items, provide you with the invoice, and deal with your order refund request. After you place an order and complete the payment online, third-party delivery companies (hereinafter referred to as "delivery companies") that cooperate with us will complete the delivery of your order. You are aware and agree that the third-party delivery company that cooperates with us will use your order information during the above steps to ensure the safe delivery of your ordered goods.

(3) Customer Support

When you contact us looking for support, we may collect the information about your use of our services, including information about our products that you own and your contact details and other necessary information you share with us, so that we can provide customer support and solve your problem.

(4) Marketing and Promoting
We may provide or promote marketing information for our products and services to you after obtaining your authorization by using your contact information, such as phone number and email. You can choose to refuse such marketing messages at any time.

3. We Obtain Your Personal Data from a Third Party

Under some circumstances, we may obtain your personal data from a third party as permitted by laws.
Suppose our business development requires processing your personal data beyond the scope of your original authorization and consent provided at the time of data submission to third-party service providers. In that case, we will seek your explicit consent before such processing. In addition, we will strictly abide by relevant laws and regulations and require third-party service providers to ensure the legitimacy of the information they provide.

4. Non-personal Data We Collect

We may also collect other information that cannot directly or indirectly identify specific individuals and is not personal data under locally applicable laws. Such information is called non-personal data. For example, the statistical data generated when you use a specific service, such as the user's operational behavior (including clicks, page jumps, and browsing time). The purpose of collecting the said information is to improve the services we provide to you. The type and amount of information collected depends on how you use our products and/or services. We will summarize such information to help us provide customers with more useful information and understand which parts of our website, products, and services customers are most interested in. Concerning this Policy, aggregated data is considered non-personal data. If we combine non-personal data with personal data for usage, such information will be regarded as personal data.

II Cookies and Other Technologies

Mova and our Third Party Service Providers use technologies such as cookies, tags, and scripts. These technologies are used to analyze trends, manage the site, track users’ browsing, and gather demographic information about our user base.
Log Files: As true of most websites, we gather certain information and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically-collected data to other information we gather about you.
Advertising: We partner with our Third Party Service Providers to either display advertising on our website or to manage our advertising on other sites. Our Third Party Service Provider may use technologies such as cookies to provide you with advertising based on your browsing activities and interests. We will obtain your prior explicit consent and involve a clear affirmative action before providing this advertising service to you.
Local Storage: We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content and preferences. Third parties with whom we partner to provide certain features on our sites or display advertising based on your web browsing activity also use HTML5 or Flash cookies to collect and store information. Various browsers may offer their management tool for removing HTML5 LSOs.

III How We Conduct the Entrusted Processing, Sharing, Transferring, and Public Disclosure of Your Personal Data

1. Entrusted Processing

Mova may entrust other companies to process your personal data on our behalf. We promise you that when we entrust third-party companies to process the said information, we will comply with the following requirements:
1. The analysis we entrust them to do shall not exceed the scope of authorization and consent we have obtained from you unless your consent is not mandatory.
2. We evaluate the data security capabilities of the entrusted party in advance to ensure the party has the said capabilities as required by local laws and regulations.
3. We specify the responsibilities and obligations facing the entrusted party through the contract, make it comply with the provisions of locally applicable laws, and require it to discharge the obligations without falling short of our standards.
4. We accurately record and save the personal data as entrusted to ensure your information security and adequate access and control of your personal data.
5. When the entrustment relationship is terminated, or we delete or anonymize your personal data according to this Policy, we will require the entrusted party to delete your personal data and destroy all data copies.

2. Sharing

Generally, we will not share your personal data except for the following cases:
1. After obtaining your express consent, Mova will share the information within your authorization with the third party designated by you.
2. Part of our products and services are provided by third-party service providers, with whom we need to provide some of your personal data, such as IT services, customer support services, e-mail sending services, and other similar services, to ensure that they can provide services for us. Data will be shared with third parties through the Application Programming Interface (API) and Software Development Kit (SDK). SDKs of different third parties will be different, and they generally include third-party account login, sharing, third-party payment, manufacturers' push, statistics, etc. We will conduct strict security testing on the third party and impose data protection measures. Before you enter the third-party page for the first time, the third-party service provider will show you the relevant agreements and privacy statements. Please read these agreements and privacy statements carefully.
Suppose we share your personal data with these third parties. In that case, we will rely on encryption and other means to ensure your information security. For companies and organizations with whom we share personal data, we will reasonably review their data security environment, sign strict data processing agreements with them, require the said third parties to take adequate protection measures for your information, and strictly comply with relevant laws, regulations, and regulatory requirements.
3. We disclose your personal data to subsidiaries or other third parties in the event of reorganization, merger, sale, entering into partnership, assignment, transfer, or other disposal of all or part of our business, assets, or shares (including but not limited to bankruptcy or any similar proceedings as described). In this case, you will receive explicit notification of changes in ownership, incompatibility of new ways of using personal data, and selection of personal data via email and/or our websites.
4. When we deem it necessary or appropriate, we shall (a) comply with locally applicable laws and regulations, (b) comply with legal procedures, (c) respond to requests from public institutions and government authorities, including those outside your country of residence; (d) fulfill our terms and conditions; (e) protect our operations, businesses, and systems; (f) protect the rights, privacy, security or property of ours and/or other users, including you; and (g) seek available remedies or limit the damages we may be required to provide.
5. We disclose your personal data to Mova’s subsidiaries or affiliates to conduct business activities regularly.

3. Transferring

Transferring means we lose control over your personal data, and the transferee obtains control over your personal data. We will not transfer your personal data to any company, organization, or individual. Should it be necessary to do so, we will transfer it in accordance with applicable laws and inform you of the purpose of the transfer, the personal data involved, the transferee, etc.
Information transfer may occur under the following circumstances:
1. Transfer based on your express consent: after obtaining your express consent, we will transfer your personal data to other parties.
2. In case of merger, acquisition, or bankruptcy liquidation, should personal data transferring be involved, we will require the new company or organization holding your personal data to continue to be bound by this statement. Otherwise, we will require the company or organization to ask you for authorization and consent again.

4. Public Disclosure

In principle, we will not publicly disclose your personal data. Should public disclosure be really necessary, we will inform you in advance of the purpose of this public disclosure, the type of information disclosed, and the content of personal sensitive information that may be involved, obtain your express consent, and perform relevant obligations in accordance with locally applicable laws.
We will only publicly disclose your personal data under the following circumstances:
1. After your express consent is obtained.
2. Legal disclosure: we may publicly disclose your personal data in compliance with local laws, legal procedures, litigation, or mandatory requirements of government authorities.

5. Information That Does Not Require Consent

We may share anonymous information with third parties (such as advertisers on our websites) in the form of aggregation for commercial purposes; we may share with them general usage trends of our services, such as the number of customers in a specific group who buy certain products or engage in certain transactions.
To dispel doubt, we may collect, use, or disclose your personal data without your consent as expressly permitted by local data protection laws (e.g., to comply with subpoenas). Besides, we may disclose your information without your consent when we believe it is necessary to protect our rights, protect your safety or the safety of others, conduct fraud investigations, or respond to government requests.

IV How We Store and Protect Your Personal Data

1. Where We Store Your Personal Data

Currently, Mova runs data centers in the United States, Germany, and Singapore. Your personal data is stored on the server according to the region in which you live. If you are a European Union user under the General Data Protection Regulation (hereinafter referred to as “GDPR”), your personal data will be stored on the German server.

2. Storage Period

We retain personal data for a period for the sake of information collection described in this Policy, or we do so in compliance with locally applicable relevant legal requirements. After fulfilling the purpose of personal data collection, or after we confirm your application of deletion or cancellation, or after we terminate the operation of corresponding products or services, we will stop retaining personal data and delete or anonymize it. If it is for public interest, scientific, historical research, or statistics, we will retain relevant data based on applicable laws, even if further data processing is irrelevant to the original purpose.

3. Protection Measures

We promise to ensure the security of your data. To prevent unauthorized access, disclosure, or similar risks, we have implemented reasonable physical, electronic, and management measures and processes to protect the information we collect. We will take all reasonable measures to protect your personal data.
We classify your data according to importance and sensitivity and ensure your personal data is protected at the highest security level. We guarantee that employees and third-party service providers who provide products and services to you by accessing this information have strict contractual confidentiality obligations. If they fail to fulfill these obligations, they will be subject to disciplinary punishment or termination of cooperation. We regularly review information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access and use.
We will take all feasible measures to protect your personal data. However, you should be aware that Internet use is not always safe. Therefore, we cannot guarantee the security or integrity of any personal data during two-way transmission through the Internet.

V Your Rights

According to your country or region's applicable laws and regulations, you are entitled to relevant rights on any of your personal data (hereinafter referred to as "the Request") held by us. Most laws require that requests made by individuals should comply with specific requirements, and this Policy requires that your request should meet the following circumstances:
1. Through our special request channel, and to protect your information security, your request should be in writing (unless local laws explicitly recognize oral application).
2. You should provide sufficient information so that we can verify your identity and ensure that the requester is the subject or a legally authorized person of the requested information.
We have the right to refuse to deal with meaningless/repeated requests, requests for unreasonable technical work, requests that violate the privacy of others, extremely unrealistic requests, and requests that do not need to be granted under local law. We may also refuse your request if we believe that some aspects of your request may prevent us from legally using the data for the above-mentioned anti-fraud and security purposes.
Once we have sufficient information to confirm that we can process your request, we will respond to your request within the time specified by applicable data protection laws.
Specifically, you can contact us via privacy@mova-tech.com to exercise the following rights:

1. Accessing Your Personal Data

Concerning personal data that we have collected and processed, please email privacy@mova-tech.com.

2. Copying Your Personal Data

Based on your requirements and locally applicable laws and regulations, we can provide a record of the personal data we have collected and processed for free. If you make other requests for relevant information, we may charge you a reasonable fee based on relevant applicable laws and the actual management cost.

3. Correcting Your Personal Data

If you believe any information we hold about you is incorrect or incomplete, you may request correction or add personal data for use.

4. Erasing Your Personal Data

According to your locally applicable laws and regulations, you may have the right to ask us to delete your personal data. We will evaluate according to your request. If the corresponding provisions are met, we will take corresponding steps, including technical means, to deal with it. When you have deleted relevant information or have done so with our assistance, we may not be able to delete the corresponding information from the backup system immediately due to applicable laws and security technologies. We will safely store your personal data and exempt it from any further processing until the backup can be cleared or anonymization is realized.

5. Withdrawal of Consent

You may withdraw your consent by submitting a request, including the collection, use, and/or disclosure of your personal data in our possession or control. You can withdraw your consent directly via privacy@mova-tech.com. We will process your request within a reasonable time after you make your request and will no longer collect, use, and/or disclose your personal data thereafter.
Please note that according to the scope of information you authorize us to process, your withdrawal of consent may result in you being unable to enjoy our services. However, your decision to withdraw your consent or authorization will not affect the previous personal data processing based on your authorization.

6. Rights under GDPR

If you are a European Union user under GDPR, you can exercise the following rights:
1. The right to obtain the erasure of your personal information from us. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures if the grounds apply to GDPR.
2. The right to obtain the restriction of processing your personal information from us. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.
3. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
4. The right to receive your personal information in a structured, commonly used format and transmit the information to another data controller.

7. Rights under CCPA/CPRA

If you are a California resident and the California Consumer Privacy Act of 2018 (hereinafter referred to as “CCPA”) or the California Privacy Rights Act (hereinafter referred to as “CPRA”) does not recognize an exemption that applies to you or your Personal Information, you have the right to:
1. Request we disclose to you free of charge the following information covering the 12 months preceding your request:
(1) the categories of personal information about you that we collected;
(2) the categories of sources from which the personal information was collected;
(3) the purpose for collecting personal information about you;
(4) the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
(5) the specific pieces of personal information we collected about you.
2. Request we delete the personal information we collected from you unless CCPA/CPRA recognizes an exemption.
3. Be free from unlawful discrimination for exercising your rights, including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA/CPRA.
4. Have the right to opt out of certain uses and disclosures of your personal information. Where you have consented to Mova’s processing of your personal information, you may withdraw that consent at any time and opt out of further processing by contacting Mova. To provide our services to you, we will ask you to provide the personal information necessary to provide those services to you. If you do not provide your personal information, we may not be able to provide you with our products or services. Even if you opt out, we may still collect and use non-personal information regarding your use of our products.
We aim to fulfill all verified requests within 45 days pursuant to the CCPA/CPRA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

VI Minors

We believe parents are responsible for supervising children's use of our products and services. However, our policy does not require access to the personal data of minors, and we do not send any promotional materials to such groups.
Mova will not seek or attempt to receive any personal data from minors. If parents or guardians have reason to believe that minors have submitted personal data to Mova without their prior consent, please get in touch with us to ensure that such personal data is deleted and that minors cancel their subscription to any applicable Mova services.

VII Transfer of Personal Data Between Countries

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies (which are in the communications, social media, information technology, and cloud businesses) or Third Party Service Providers, we shall do so in accordance with the applicable laws.
Your personal information will only be transferred or accessed in countries/regions outside your jurisdiction to provide you with products or services, perform the agreement between you and us, or for other purposes agreed by you. For example, we have to transfer your personal information outside of your jurisdiction to perform repair, return, and exchange services. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards.

VIII Contact Us

If you have any comments or questions about this Policy, or if you have any questions about our collection, use, or disclosure of your personal data, please get in touch with us at the address below and mention the “Privacy Policy.” We have a professional team to solve your problems when you have any issues concerning your rights and questions related to personal data. We may ask you for more information if your question involves more important matters. If you are not satisfied with the response you have received, you can refer the complaint to the relevant regulatory authority of the jurisdiction. If you consult us, we will provide information on applicable complaint channels according to your situation.
Email address: privacy@mova-tech.com

IX Update of This Privacy Policy

We will regularly review this Policy and may update it to reflect changes in our information practices. If we make significant changes to this privacy policy, we will notify you by email (to the email address specified in your account) or on all search websites or mobile devices so that you can understand the information we collect and how we use it. Such policy changes will apply from the effective date specified in the notice or on the website. We recommend you check this page regularly for the latest information on our privacy practices. If you continue to use products and websites or other services, you will be deemed to accept the updated privacy policy. When we collect more personal data from you, or we hope to use or disclose your data for new purposes, we will obtain your consent again.