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Privacy Policy

Table of Contents

• 1. Changes to This Privacy Policy
• 2. Information We May Collect
• 3. How Your Personal Data Is Collected
• 4. Purposes for Which We Use Your Personal Data
• 5 .Disclosure of your personal data
• 6. Automated Decision-Making Technology (ADMT)
• 7. Cookies & Tracking Technologies
• 8. Platform Opt-Out Links
• 9. Global Privacy Control (GPC)
• 10. International Transfers
• 11. Security
• 12. Data Retention
• 13. Third-Party Links
• 14. Your Privacy Rights
• 15. Sensitive Personal Information (CPRA)
• 16. Contact Us
• 17. Glossary
• 18. Appendix A – Third-Party Cookies: Affirm

1. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated “Last Updated” date. Where appropriate, we will notify you by email. We encourage you to check this page periodically. Your continued use of our Platform after changes are posted constitutes your acceptance of those changes.

2. Information We May Collect

'Personal data' (or 'personal information') means any information about an individual from which that person can be identified. It does not include anonymized data. We may collect, use, store, and transfer the following categories of personal data:

• • Identity Data: First name, last name, username or similar identifier, marital status, title, date of birth, and gender.
• • Contact Data: Billing address, delivery address, email address, and telephone numbers.
• • Financial Data: Bank account and payment card details.
• • Transaction Data: Details about payments to and from you and other details of products and services you have purchased from us.
• • Technical Data: Internet protocol (IP) address, login data, browser type and version, time zone and location, browser plug-in types and versions, operating system and platform, and other technology on devices you use to access our Platform.
• • Profile Data: Your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• • Usage Data: Information about how you use our website, products, and services, including browsing history, search history, and interaction with our Platform.
• •Marketing and Communications Data: Your preferences for receiving marketing from us and third parties, and your communication preferences.
• • Geolocation Data: We collect your IP address automatically when you visit our website or initiate an order, and may determine your general location from it.
• • Sensory / Call Recording Data: When you contact us by phone, we may record calls for training and quality purposes. You will be notified at the start of any recorded call.
• • Inferences: We may derive inferences about your preferences, characteristics, predispositions, behavior, attitudes, and aptitudes from the information we collect, to build a consumer profile for marketing and service purposes.

Sensitive Personal Information

We do not intentionally collect Special Categories of Personal Data (e.g., race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic, or biometric data) or information about criminal convictions. If you believe we have inadvertently collected such data, please contact us immediately using the details in Section 16.

Aggregated Data

We may collect, use, and share Aggregated Data (e.g., statistical or demographic data) for any purpose. Aggregated Data is not personal data. If we combine it with personal data in a way that can identify you, we treat the combined data as personal data subject to this Policy.

3. How Your Personal Data Is Collected

Direct Interactions

You may provide Identity, Contact, and Financial Data by filling in forms or corresponding with us by post, phone, email, or otherwise, including when you:

• • Apply for our products or services;
• • Create an account on our website;
• • Subscribe to our service or publications;
• • Request that marketing be sent to you;
• • Enter a competition, promotion, or survey;
• • Give us feedback.

Automated Technologies or Interactions

As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions, and patterns using cookies, server logs, pixel tags, and similar technologies. See Section 7 (Cookies & Tracking Technologies) for details.

Third Parties and Publicly Available Sources

We may receive personal data about you from:

• • Analytics providers such as Google (based outside the EU);
• • Advertising networks;
• • Search information providers;
• • Providers of technical, payment, and delivery services;
• • Data brokers or aggregators;
• • Publicly available sources such as Companies House and the Electoral Register (EU).

4. Purposes for Which We Use Your Personal Data

We use personal data for the following purposes and on the following lawful bases:

• • To register you as a new customer: Identity, Contact. Lawful basis: Performance of a contract.
• • To process and deliver your order (manage payments; collect money owed): Identity, Contact, Financial, Transaction, Marketing & Communications. Lawful basis: Performance of a contract; Legitimate interests (debt recovery).
• • To manage our relationship (notify you of changes; request reviews/surveys): Identity, Contact, Financial, Transaction, Marketing & Communications. Lawful basis: Performance of a contract; Legal obligation; Legitimate interests (keeping records updated).
• • To enable prize draws, competitions, or surveys: Identity, Contact, Profile, Usage, Marketing & Communications. Lawful basis: Performance of a contract; Legitimate interests.
• • To administer and protect our business and Platform: Identity, Contact, Technical. Lawful basis: Legitimate interests (IT, security, fraud prevention); Legal obligation.
• • To deliver relevant content and advertising and measure effectiveness: Identity, Contact, Profile, Usage, Marketing & Communications, Technical. Lawful basis: Legitimate interests.
• • To use data analytics to improve our Platform, marketing, and customer experience: Technical, Usage. Lawful basis: Legitimate interests.
• • To make suggestions and recommendations about goods or services: Identity, Contact, Technical, Usage, Profile. Lawful basis: Legitimate interests.
• • To use Automated Decision-Making Technology (ADMT): Usage, Profile, Inferences. See Section 6 for full details.

5. Disclosure of Your Personal Data

We may share your personal information with:

• • Members of our corporate group (subsidiaries, holding companies, and their subsidiaries);
• • Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you;
• • Analytics and search engine providers that assist in improving and optimizing our Platform;
• • Credit reference agencies for the purpose of assessing your credit score;
• • Advertising and marketing partners;
• • A prospective seller or buyer if we sell or buy any business or assets;
• • A third party that acquires substantially all of our assets, in which case personal data is one of the transferred assets; and
• • Law enforcement, regulators, or other parties where required by law, to enforce our terms, or to protect our rights or the rights and safety of others (including for fraud protection and credit risk reduction).

We require all third parties to respect the security of your personal data and treat it in accordance with the law. We do not allow third-party service providers to use your personal data for their own purposes; we only permit them to process it for specified purposes and in accordance with our instructions.

6. Automated Decision-Making Technology (ADMT)

In compliance with the California Consumer Privacy Act (as amended by the CPRA) and related regulations, we disclose our use of Automated Decision-Making Technology (ADMT) — any system that uses computation to make or facilitate decisions about consumers.

How We Use ADMT

We use ADMT for the following purposes:

• • Personalized Marketing & Product Recommendations: We use automated profiling to analyze your browsing behavior, purchase history, preferences, and interactions on our Platform to generate personalized product recommendations and targeted advertising.
• • Fraud Detection and Prevention: Automated systems analyze transaction patterns and account activity to detect and prevent fraudulent transactions.
• • Credit & Risk Assessment: Where applicable, automated tools assist in assessing creditworthiness and risk as part of our purchasing or financing processes.
• • Website Optimization: We use analytics and automated tools to understand how consumers use our Platform and to improve content and functionality.

Your Right to Opt Out of ADMT

California residents have the right to opt out of the use of ADMT that produces legal or similarly significant effects concerning you. To exercise this right, please contact us at:

• • privacy@CyberPowerPC.com

We will process your request within 45 days of receipt, unless an extension is required, in which case we will notify you.

Human Review

Where ADMT produces a decision that significantly affects you (e.g., a credit decision or account restriction), you may request that a qualified human review the decision. To make such a request, contact us using the details in Section 16.

7. Cookies & Tracking Technologies

A cookie is a small text file placed on your device when you access our Platform. We use cookies and similar tracking technologies (pixel tags, web beacons, and scripts) to:

• • Ensure the Platform works correctly;
• • Remember your preferences and settings;
• • Understand how visitors use our Platform (analytics);
• • Deliver targeted advertising; and
• • Measure advertising effectiveness.

On your first visit, our cookie consent tool will ask for your explicit consent for non-essential cookies, in compliance with applicable law. You may withdraw consent at any time through our cookie settings.

Essential Cookies

Essential cookies are strictly necessary for our website to work. They allow you to browse our products, add items to your cart, complete a purchase, log in to your account, and get help from our support team. Without them, these core features of our website would not function.

Essential cookies cannot be disabled. They are always active and are never used to track you for advertising purposes.

Google Analytics

Google Analytics is used to track visitor usage and behavior. It uses cookies to monitor engagement and usage but does not store, save, or collect personal information in identifiable form. You can review Google’s Privacy Policy at https://policies.google.com/privacy.

Third-party cookies

Third-party partners — including Twitter/X, Facebook/Meta, LinkedIn, TikTok, and Affirm — may also set cookies on our Platform. Those parties are responsible for their own cookies. For more information, visit the respective party's privacy policy. See also Appendix A for information about Affirm.

How to Manage or Disable Cookies

You can change your browser settings to refuse cookies. Note that disabling some cookies may affect Platform functionality. Browser-specific instructions:

• • Google Chrome
• • Mozilla Firefox
• • Internet Explorer / Edge
• • Opera
• • Safari
• • allaboutcookies.org

8. Platform Opt-Out Links

We participate in advertising programs operated by third-party platforms. You may opt out of interest-based advertising and data sharing on those platforms using the links below:

• • Google Ad Center: myadcenter.google.com
• • Meta (Facebook/Instagram) Ads: accountscenter.facebook.com/ads
• • TikTok Ads: TikTok Ads Opt-Out
• • WebChoices (Digital Advertising Alliance): optout.aboutads.info
• • AppChoices (Mobile App Opt-Out): youradchoices.com/appchoices

Please note that opting out through these platforms does not opt you out of receiving all advertising — you may still see generic, non-targeted ads. These opt-outs are managed by third parties, and we do not control their processes.

9. Global Privacy Control (GPC)

We honor the Global Privacy Control (GPC) signal. The GPC is a browser-level signal that communicates a consumer’s opt-out preference for the sale and sharing of personal information to websites automatically, without requiring individual opt-out requests on each site.

If your browser or device transmits a GPC signal when you visit our Platform, we will treat it as a valid opt-out request under the CCPA and CPRA (Cal. Civ. Code §1798.135(c)). We will stop selling or sharing your personal information for cross-context behavioral advertising as required by California law.

What GPC does

• • Automatically opts you out of the sale and sharing of your personal information for targeted advertising;
• • Applies to the specific browser or device on which the signal is enabled; and
• • Is processed each time you visit our Platform with a GPC-enabled browser.

What GPC does not do

• • GPC does not opt you out of all data collection — we may still collect data necessary to operate our Platform and provide our services;
• • GPC does not apply to other devices or browsers where GPC is not enabled; and
• • GPC does not replace your right to submit a manual Do Not Sell or Share request, which may cover additional contexts.

How to enable GPC

You can enable GPC through supported browsers and browser extensions. For more information and a list of compatible tools, visit:
• • globalprivacycontrol.org

10. International Transfers

We do not routinely transfer your personal data outside the European Economic Area (EEA). If we do — for example, when using technology supported outside the EEA — we ensure the transfer is to a country with an adequate level of data protection, or we implement appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms.

11. Security

We have implemented appropriate technical and organizational security measures to protect your personal data from accidental loss, unauthorized use, access, alteration, or disclosure. However, the transmission of information via the internet is not completely secure. We have procedures to deal with suspected personal data breaches and will notify you and any applicable regulator as legally required.

12. Data Retention

We retain your personal data only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements.

By law, we must keep basic information about customers (Contact, Identity, Financial, and Transaction Data) for six (6) years after they cease being customers for tax purposes

In some circumstances, you may ask us to delete your data (see Section 14). In some circumstances we may anonymize your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

13. Third-Party Links

Our Platform may, from time to time, contain links to the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that they have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check these policies before submitting any personal data to those websites.

14. Your Privacy Rights

The following rights apply to all users of our Platform. California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) — where a right is California-specific, it is noted with the applicable legal reference.

• • Right to Access / Know: Request a copy of the personal data we hold about you and check we are lawfully processing it.
• • Right to Correct: Request correction of any incomplete or inaccurate data we hold about you.
• • Right to Delete (Erasure): Ask us to delete or remove your personal data where there is no good reason for us to continue processing it, subject to certain exceptions.
• • Right to Object: Object to processing of your personal data where we rely on legitimate interests (or those of a third party), or where we process it for direct marketing purposes.
• • Right to Restrict Processing: Request that we suspend processing of your personal data in certain scenarios.
• • Right to Data Portability: Request the transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format.
• • Right to Opt Out of Sale / Sharing / ADMT: See Section 6 for details on opting out of Sale, Sharing, and ADMT.
• • Right to Withdraw Consent: Withdraw consent at any time where we rely on consent to process your data. This does not affect the lawfulness of processing before withdrawal.
• • Right to Non-Discrimination: We will not discriminate against you in price, service quality, or otherwise for exercising your privacy rights.

To exercise any of these rights, please contact us as set out in Section 16. We will respond to your request within 45 days. If we need more time, we will notify you.

15. Sensitive Personal Information (CPRA)

Under the CPRA, 'sensitive personal information' includes social security numbers, financial account details, precise geolocation data, racial or ethnic origin, religious beliefs, union membership, personal communications, genetic data, biometric data, health information, and information about sex life or sexual orientation.

We collect the following sensitive personal information: financial account and payment card details (for transaction processing) and IP-based general geolocation data.

We use sensitive personal information only to provide our services and for security purposes. We do not use or disclose it for purposes other than those specified under Cal. Civ. Code §1798.121.

California residents may request that we limit the use and disclosure of their sensitive personal information to only what is necessary to provide our services, by contacting us at the details in Section 16.

16. Contact Us

Questions, comments, and requests regarding this Privacy Policy are welcomed. Please contact our Privacy Team:

• • Email: privacy@CyberPowerPC.com
• • Phone: 800-707-0393
• • Post: CyberPowerPC, Attn: Privacy Team, 730 Baldwin Park Blvd., City of Industry, CA 91746, USA

17. Glossary

• • ADMT (Automated Decision-Making Technology): Any system that uses computation to make or facilitate decisions that significantly affect consumers.
• • CCPA: California Consumer Privacy Act of 2018.
• • CPPA: California Privacy Protection Agency.
• • CPRA: California Privacy Rights Act of 2020, amending the CCPA.
• • EEA: European Economic Area.
• • Legitimate Interest: The interest of our business in conducting and managing our operations in a way that enables us to give you the best service and most secure experience. We consider and balance any potential impact on you and your rights before processing your personal data for legitimate interests.
• • Performance of Contract: Processing necessary for the performance of a contract to which you are a party, or to take steps at your request before entering such a contract.
• • Personal Data / Personal Information: Any information about an individual from which that person can be identified.
• • Sale: Under the CCPA/CPRA, selling, renting, releasing, disclosing, disseminating, making available, transferring, or communicating personal information to a third party for monetary or other valuable consideration.
• • Sensitive Personal Information: A defined subset of personal information under the CPRA — see Section 15.
• • Sharing: Under the CPRA, sharing personal information for cross-context behavioral advertising, whether or not for money.

18. Appendix A – Third-Party Cookies: Affirm

We offer Affirm as a buy-now-pay-later financing option. When you use Affirm, Affirm may collect additional information about you to facilitate financing. This includes:

• • IP address and device information (identifier, name, type, operating system, location, mobile network information);
• • Standard web log information (browser type, traffic to and from our site, pages accessed);
• • Usage and interaction data with our website and Affirm's services;
• • Purchase history, content viewed, event information, and click stream data; and
• • Cookies that may uniquely identify your browser or Affirm account.

Affirm may also collect information about you from any contact you have with their services or employees, including customer support interactions, surveys, and interactions with their affiliates.