PRIVACY POLICY OF ENGWE
Last Updated: 29.05.2026
Effective Date: 29.05.2026
Version: V2.0
§1
GENERAL PROVISIONS
This Privacy Policy (hereinafter referred to as the "Policy") applies to the processing of personal data collected in relation to the operations of website 【https://pl.engwe.com/】operated by ENGWE, in particular sets rules pertaining to personal data protection and security of other data submitted by you via website.
§2
DEFINITIONS
The terms used in this document are of the meaning as follows:
1. GDPR - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).
2. UK GDPR (United Kingdom General Data Protection Regulation) - The version of the EU General Data Protection Regulation (Regulation (EU) 2016/679) as incorporated into United Kingdom domestic law pursuant to section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019.
3. User (otherwise referred to as “you”) - a natural person who uses the website for your own purposes, consisting in reviewing the website, creating an account on the website, using the services or purchasing products offered by us.
4. Website – a website operated by us, via which you may, among others, purchase our products, contact us, etc.
§3
CONTACT WITH CONTROLLERS
Whenever you have a doubt or question regarding the processing of your personal data, you may reach us:
· via e-mail: [service.pl@engwe.com]
· Via tel: 【+33 805980036】
· LiveChat on our website
§4
PROCESSING OF YOUR DATA
I. Is it necessary to provide your personal data?
The personal data within the meaning of the GDPR and UK GDPR are any information which, on its own or jointly with other information, allow to identify you, directly or indirectly. ENGWE may process your personal data in connection with usage of the Website.
You provide us with your data when using the Website, including when reviewing the Website, searching for products or registering on the Website . Providing data is voluntary, but necessary for you to use the Website, as well as to achieve other goals. You may refuse to provide us with your personal data. However, such refusal may result in inability to enter contractual relation with ENGWE (e.g., inability to place the order).
In some cases, your personal data will be processed after obtaining your explicit consent. You may, at any time, withdraw the consent granted by contacting us via chosen channel as provided in §3 above.
II. What categories of data do we process?
While using the Website, we may collect (and process in the manner as described below) your personal data, such as:
1) contact data and login (e.g., name, surname, e-mail address, phone number)
2) location data, however only restricted to the country level in case you did not make a purchase
3) shipping address
4) billing data (e.g., abbreviated account number, address)
5) technical data (e.g., IP address, device ID number and information, information on operating system and/or search engine used)
6) statistical data (e.g., way of usage of the Website, history of purchases)
7) data saved on your account (e.g. purchase history, unfinished purchases
8) the contents of your communication with us (eg. via contact form, livechat)
9) the contents of your rating and comments on our website
10) profile name and profile contents in case you use the social plug ins (eg. Facebook, Instagram) available on our website
11) your preferences and settings for website display (as collected by cookies – please refer below)
We will process the data collected by cookies – for further information please see Cookie Policy.
III. For what purposes and how long ENGWE process your personal data?
We process your personal data based on the following legal basis according to the Regulation (EU) 2016/679 (the “EU GDPR”) or, where applicable, the “UK GDPR” for the following purposes:
|
Purpose of personal data processing |
Legal basis for personal data processing |
Retention period* |
|
Website usage: Usage of website by the users – non-registered and registered Users (including review of our products posted by you on our page) |
Our legitimate interest being providing the users with necessary functionalities of the website, as well as providing the users with complex information on our products (including reviews of the products by other users) – article 6 (1) (f) of the GDPR
|
As long as it is necessary to fulfil legitimate interest of a controller |
|
Your consent to analyzing user behavior and creating a forecast for the future, which is designed for displaying content to the user in accordance with his individual preferences and interests of the user – article 6 (1) (a) of the GDPR |
Until you revoke your consent, but in any case, not longer than 1 year after your visit on the website. |
|
|
Account management & order handling: Including: · Usage of website by registered Users (creation and operation of an account, etc.) · Completing the transaction between you and ENGWE, including processing of your order, delivery of orders, customer support, payments, processing of returns etc. · Data processed with relation to review of our products posted by you on our page · Carrying out internal statistics, analysis, customer satisfaction surveys, market surveys and other similar activities |
Performance of a contract or taking steps at your request prior to entering into a contract - article 6 (1) (b) of the GDPR
|
Until you decide to no longer use our Website by deleting the account |
|
Compliance with a legal obligation (e.g., arisjng from tax, custom or accounting law) – article 6 (1) (c) of the GDPR |
Time period arising from relevant legislation (e.g., tax provisions) |
|
|
Our legitimate interest being providing the users with complex information on our products (including reviews of the products by other users) – article 6 (1) (f) of the GDPR |
As long as it is necessary to fulfil legitimate interest of a controller |
|
|
Our legitimate interest being enhancement of offered services, customer service and website functionalities via analysis and statistics - article 6 (1) (f) of the GDPR |
Until you decide to no longer use our Website by deleting the account, |
|
|
Inquiry handling: Contact between you and ENGWE (e.g. via contact form), including handling of your complaints, questions and requests |
Our legitimate interest being ensuring the highest level of customer service – article 6 (1) (f) of the GDPR |
3 years from the last electronic contact or use of the Website |
|
Marketing: Marketing activities, presentation of tailored advertisements and offers (including our newsletter) |
Your consent to receive marketing content and to adapt as precisely as possible products and services offered on the Website to your preferences or the preferences of larger group of customers – article 6 (1) (a) of the GDPR |
Until you revoke your consent, but in any case, not longer than 1 years after your open last communication received from us. |
|
Website maintenance: Maintenance, management, preservation and other related works on the ENGWE’ websites |
Our legitimate interest being provision of the proper functioning and maintenance of the Website and ensuring the safety of its use – article 6 (1) (f) of the GDPR |
As long as it is necessary to fulfil legitimate interest of a controller |
|
Management of claims: Establishment, assertion or defence against claims |
Our legitimate interest being legal necessity of proving facts and providing proofs in case of claims against or raised by ENGWE - article 6 (1) (f) of the GDPR |
The period prescribed by law depending on the type of claim or legal proceedings (until the time limit provided for the claim under applicable laws expires) |
* Indicated periods of data retention (storage) may be extended if it is necessary to further process the data in order to defend or pursue legal claims. In such event, we will process data for the duration of the proceedings in the case in question.
Please note we may use your data for profiling for marketing reasons, but we will not use your data to conduct automated decision-making.
IV. How long will we process and how we store your personal data?
We may process your personal data on the basis of the legitimate interests until our legitimate interests are fulfilled, or until you object to such processing. We will handle the data processed for other purposes for the period required by applicable law on, among others, taxation and accounting. In the absence of the provisions of such laws, we may process personal data for the duration of the contract and after its termination - for the period no longer than statute of limitations of potential claims. For detailed information please refer to the table in point III above.
Currently ENGWE store your personal data in Germany. We will retain data in accordance with relevant laws and regulations on data storage. We will take necessary and appropriate security measures to ensure data security, taking into account the characteristics, scope and purpose of personal data processing, the risks that may be encountered during the processing, and the serious consequences of damage. For example, we will take a combination of encryption and de-identification technical measures, as well as necessary organizational and management measures to prevent data from being misused, unauthorized access, and unauthorized modification, disclosure or destruction, etc.
V. How we disclose your personal data?
When necessary, we may disclose your personal data to the following categories of recipients:
· service providers, supporting us in daily operations (e.g., delivery, logistics, storage services, payment processing services or IT services providers)
· other companies within ENGWE group, when it is necessary to fulfil our obligations towards you
· regulatory authorities, courts or competent authorities (upon their request in order to comply with applicable standards and laws or to safeguard their rights and interests)
· entities providing advisory services to us (e.g., our insurers, lawyers, tax advisors and other advisors when necessary)
· entities involved in formal proceedings (e.g., restructuring, merger, acquisition, or a bankruptcy or liquidation proceedings)
· postal service providers / courriers
· operators of plugins for marketing purposes (e-mail marketing, SMS marketing, social media marketing, loyalty programs)
§5
TRANSFER OF DATA
ENGWE is based in the People’s Republic of China. When using the Website, your data may be transferred to and processed in the company outside of your country of residence. Specifically, this may include China, and Hong Kong SAR, China.
In the course of our operation, we use support from professional companies in the other field. In such cases, your personal data might be transferred and processed in countries outside your country of residence. Specifically, this may include Canada, the United States of America, China, and Hong Kong SAR, China.
We transfer personal data outside your country of residence only when necessary.And in the event of a transfer by ENGWE, we ensure that: (i) the personal data is transferred to countries recognized as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard contractual clauses adopted by the European Commission. You may obtain a copy at: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
§6
YOUR RIGHTS
You have a number of rights related to the protection of the personal data we process about you. Please be aware these rights may be subject to certain limitations arising from the specific provisions of the GDPR and other related data protection laws, depending on the purpose and legal basis of the processing.
On the grounds of the GDPR, you are granted the following rights allowing you to control your personal data and related processing activities:
· Right of access: you have the right to request from us to access your personal data and receive a copy of them. The first copy is free of charge (for subsequent ones, we may impose a fee in the amount resulting from the administrative costs).
· Right to rectification: you have the right to rectify your personal data if it is incorrect or incomplete.
· Right to erasure or restriction of processing: you have the right to request deletion of data or limitation of data processing. If the correctness, legality or our need to process your personal data is questioned, we will limit the processing of your personal data to the minimum necessary (storage), and in appropriate cases we will process it only for the purpose of establishing, pursuing or defending claims or, if necessary, for the protection of another natural or legal person, or due to other limited considerations resulting from applicable law.
· Right of object: you have the right to object to processing, if the data is processed in order to implement a legitimate interest, and your objection is justified by a special situation, which will result in us ceasing to process your personal data, until we prove the existence of valid legitimate grounds for processing, overriding the interests, rights and freedoms of the data subject, or grounds for establishing, pursuing or defending claims;
· Right to data portability: you have the right to request data portability, if the data is processed on the basis of consent or for the conclusion or performance of a concluded contract, and the data is processed in an automated manner.
· Right to withdraw consent: you have the right to withdraw your consent to the processing of your personal data by us at any time (without prejudice to the lawfulness of the processing performed on the basis of consent before its withdrawal).
To some extent you may exercise your rights directly on our Website (e.g., by amending incorrect data). In other cases, to exercise your rights, please contact us at via chosen channel as provided in §3 above.
In addition, if you believe that processing of personal data performed by us is not compliant with the applicable personal data protection provisions, you have right to lodge a complaint with a personal data supervisory authority. The list of data protection authorities within the European Union can be found at: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
If you are based in:
the UK , your local data protection authority is the UK Information Commissioner’s Office (https://ico.org.uk/global/contact-us/).
Switzerland, your local data protection authorities is the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html).
Ireland, your local data protection authority is the Data Protection Commission (https://www.dataprotection.ie/en/contact/how-contact-us).
§7
How We Handle the Personal Information of Children
We do not provide our products or services to children under the age of 13 or the equivalent age as specified by law in your jurisdiction (we will define children mainly based on the laws and regulations of the country or region where our business is located because laws of different countries may differ when defining the age of children). We do not knowingly collect children’s personal data or use children’s personal data for the purposes of marketing and our product does not actively ask for children's data. If you find that a child’s data has been collected to us, please send an email to [service.pl@engwe.com] to contact us. We will remove the relevant data as soon as possible. If we become aware that a child has provided us with personal data, we will take steps to delete their personal data from ENGWE as soon as possible.
§8
FINAL PROVISIONS
We reserve the right to update and change this Policy at any time. In this case, we will publish changes to the Policy through our Website. If any substantial amendments will be introduced to this Policy, we may notify you using different channels e.g., direct notification via e-mail.
