This Privacy Policy describes how your Personal Information is collected, used, and shared when you visit or make a purchase from www.ugramo.com (the “Site”)， and its mobile applications (the “Application”), Ugramo implements the processing of personal data listed below.

1. Data processing implemented by Ugramo

1.1 Processing of personal data related to your visit to our website and the purchase and use of our products.

When you visit the Site or purchase a product through the Site, we automatically collect certain information about your device (commonly called “Device Information”) including information about:

- Web browser
- IP address
- Time zone
- The name and URL of the retrieved file, the website/app from which access was made (referrer URL)

1.2 Processing of personal data related to comments areas. Said comments and the related personal data are provided by the User voluntarily. We will collect information including:

- Email address
- Name or nickname
- Profile photo
- The content of your comment

1.3 When you make a purchase or attempt to purchase through the Site, we collect certain “Order Information” from you, including:

- Name - Email address
- Country
- Billing address
- Shipping address
- Phone number (voluntary)
- Payment information such as Credit card information (type, number, expiration date, CVV security code)/debit card information or other payment/billing information.
- Information we get from your use of our products. We collect information about the products that you use and how you use them and your local device information, such as gender, age, height, weight, training goals, training history, sporting activities, mealtimes, etc.

1.4 Processing of personal data related to newsletters and advertising emails voluntarily. Said data collection including:

- Email address
- Name or nickname
- Country
- Preferred product
- An operation to the promotion emails

2. Purpose and legal basis of the processing

Ugramo uses the Personal Information we collect about you for the following purposes:

2.1 Device information collecting purpose

• Help us screen for potential risk and fraud (in particular, your IP address);
• Generally, to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site;
• To ensure the website connection and system stability.

2.2 Order information collecting purpose

• For Ugramo to provide the User with the ordered product(s);
• For the performance of a contract to which the User is party, following Article 6.1.b of the GDPR and the collected data are necessary for Ugramo to identify and bill the User and to charge its bank card number;
• For verifying your identity and providing customer service or support;

2.3 Comments information collecting purpose

• To improve our product user experience and provide the consumers and potential consumers with better and transparent information about Ugramo products.

2.4 Information for newsletter collecting purpose

• Provide consumers and potential consumers with information and news regarding products or services.

3. Recipients of the Personal Data

We may also share your Personal Information with third parties that help us to run our business. Such third parties include providers of payment processing services, server services providers, data analysis services providers, fraud monitoring and prevention providers, email delivery service providers, social media, and other marketing platforms and service providers. In addition, Ugramo may disclose the User’s personal data:

- if Ugramo is under a duty to disclose or share such personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of its business, its customers or others; and
- to successors in title or replacement operators of all or part of Ugramo respective businesses.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful requests for information we receive, or to otherwise protect our rights.

4. Behavioral Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/.

5. Cookies and Track

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

6. Data Retention

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information. And we are trying to apply the highest standard to data security.

7. Your Rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us.

Additionally, if you are a European resident, we note that we are processing your information to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including Canada and the United States.

8. Changes

We may update this privacy policy from time to time to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

9. Contact Ugramo

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at support@ugramo.com.