Privacy Policy

Updated and Effective as of May 1, 2024

INVAN highly values the protection of users’ personal information and strictly adheres to legal requirements to safeguard your personal information. Based on applicable laws and regulations, we have developed the “INVAN Privacy Policy” (hereinafter referred to as “this Privacy Policy”). Through this Privacy Policy, we aim to explain how INVAN collects, uses, stores, shares, and protects your personal information during the provision of products and/or services, and how you can manage your personal information. Before you start using INVAN’s services, please carefully read and fully understand this Privacy Policy, and only use our related products and/or services if you fully understand and agree with the terms. If you have any questions about the content of this policy, you can contact us through the contact information provided at the end of this document. Once you start using our website, it will be deemed as acceptance and agreement to all contents of this Privacy Policy. For your convenience in reading and understanding, please refer to the definitions of key terms in the appendix of this Privacy Policy. Here are some special notes for your attention:

All important content is highlighted in bold. For personal sensitive information, we use bold italics to draw special attention. Before you provide us with any personal sensitive information, you should carefully consider and confirm that such provision is appropriate, and you agree that your personal sensitive information may be processed for the purposes and in the manner described in this policy.
INVAN does not cater to minors; we do not collect or provide any products and/or services of this platform to them. Before using our products and/or services, please confirm that you meet the age requirements and have carefully read and understood the details of this policy. We do not knowingly collect personal information from minors. If you find that we have inadvertently collected personal information from minors, please notify us immediately, and we will promptly delete the relevant data.
We provide ways for you to exercise your rights regarding personal information, including but not limited to accessing, correcting, deleting your personal information, deactivating your account, withdrawing consent, and receiving timely responses, to ensure you have control over your personal information.

This policy will help you understand the following:

How we collect and use personal information
How we use cookies and other similar tracking technologies
How we entrust, share, transfer, and publicly disclose personal information
How you can manage your personal information
How we store and protect personal information
How we update this Privacy Policy
How to contact us
Definitions of key terms

1. How we collect and use personal information

We collect and use personal information you provide voluntarily or that is generated during your use of this platform, in accordance with principles of legality, legitimacy, and necessity, to achieve the functionalities described in this Privacy Policy. You understand that the functionalities of this platform’s products and/or services may change and evolve with business strategies. If we intend to use personal information for purposes not specified in this policy or to collect and use personal information for other specific purposes, we will notify you in a reasonable manner and obtain your consent before collecting and using such personal information.

(a) Information we collect:

Personal registration information provided during account registration, including but not limited to your name, phone number, email address, legal representative, business license, ID documents, etc.
Information automatically received and recorded by INVAN when you visit InvanGrills.com, including but not limited to your IP address, browser type, access time, and page records.
Information obtained from business partners through legal means, including but not limited to Paypal, Payoneer, and third-party payment institutions.

(b) Purposes and scenarios for collecting information:

To help you become our member and to identify and verify your identity when you use our website.
To display products to you and provide functions for collecting and adding items to your cart.
To help you complete payments. To complete order payments, we will share your INVAN account information, order information, including necessary bank card payment information and other information required by anti-money laundering laws with the corresponding financial institution you choose.
To help you complete order processing. During the ordering process, you need to provide at least the recipient’s name, shipping address, and recipient’s contact phone number. For certain special types of products and services, you may need to provide additional information necessary for those products or services, such as face-to-face receipt and express delivery.
To assist with customer service and dispute resolution. When you contact us for customer service or dispute resolution, to ensure the security of your account and system, we need you to provide necessary personal information to verify your membership. To quickly help you resolve issues, we may review your account and order information and retain your online communication messages and call records with us.
Services related to cookies and similar technologies. Cookies and similar device identification technologies are commonly used in the internet. When you use INVAN services, we may use related technologies to send cookies to your device to collect, identify, and store your information. We promise that we use cookies mainly to ensure the safe and efficient operation of products and services, troubleshoot crashes, delays, and other related issues, and to save you from repeatedly filling out forms and processes. We will not use cookies for any purposes other than those described in this Privacy Policy.
Additionally, we may use cookies to display information or functions that may interest you and optimize your ad choices. You have the right to accept or refuse cookies. You can modify your browser settings to refuse our cookies, but these modifications may prevent you from logging in or using services or functions dependent on cookies.

(c) Authorization and consent from third-party users
For the purpose of using this platform and INVAN services, you understand and agree that we collect, store, process, and use your personal information with full and necessary authorization, consent, and permission to fulfill the service needs. If you provide any third-party personal information for us to process, you should ensure that you have obtained the third party’s full and necessary authorization, consent, and permission before providing it, allowing us to process and use such personal information for the purposes you specify. We have the right to refuse requests to process third-party personal information based on legal requirements and restrictions.

(d) Exceptions to obtaining authorization and consent
According to applicable laws and regulations, the following circumstances do not require obtaining the consent of the personal information subject for the collection and use of personal information:

Related to fulfilling legal obligations;
Directly related to national security and national defense security;
Directly related to public safety, public health, and significant public interests;
Directly related to criminal investigations, prosecutions, trials, and enforcement of judgments;
Necessary for protecting the vital legal rights and interests of personal information subjects or other individuals, such as life and property, but difficult to obtain authorization and consent;
Personal information that is voluntarily disclosed by the personal information subject to the public;
Necessary for signing and performing contracts as requested by the personal information subject;
Information collected from legally disclosed sources;
Necessary for maintaining the safe and stable operation of our platform, such as detecting and handling faults in our products and/or services;
Other circumstances stipulated by laws and regulations.

2. How we use cookies and other similar tracking technologies

(a) What are cookies
Cookies are small files stored on personal information subjects’ computers, mobile phones, or other smart terminal devices by the website server when they log in to websites or browse online content. Cookies usually contain identifiers, site names, and some numbers and characters. When personal information subjects visit the corresponding website again, the website can recognize their browser through cookies. Cookies may store user preferences and other information.

(b) How we use cookies
When personal information subjects use our website, we may collect their device model, operating system, device identifier, login IP address information, and cache their browsing information and click information through cookies or similar technologies to understand their network environment. Through cookies, we can recognize their identity when they visit the website and continuously optimize the user-friendliness of the website, making adjustments according to their needs. Personal information subjects can also change their browser settings to not accept our website’s cookies, but this may affect the use of some website functions.
On the INVAN website, with the help of cookies and similar technologies, we can recognize whether personal information subjects are our users each time they use our products and/or services without having to log in and verify on each page again.

(c) How to manage cookies
Personal information subjects can manage or delete certain types of tracking technologies according to their preferences. Many web browsers have a “Do Not Track” feature that can send “Do Not Track” requests to websites.
In addition to the controls we provide, personal information subjects can also choose to enable or disable cookies in their internet browser. Most internet browsers also allow personal information subjects to choose whether to disable all cookies or only third-party cookies. By default, most internet browsers accept cookies, but this can be changed. For more details, please refer to the help menu in your internet browser or the documentation that came with your device.
The following links provide instructions on how to control cookies in all major browsers:

Google Chrome: Google Chrome Help
Internet Explorer: Microsoft Support
Safari (desktop): Apple Support
Safari (mobile): Apple Support
Mozilla Firefox: [Mozilla Support](https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies)
Opera: Opera Help

If personal information subjects use other browsers, please refer to the documentation provided by the browser manufacturer.
On the INVAN website, personal information subjects can delete existing tracking technologies by clearing the cache.
When personal information subjects browse the page without logging in, we will collect necessary cookie information to enable browsing functionality.
Please note that if personal information subjects refuse to use or clear existing tracking technologies, they will need to personally change user settings each time they visit, and we may not be able to provide a better user experience, and some functions may not work properly.

3. How we entrust, share, transfer, and disclose personal information

(a) Entrustment
Certain functionalities of this platform may be provided by our third-party partners, and we may entrust partners (including technical service providers) to process some personal information of the information subjects. For example, when using automatic payment functions, we may entrust third-party payment companies to process your credit card information to charge related service fees according to your instructions. Similarly, when using online payments, we may entrust third-party technical or service providers to process your and your end-users’ personal information for customer due diligence and transaction monitoring and risk management. For third-party service providers we entrust to process personal information, we will sign confidentiality agreements with them, specifying the data processing purposes, processing periods, and responsibilities of both parties, requiring partners to process personal information only according to our requirements and this policy. If you refuse our suppliers’ collection of personal information necessary for providing services, it may prevent you or your end-users from enjoying the services provided by the suppliers during the use of our products and/or services.

(b) Sharing
We will not share personal information with any third party unless one or more of the following circumstances exist:

Based on the request of the personal information subject or after obtaining their explicit authorization or consent;
Related to fulfilling legal obligations;
Directly related to national security and national defense security;
Directly related to public safety, public health, and significant public interests;
Directly related to criminal investigations, prosecutions, trials, and enforcement of judgments;
Necessary for protecting the vital legal rights and interests of personal information subjects or other individuals, such as life and property, but difficult to obtain authorization and consent;
Personal information that is voluntarily disclosed by the personal information subject to the public;
Personal information collected from legally disclosed sources.
Sharing with affiliated companies: To provide you with INVAN products and/or services, recommend information you may be interested in, identify abnormal user accounts, and protect the personal and property safety of INVAN affiliated companies or other users or the public from harm, you understand and agree that your and your end-users’ personal information may be shared with our affiliated companies. We will only share necessary personal information, and it will be subject to the purposes stated in this policy. If we share personal sensitive information or if affiliated companies change the purpose and processing methods of personal information, we will seek your authorization and consent again.
Sharing with third-party partners: We will only share personal information for legitimate, justified, necessary, specific, and clear purposes, and only share the necessary personal information to provide services to you or your end-users. We will not share personal information that can identify the information subject unless otherwise stipulated by laws and regulations. Generally, such partners are also data controllers who will process personal information after obtaining the consent of the personal information subjects in their own name. Partners may have their own independent privacy policies and user service agreements. We recommend that you and your end-users read and comply with these partners’ user agreements and privacy policies. Below is the detailed information on how we share information with third parties:

Advertising Partners: Unless authorized by you, we will not share personal information of your end-users with advertising partners. We will provide these partners with information on the coverage and effectiveness of their ads, or we will aggregate this information to prevent it from identifying end-users personally. These partners may combine the above information with other data they have legally obtained for advertising or decision-making purposes.
Statistical Analysis Partners: Unless authorized by you, we will not share personal information of your end-users with statistical analysis partners. We will provide these partners with aggregated information to prevent it from identifying end-users personally. These partners may combine the above information with other data they have legally obtained for statistical analysis.
Other Suppliers, Service Providers, and Partners: We may share relevant information with other suppliers, service providers, and partners to support our business, including providing technical infrastructure services, customer service, payment facilitation, or conducting academic research and surveys, complying with legal requirements, and monitoring transaction fraud or risk control. We will require them to adopt strict data protection measures and handle personal information according to our instructions, this policy, and any other related confidentiality and security measures.
Payment Partners: When you use payment services, we will share your specific personal information (including business name, business registration number, or if you are a personal merchant, your name and personal identification number, and transaction-related information) with payment partners as required to monitor transaction fraud and risk control and comply with legal and regulatory requirements (including customer due diligence and compliance with anti-money laundering and anti-terrorism laws).

(c) Transfer
We generally do not transfer personal information control rights to any third party except in the following situations:

Based on the request of the personal information subject or after obtaining their explicit authorization or consent;
Related to fulfilling legal obligations;
Directly related to national security and national defense security;
Directly related to public safety, public health, and significant public interests;
Directly related to criminal investigations, prosecutions, trials, and enforcement of judgments;
Necessary for protecting the vital legal rights and interests of personal information subjects or other individuals, such as life and property, but difficult to obtain authorization and consent;
Personal information that is voluntarily disclosed by the personal information subject to the public;
Personal information collected from legally disclosed sources;
Transfer during company mergers, acquisitions, reorganizations, bankruptcies, and changes in operational entities.
Please note that if a transfer is necessary for the above reasons, we will inform you of the purpose, type, and transferee of the transfer before it occurs and obtain your consent, except as otherwise stipulated by laws and regulations. The new entity will continue to fulfill the responsibilities and obligations under this Privacy Policy. If we go bankrupt or cease operations with no successor, we will delete or anonymize your personal information.

(d) Public Disclosure
We generally do not publicly disclose your personal information to the public or unspecified groups, except as agreed with you or as required by applicable laws and regulations.

4. How you can manage your personal information

(a) Access and Correction of Personal Information
You have the right to log in and access your INVAN account at any time to view your personal information. If you find that we have collected, stored, used, or disclosed incorrect or incomplete personal information, or in other circumstances as stipulated by laws and regulations, you can log in to the platform management backend and enter the “Personal Center” to correct or supplement your personal information.
If you wish to access or correct other personal information, or encounter difficulties in exercising the above rights, you can contact us. We will respond to your request promptly after verifying your identity, except as otherwise stipulated by laws and regulations or as agreed in this policy.

(b) Deleting Personal Information
You can contact us to request the deletion of your personal information in the following circumstances, except for anonymized data or as otherwise stipulated by laws and regulations:

We collect and use personal information in violation of laws, administrative regulations, or agreements with you;
We share or transfer personal information in violation of laws, regulations, or agreements with you, and we will immediately stop the sharing or transfer and notify the third party to delete it promptly;
You terminate the use of this platform and any INVAN products and/or services by deactivating your account;
Other circumstances stipulated by laws and regulations.
Before deleting the relevant information, we may require you to undergo identity verification to ensure account security. Once we decide to respond to your deletion request, we will delete your information from INVAN products and/or servers as soon as possible. However, due to requirements by regulatory authorities for crime prevention and national security, we will retain your communication and transaction records within the legally permitted period, but we will not use them for any other purpose. Please note that we may not immediately delete the information you request to delete from the backup system, but will delete it during the next update of the backup system.

(c) Deactivating Your Account
You can deactivate your account as stipulated in the INVAN User Agreement. You understand that deactivating your platform account will result in the permanent loss of access to the account and the data within it. After verifying your identity and handling your account assets in agreement with you, we will deactivate your account. After deactivating your account, unless required by laws to retain personal information, we will delete your personal information or anonymize it promptly.
Deactivating your account is irreversible. Once your account is deactivated, we will no longer collect your personal information or provide you with our products and/or services. Therefore, we recommend that you carefully consider your decision to deactivate your account.

(d) Restricting Automated Decision-Making Systems
In some business functions of this platform, we may make decisions based on non-manual automated decision-making systems, such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation, and

you can contact us through the methods provided in this Privacy Policy.

(e) Responding to Requests
To exercise the user rights described in this section, or if you have any questions, complaints, opinions, or suggestions, you can contact us through the contact information provided in this Privacy Policy. To ensure security, we may first require verification of your identity before processing your request. In principle, we will verify your identity and respond to your request within 15 working days of receiving your request.
We generally do not charge for reasonable requests. For repeated requests within a certain period, we will charge a reasonable cost based on the situation; for requests requiring excessive technical means (e.g., requiring the development of new systems or fundamentally changing existing practices) or other significant difficulties, we will provide alternative methods.
We will refuse your request under the following circumstances:

Related to fulfilling legal obligations;
Directly related to national security and national defense security;
Directly related to public safety, public health, and significant public interests;
Directly related to criminal investigations, prosecutions, trials, and enforcement of judgments;
Sufficient evidence shows that the user has subjective malice or abuses their rights;
Necessary for protecting the vital legal rights and interests of users or other individuals, such as life and property, but difficult to obtain authorization and consent;
Responding to the user’s request will result in significant damage to the legitimate rights and interests of the user or third parties;
Involving commercial secrets.
Please note that you should directly respond to requests regarding personal information from your end-users (not the platform’s direct customers). Unless we receive a request from you to assist, we will forward requests from your end-users to you or ask end-users to contact you directly.

5. How we store and protect personal information

(a) Storage Period
During the use of INVAN products and/or services, we will continuously store your personal information. We promise that, unless otherwise required by laws and regulations or authorized by personal information subjects, the storage time for your and your end-users’ personal information will be limited to the shortest time necessary to achieve the purposes authorized by you and your end-users.
If you deactivate your account, delete the aforementioned information voluntarily, or if we cease operations for any reason, we will stop collecting your personal information in accordance with legal requirements and delete the collected personal information or anonymize it.

(b) Storage Location
We provide this platform and INVAN products and services in multiple countries and regions. You understand that we may transfer and store the information and data you provide outside your country/region for processing. Generally, your personal information will be stored in Singapore. However, for statistical and analytical purposes, we may transfer your personal information across borders outside Singapore. In such cases, we will ensure that your personal information receives adequate protection equivalent to your country or region and will use encrypted channels for cross-border data transfer.

(c) Protection of Personal Information
We highly value your personal information security and adopt industry-standard security measures, including technical measures and organizational structures, to prevent your personal information from being disclosed, damaged, misused, unauthorized accessed, disclosed, or altered. Specific measures include:

Data Security Technical Measures: To ensure information security, we take various reasonable security technical measures to protect personal information, preventing leakage, damage, or loss. We use encryption transmission technologies such as SSL to protect data during transmission and proper protection mechanisms to prevent malicious attacks on data. We employ encryption storage and data access control mechanisms to prevent unauthorized access, public disclosure, use, modification, accidental or intentional damage, or loss of personal information.
Data Security Organizational and Management Measures: We appoint personal information protection officers and establish personal information protection institutions as required by laws. We also establish internal control management processes, setting strict access permissions to limit the scope of personal information knowledge based on the minimum necessary principle. We establish internal norms for data security use, managing employees or outsourced personnel who may come into contact with personal information through strict measures, including signing confidentiality agreements, monitoring their operations, and taking necessary actions based on their positions.
Data Security Contract Guarantees: Before indirectly collecting your personal information from third parties, we explicitly require in writing that the third party obtain your explicit consent before collecting and processing your personal information. We require third parties to ensure the legality and compliance of personal information sources through written agreements and bear corresponding legal responsibilities in case of violations. Before sharing your or your end-users’ personal information with partners, we strictly require partners to assume information protection obligations and responsibilities. We require partners to sign data processing agreements or include data protection clauses in cooperation agreements, stipulating partners’ confidentiality obligations for user information, including information storage, use, and flow, meeting our control requirements and subjecting to our review, supervision, and audit. In case of violations, we require partners to bear corresponding legal responsibilities.
Security Incident Handling: In the unfortunate event of a personal information security incident, we will immediately initiate an emergency response plan, take remedial measures, record the incident, and promptly report it as required by applicable laws and regulations. If the incident may cause significant harm to your or your end-users’ legitimate rights, such as personal sensitive information leakage, we will inform you of the incident’s basic situation and possible impact, measures we have taken or will take, recommendations for risk prevention and reduction, remedial measures we provide, and our contact information. We will inform you of the above information via email, letter, phone, or push notification, and if individual notification is difficult, we will take reasonable and effective measures to publish a public warning.
Please understand that the internet is not an absolutely secure environment. We strongly recommend that you use secure methods and complex passwords to help ensure your account’s security. If you discover your personal information has been leaked, especially if your account or password is disclosed, please contact us immediately using the contact information provided in this policy so that we can take corresponding measures to protect your information security.

6. How we update this policy

We may revise the terms of this Privacy Policy from time to time, and the revisions will constitute a part of this policy. If these revisions result in a substantial reduction of your rights under this policy, we will notify you by prominently posting on the homepage or sending an email or other methods before the revisions take effect. In such cases, if you do not agree with this policy or the modified, updated content, you can choose to stop using our products and/or services or deactivate your account. However, please note that your behavior and activities before deactivating your account or stopping using this platform will still be subject to this policy.
In case of significant, substantial changes, we will notify you prominently based on the specific circumstances.
Significant, substantial changes include but are not limited to the following situations:

Major changes in our service model, such as the purpose of processing personal information, the type of processed personal information, and the way personal information is used;
Significant changes in your participation in personal information processing and the exercise of your rights;
Significant changes in our ownership structure, organizational structure, etc.;
Significant changes in the main objects of personal information sharing, transfer, or public disclosure;
Changes in the department responsible for personal information security, contact information, and complaint channels;
High-risk personal information security impact assessment report.

7. How to contact us

If you have any questions, opinions, or suggestions about the content of this policy, you can contact us through the following ways:
Please send your feedback to: info@invangrills.com

8. Definitions

You: Refers to the registered and using buyer users of INVAN and/or their employees and/or developers or other personnel authorized to operate this platform.
Personal Information: Refers to various information recorded electronically or otherwise that can identify a specific natural person’s identity or reflect a specific natural person’s activities alone or in combination with other information. Personal information involved in this Privacy Policy includes names, birthdates, identification numbers, personal biometric information, addresses, contact details, communication records and contents, passwords, property information, transaction information, etc.
Personal Sensitive Information: Refers to personal information that, if leaked, illegally provided, or misused, may endanger personal and property safety, easily cause damage to personal reputation, physical and mental health, or lead to discriminatory treatment, including identification numbers, personal biometric information, bank accounts, property information, credit information, movement trajectories, health physiological information, transaction information.
Deletion: Refers to the act of removing personal information involved in the realization of daily business functions from the system to keep it in an unretrievable and inaccessible state.
Anonymization: Refers to the process of making it impossible to identify or associate you through technical processing of personal information, and the processed information cannot be restored.