Privacy Policy

Shenzhen Neutro Technology Co., Ltd. respects your privacy and is committed to protecting the personal information that we collect and process.

This Privacy Policy explains how Neutro collects, uses, stores, shares and protects personal information when you visit https://neu-tro.com/ , submit an inquiry, use a contact form or chat function, upload text or images, request product information, communicate with us or otherwise interact with our products and services.

In this Privacy Policy, “Neutro,” the “Company,” “we,” “us” and “our” refer to Shenzhen Neutro Technology Co., Ltd. “You” and “your” refer to an individual who visits or uses the Website, communicates with us, represents a customer or supplier, or otherwise provides personal information to us.

Please read this Privacy Policy carefully. By using the Website or voluntarily providing personal information to us, you acknowledge that you have read and understood the practices described in this Privacy Policy.

1. Company and Data Controller Information

The Website is operated by:

Company Name: Shenzhen Neutro Technology Co., Ltd.
Website Name: Neutro
Website: https://neu-tro.com/
Country: People’s Republic of China
Address: Room 269I, 2nd Floor, Building 523, Bagualing Industrial Zone, Bagua Third Road, Hualin Community, Yuanling Street, Futian District, Shenzhen, Guangdong Province, China
Email: [email protected]
Contact Page: https ://neu-tro.com/contacts-us/

For the purposes of applicable personal information and data protection laws, Shenzhen Neutro Technology Co., Ltd. generally acts as the personal information processor, data controller or business responsible for determining why and how personal information is processed through the Website.

2. Scope of This Privacy Policy

This Privacy Policy applies to personal information collected through or in connection with:

The Neutro Website;
Website contact forms and quotation request forms;
Website chat windows and messaging functions;
Email communications initiated through the Website;
Product, sample, customization and service inquiries;
Uploaded text, photographs, designs, documents or other materials;
Business communications with customers, prospective customers, suppliers and business partners;
Order preparation, project evaluation and after-sales communication; and
Other online or offline interactions that refer to this Privacy Policy.

This Privacy Policy does not apply to independent third-party websites, platforms or services that may be linked from the Website. Those third parties maintain their own privacy policies and are responsible for their own processing activities.

3. What Is Personal Information?

“Personal information,” “personal data” or similar terms generally refer to information relating to an identified or identifiable natural person.

Personal information may directly identify an individual, such as a name or email address, or may identify an individual when combined with other information, such as an IP address, company position, telephone number, communication history or device identifier.

Personal information generally does not include information that has been irreversibly anonymized so that it can no longer be associated with an identifiable individual.

4. Personal Information We Collect

The types of personal information we collect depend on how you interact with us. We seek to collect only information that is reasonably necessary for the relevant purpose.

4.1 Information You Provide Directly

You may provide personal information to us when you complete a form, send an email, use a chat window, request a quotation, request samples, upload materials or communicate with our staff.

This information may include:

Your full name;
Company name;
Job title or business role;
Business email address;
Telephone number;
WhatsApp or other messaging contact details;
Country, region or business location;
Company website or social media information;
Product categories in which you are interested;
Estimated order quantity or purchasing requirements;
Formula, ingredient, packaging or customization requirements;
Target market and intended sales channels;
Messages, questions, comments and communication records;
Shipping or consignee information where relevant;
Billing and transaction-related information where relevant;
Product feedback, quality concerns or after-sales information; and
Any other information you voluntarily provide.

4.2 Information Uploaded Through Forms or Chat Functions

The Website may allow users to enter text or upload images, artwork, packaging references, logos, product photographs, design files, specifications or other documents through forms, email links or chat windows.

Uploaded materials may contain personal information. For example, a packaging design may contain the name or contact information of a brand representative, and a photograph may include identifiable individuals.

You should upload only information that is necessary for your inquiry or project. You are responsible for ensuring that you have the right and legal authority to provide any personal information relating to another person.

4.3 Information Collected Automatically

When you visit the Website, certain technical information may be collected automatically by our servers, hosting providers, security tools, analytics tools or similar technologies.

This information may include:

Internet Protocol address;
Approximate geographic location derived from an IP address;
Browser type and version;
Device type;
Operating system;
Language settings;
Screen resolution;
Referring website or source;
Pages viewed;
Links clicked;
Date and time of access;
Time spent on individual pages;
Website navigation patterns;
Error logs and diagnostic information;
Cookie identifiers; and
Information used to detect suspicious, fraudulent or malicious activity.

Some automatically collected information may not identify you by itself, but it may constitute personal information under applicable law when associated with an identifiable individual or device.

4.4 Information Received From Third Parties

We may receive personal information from third parties where permitted by law, including:

Business partners and referral partners;
Distributors, sourcing agents or purchasing representatives;
Trade fairs and industry events;
Public business directories;
Public company websites;
Social media and professional networking platforms;
Logistics, customs or delivery service providers;
Payment and financial service providers;
Fraud prevention and compliance service providers; and
Other persons involved in a customer’s project or commercial transaction.

Where information is obtained from another source, we will process it only where we have a lawful basis and only for purposes reasonably related to our business relationship, legal obligations or legitimate interests.

5. Sensitive Personal Information

Neutro does not normally require sensitive personal information through its Website.

You should not submit government identification numbers, passport information, precise financial account credentials, passwords, medical records, biometric information, information concerning racial or ethnic origin, religious beliefs, political opinions, trade union membership, sexual orientation or other sensitive personal information through general contact forms or chat windows unless it is strictly necessary and we have specifically requested it through an appropriate and secure process.

If sensitive personal information is unintentionally provided, we may delete it, restrict access to it or request that you provide the information through a more appropriate channel.

6. How We Use Personal Information

We may use personal information for the following purposes:

To operate, maintain and secure the Website;
To respond to questions, messages and contact requests;
To understand your product, customization or sourcing requirements;
To prepare quotations, product recommendations or commercial proposals;
To evaluate whether a requested project is technically and commercially feasible;
To arrange product samples or prototype development;
To communicate about formulas, ingredients, packaging, artwork and labeling;
To process and manage orders and manufacturing projects;
To provide customer service and after-sales support;
To manage business relationships with customers, suppliers and service providers;
To coordinate shipping, delivery, customs and logistics activities;
To verify information and protect against fraud or unauthorized activity;
To maintain Website security and prevent malicious use;
To monitor Website performance and improve usability;
To analyze general Website traffic and user engagement;
To improve our products, services and business processes;
To maintain accounting, tax, compliance and transaction records;
To establish, exercise or defend legal claims;
To comply with applicable laws, regulations and governmental requests;
To enforce our Terms and Conditions and other agreements; and
For other purposes disclosed to you at the time information is collected.

We will not process personal information for a materially incompatible purpose without providing appropriate notice and, where required, obtaining consent.

7. Legal Bases for Processing

Depending on the applicable law and the circumstances, we may process personal information on one or more of the following legal bases:

7.1 Consent

We may process personal information where you have voluntarily and clearly consented to the processing. Where processing is based on consent, you may withdraw your consent at any time, subject to applicable law.

7.2 Contractual Necessity

We may process information where it is necessary to take steps at your request before entering into a contract or to perform a contract with you or the organization you represent.

This may include preparing a quotation, evaluating a product requirement, producing samples, processing an order or providing customer support.

7.3 Legal Obligations

We may process information where necessary to comply with legal, accounting, tax, customs, regulatory, product safety, recordkeeping or other statutory obligations.

7.4 Legitimate Interests

Where permitted by applicable law, we may process personal information where it is necessary for our legitimate business interests and those interests are not overridden by your fundamental rights and freedoms.

These interests may include:

Operating and protecting our Website;
Responding to business inquiries;
Developing commercial relationships;
Preventing fraud and security incidents;
Improving products and services;
Maintaining appropriate business records; and
Protecting our legal and commercial interests.

7.5 Other Lawful Grounds

We may also process personal information where necessary to protect the life, health or property of an individual in an emergency, where information has lawfully been made public, or where another lawful basis is available under applicable legislation.

8. Cookies and Similar Technologies

The Website may use cookies, pixels, tags, local storage, server logs and similar technologies to operate correctly, remember preferences, improve performance, understand Website traffic and protect Website security.

A cookie is a small text file that a website stores on a user’s device. Cookies may be temporary session cookies that expire when a browser is closed or persistent cookies that remain until they expire or are deleted.

8.1 Strictly Necessary Cookies

These cookies support essential Website functions, security, network management, form operation and fraud prevention. The Website may not function correctly without them.

8.2 Functional Cookies

Functional cookies may remember settings such as language, region, display preferences or previous interactions.

8.3 Analytics and Performance Cookies

Analytics technologies may help us understand how visitors use the Website, which pages receive traffic, how users navigate between pages and whether technical errors occur.

8.4 Communication and Chat Technologies

Where the Website provides a chat window, inquiry function or external messaging link, the relevant technology may store identifiers or communication information necessary to provide that feature.

Where required by applicable law, non-essential cookies will be used only after appropriate consent has been obtained. You may manage cookies through an available consent tool or through your browser settings.

Blocking certain cookies may affect the operation or availability of some Website features.

9. Marketing Communications

We may use your business contact information to follow up on an inquiry, provide requested product information, discuss an existing project or communicate about services that are reasonably related to your business interests.

Where applicable law requires consent for direct marketing, we will seek that consent before sending marketing communications.

You may request that we stop sending non-essential marketing communications at any time by:

Using an unsubscribe link included in the communication, where available;
Replying to the communication with an unsubscribe request; or
Emailing [email protected] (Link).

Even after you opt out of marketing communications, we may continue to send necessary service, project, order, legal, security or transaction-related communications.

10. How We Share Personal Information

We do not disclose personal information indiscriminately. We may share information only where reasonably necessary for a legitimate business purpose, contractual performance, legal obligation or another lawful basis.

10.1 Service Providers

We may engage service providers that process information on our behalf, including providers of:

Website hosting and domain services;
Cloud storage;
Email hosting and communication systems;
Website development and maintenance;
Cybersecurity and fraud prevention;
Analytics and performance measurement;
Contact forms and chat functions;
Customer relationship management;
Document storage and collaboration;
Translation and business support;
Accounting and payment processing;
Shipping, freight forwarding and logistics; and
Data backup and disaster recovery.

Service providers are permitted to process personal information only for the agreed purpose and are expected to apply appropriate confidentiality and security safeguards.

10.2 Company Personnel and Affiliates

Personal information may be shared internally with authorized employees, departments or affiliated entities that need the information to respond to an inquiry, evaluate a project, prepare a quotation, manage production, arrange delivery or provide support.

10.3 Commercial and Project Partners

Where necessary for a specific project, we may share limited information with packaging suppliers, testing laboratories, logistics providers, customs agents, product consultants, designers or other parties involved in fulfilling your request.

10.4 Professional Advisers

We may disclose information to lawyers, accountants, auditors, insurers, consultants and other professional advisers where necessary to receive professional services or protect our legal interests.

10.5 Legal and Governmental Disclosures

We may disclose personal information where required or permitted by law, regulation, court order, governmental request, customs requirement, law enforcement request or other legal process.

We may also disclose information where reasonably necessary to:

Protect the rights, property or safety of Neutro or another person;
Investigate fraud, cybersecurity incidents or unlawful conduct;
Enforce our agreements;
Respond to a legal claim; or
Prevent serious harm.

10.6 Business Transfers

If Neutro is involved in a merger, acquisition, restructuring, financing, transfer of business, sale of assets, insolvency or similar transaction, personal information may be disclosed to relevant advisers, potential counterparties and successor organizations.

Any recipient will be expected to continue processing the information in accordance with applicable law and the commitments described in this Privacy Policy, unless you are informed otherwise.

11. Sale and Sharing of Personal Information

Neutro is not a data broker and does not sell personal information for monetary compensation as part of its ordinary business model.

We do not knowingly sell or share the personal information of individuals under the age of 16.

Certain analytics, advertising or embedded technologies, if enabled on the Website, may be treated as a “sale,” “sharing” or targeted advertising activity under some privacy laws even where no money is exchanged.

Where such laws apply, we will provide any legally required notice, consent mechanism or opt-out method. You may also contact us at [email protected] (Link) regarding an applicable opt-out request.

12. International and Cross-Border Data Transfers

Neutro is located in Shenzhen, Guangdong Province, People’s Republic of China and provides products and services to customers around the world.

If you access the Website or contact us from another country, your personal information may be transferred to, stored in or processed in China or another country where our service providers or project partners operate.

The privacy and data protection laws of those countries may differ from the laws of your country of residence.

Where required by applicable law, we will use an appropriate mechanism for cross-border transfers, which may include:

Obtaining separate or explicit consent;
Entering into approved contractual clauses;
Applying data transfer agreements;
Conducting legally required assessments;
Using a recognized certification or transfer mechanism;
Transferring information where necessary to perform a contract; or
Relying on another lawful transfer basis.

We will take reasonable steps to ensure that transferred personal information receives protection consistent with applicable legal requirements.

13. Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by applicable law.

Our general retention approach is as follows:

General inquiries: Generally retained for up to three years after the most recent substantive communication, unless the inquiry develops into a longer commercial relationship.
Customer and project records: Generally retained for the duration of the business relationship and for a reasonable period afterward, which may be up to ten years where required for contractual, tax, accounting, product traceability, quality or legal purposes.
Quotation and sample records: Generally retained for the period necessary to evaluate the project and maintain an appropriate record of the proposal.
Uploaded designs and project materials: Retained for the active project period and for a reasonable period afterward for quality, repeat-order, dispute prevention and recordkeeping purposes.
Marketing contact information: Retained until you unsubscribe, object or the information is no longer reasonably relevant, subject to retention of limited suppression information needed to respect your request.
Website security and technical logs: Generally retained for up to 12 months, unless a longer period is necessary to investigate a security incident or comply with law.
Cookie information: Retained according to the duration of the relevant cookie or until the cookie is deleted.
Legal and dispute records: Retained until the applicable claim, investigation, limitation period or legal proceeding has concluded.

When determining an appropriate retention period, we may consider:

The nature and sensitivity of the information;
The purpose for which it was collected;
The duration of the business relationship;
Product quality and traceability requirements;
Legal and regulatory obligations;
Potential risks from unauthorized use or disclosure;
The applicable limitation period for legal claims; and
Whether the information can be anonymized.

When personal information is no longer required, we will delete it, anonymize it or securely isolate it where immediate deletion is not reasonably possible.

14. Data Security

We use reasonable administrative, technical and organizational safeguards designed to protect personal information from accidental loss, unauthorized access, unlawful use, alteration, disclosure or destruction.

Depending on the nature of the information and processing activity, safeguards may include:

Access controls and user authorization;
Password and account management measures;
Secure hosting and network protections;
Encryption during transmission where appropriate;
Malware and intrusion monitoring;
Regular software maintenance and updates;
Data backup procedures;
Employee confidentiality obligations;
Service provider confidentiality and data protection requirements;
Internal access limitations based on business need; and
Incident response procedures.

No Internet transmission, Website, email system or storage platform can be guaranteed to be completely secure. You should therefore use appropriate care when submitting confidential information online.

You should not send passwords, complete payment credentials, highly sensitive identity documents or confidential formulas through a general contact form or unsecured chat function unless we have specifically provided an appropriate secure method.

15. Personal Information Incidents

If we become aware of a personal information security incident, we will assess the nature and potential impact of the incident and take reasonable measures to contain, investigate and remediate it.

Where required by applicable law, we will notify affected individuals, regulators or other competent authorities within the legally required period.

16. Automated Decision-Making

Neutro does not normally use personal information collected through the Website to make decisions based solely on automated processing that produce legal effects or similarly significant effects on individuals.

We may use automated tools to filter spam, identify security threats, organize inquiries or analyze general Website activity. These activities are intended to support Website operation and business communication rather than make significant decisions about individuals.

17. Your Privacy Rights

Depending on your location and the applicable law, you may have some or all of the following rights:

The right to know whether we process your personal information;
The right to receive information about how your personal information is processed;
The right to request access to personal information we hold about you;
The right to request correction of inaccurate or incomplete information;
The right to request deletion of personal information;
The right to restrict or limit certain processing activities;
The right to object to processing based on legitimate interests;
The right to withdraw consent;
The right to object to direct marketing;
The right to request a portable copy of certain information;
The right to opt out of certain sales, sharing or targeted advertising activities;
The right to request an explanation of certain automated decisions;
The right not to be discriminated against for exercising privacy rights;
The right to authorize another person to submit a request where permitted; and
The right to complain to a competent data protection authority.

These rights are not absolute. A request may be limited or refused where an exception applies, including where processing is necessary to comply with law, perform a contract, protect another person’s rights, establish or defend legal claims, prevent fraud or preserve legally required records.

18. How to Exercise Your Rights

You may submit a privacy request by contacting:

Email: [email protected] (Link)

Contact Page: https://neu-tro.com/contacts-us/ (Link)

Please use the subject line “Privacy Request” and provide enough information for us to understand your request.

Depending on the nature of the request, we may ask you to provide information reasonably necessary to verify your identity and prevent unauthorized disclosure or deletion. We will not request more information than is reasonably necessary for verification.

If you submit a request on behalf of another person, we may require evidence of your authority and may separately verify the identity of the person concerned.

We will respond within the period required by applicable law. Where additional time is legally permitted and reasonably necessary, we will inform you of the extension and the reason for it.

19. Rights Under the Personal Information Protection Law of China

Where the Personal Information Protection Law of the People’s Republic of China applies, individuals may have rights that include:

The right to be informed about personal information processing;
The right to make decisions regarding the processing of personal information;
The right to restrict or refuse processing;
The right to access and copy personal information;
The right to correct or supplement inaccurate or incomplete information;
The right to request deletion in legally specified circumstances;
The right to withdraw consent where processing is based on consent;
The right to request an explanation of personal information processing rules; and
Other rights provided by applicable law.

Where separate consent is required for sensitive personal information, disclosure to another processor, public disclosure or cross-border transfer, we will seek such consent where legally required.

20. Rights for Individuals in the EEA, United Kingdom and Switzerland

If you are located in the European Economic Area, United Kingdom or Switzerland and the relevant data protection law applies to our processing, you may have rights including:

Access to your personal data;
Correction of inaccurate personal data;
Deletion of personal data;
Restriction of processing;
Objection to processing based on legitimate interests;
Objection to direct marketing;
Data portability for certain information;
Withdrawal of consent;
Protection from certain solely automated decisions; and
The right to lodge a complaint with a competent supervisory authority.

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

You may object to direct marketing at any time. Where a valid direct marketing objection is received, we will stop using the relevant personal information for that purpose.

21. California Privacy Notice

This section applies only to California residents and only to the extent that Neutro is subject to the California Consumer Privacy Act, as amended.

21.1 Categories of Personal Information

Depending on your interaction with us, we may collect categories of information that include:

Identifiers, such as name, email address, IP address and telephone number;
Customer and commercial information, such as product interests, quotation requests and transaction records;
Internet or electronic network activity, such as browsing activity and Website interaction information;
Professional or employment-related information, such as company name and business role;
Approximate location information derived from an IP address;
Audio, visual or similar information that you voluntarily upload or provide;
Communication content; and
Inferences reasonably derived from inquiry information, such as likely product or purchasing interests.

21.2 Sources of Information

We may obtain this information directly from you, automatically through Website technologies, from the organization you represent, from service providers, from business partners or from public business sources.

21.3 Business Purposes

We may use this information to respond to inquiries, provide services, prepare quotations, manage projects, maintain security, improve the Website, comply with law and protect our business interests.

21.4 California Rights

Subject to applicable limitations and verification requirements, California residents may have the right to:

Request information about categories and specific pieces of personal information collected;
Request information about the sources, purposes and recipients of personal information;
Request deletion of certain personal information;
Request correction of inaccurate personal information;
Opt out of the sale or sharing of personal information;
Limit certain uses of sensitive personal information; and
Receive equal service and not be discriminated against for exercising privacy rights.

Neutro does not sell personal information for monetary compensation and does not knowingly sell or share the personal information of individuals under 16.

Where applicable law treats certain Website technologies as a sale or sharing activity, you may submit an opt-out request by emailing [email protected] (Link).

22. Other United States Privacy Rights

Residents of certain other United States jurisdictions may have rights similar to the rights described above, including rights to access, correct, delete or obtain a copy of personal information and to opt out of targeted advertising, sale or certain profiling activities.

Where such a law applies to Neutro, you may submit a request using the contact details provided in this Privacy Policy.

If we decline a request and applicable law provides an appeal right, you may appeal by replying to our decision and clearly stating that you wish to appeal it.

23. Global Privacy Control and Do Not Track Signals

Some browsers and browser extensions allow users to send a Global Privacy Control or similar privacy preference signal.

Where applicable law requires us to treat a recognized signal as a valid opt-out request, we will take reasonable steps to honor that signal for the relevant browser or device.

Because there is not yet a universally accepted standard for all “Do Not Track” signals, the Website may not respond to every type of browser-based tracking preference.

24. Children’s Privacy

The Website is intended for businesses, business representatives and adults interested in our products and services. It is not directed to children.

We do not knowingly collect personal information from children under the age of 14 in China or under the minimum age established by applicable law in another jurisdiction without appropriate parental or guardian authorization.

If you believe that a child has provided personal information through the Website without appropriate authorization, please contact [email protected] . We will review the matter and take appropriate action, which may include deleting the information.

25. Third-Party Links and Embedded Content

The Website may contain links to social media services, messaging platforms, map services, logistics providers, external articles or other third-party websites.

The Website may also display embedded content, such as videos, maps, forms or communication tools provided by third parties.

When you interact with a third-party link or embedded service, the third party may collect information according to its own privacy policy and technical practices.

Neutro does not control and is not responsible for the privacy, security or data processing practices of independent third parties. You should review their privacy policies before providing personal information.

26. Social Media and External Messaging Platforms

If you communicate with Neutro through a social media service, WhatsApp or another external messaging platform, your interaction will also be subject to the privacy policy and terms of that platform.

We may receive information including your platform username, profile information, telephone number, message content and attachments, depending on the service and your privacy settings.

27. No User Accounts or Paid Content Subscriptions

The Website does not currently provide user account registration or paid content subscriptions.

Accordingly, we do not collect account login credentials for customer Website accounts or process recurring subscription payments through the Website.

If these features are introduced in the future, this Privacy Policy may be updated to explain the additional information collected and the applicable processing practices.

28. Promotions and Prize Draws

Neutro does not currently conduct Website-based prize draws, contests or promotional sweepstakes.

If such an activity is introduced in the future, separate terms and an appropriate privacy notice may be provided for that activity.

29. Your Responsibilities

When providing personal information to us, you are responsible for ensuring that:

The information is accurate and not misleading;
You are authorized to provide the information;
You do not submit unnecessary sensitive personal information;
You have obtained any required permission from other individuals;
Uploaded files do not contain malicious software;
Uploaded content does not unlawfully infringe another person’s rights; and
You update us if material information becomes inaccurate.

30. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Website, technologies, services, business practices or legal obligations.

When we update the Privacy Policy, we will publish the revised version on the Website and change the “Last Updated” date at the top of the page.

If a change materially affects how we process personal information, we may provide additional notice through the Website, email or another appropriate communication method where required by law.

Your continued interaction with the Website after an updated Privacy Policy becomes effective will be subject to the revised policy. Where consent is legally required for a new processing activity, continued use alone will not replace that consent.

31. Language

This Privacy Policy is written in English. A translation may be provided for convenience.

To the extent permitted by applicable law, the English version will prevail if there is an inconsistency between the English version and a translated version.

32. Contact Us

If you have a question about this Privacy Policy, wish to exercise a privacy right or have a concern about how your personal information is processed, please contact us:

Shenzhen Neutro Technology Co., Ltd.
Room 269I, 2nd Floor, Building 523, Bagualing Industrial Zone, Bagua Third Road, Hualin Community, Yuanling Street, Futian District, Shenzhen, Guangdong Province, China

Email: [email protected]

Contact Page: https://neu-tro.com/contacts-us/

Please include “Privacy Request” in the subject line where possible. We will make reasonable efforts to review and respond to legitimate requests in accordance with applicable law.