Last Updated: October 30th, 2023 

MGI-Tech GmbH and other European companies controlled by MGI Tech Co., Ltd. (hereafter collectively referred to as “MGI”, “we”, or “us”) are committed to protecting your privacy. When you are using our product and/or services, we may collect and use your relevant personal data. As a global enterprise, we will adopt corresponding safeguard measures according to applicable laws and regulations with our best efforts to keep your personal data safe and under control. 

This Privacy Policy (hereafter referred to as “this Policy”) applies when you use our website (e.g., https://mgi-tech.eu/, hereafter referred to as “Website”), or when you interact with us, we collect your personal data via online channel (all kinds of channels including our website, Linkedin,  Facebook and other platforms) or offline channel (all scenarios including exhibition, meeting, training, visits, and phone call). We may also provide you with separate privacy policy or statement to inform you about how we collect and process your personal data under certain specific circumstances (e.g., when we provide specific products or services). If any conflicts or discrepancies incur between those separate privacy policies or statements with this Policy, in principle, those separate privacy policies or statements will prevail, unless otherwise stated or agreed.  

Please take time to read this Privacy Policy carefully to ensure that you fully understand and agree to this Privacy Policy before using this Website or interacting with us. If you are re-directed to this Website from a third-party website or you visit third-party websites through this Website and accept services provided by them, we are not responsible for the commitments offered by privacy policies from third-party websites. Please note that, we do not have control over the product or services offered by third parties or personal data processed by them. This Policy does not apply to the personal data protection issues arising from the products or services provided by third parties, nor apply to any personal data that you voluntarily provide to third parties, so we suggest you to read the privacy policy of third parties or contact that third party to get details regarding their privacy policy. If you find any risks from third-party developed websites or applications, we suggest you to cease from taking related actions to protect your legitimate rights and interests. 

I.  How we collect and process your personal data

1  Definition 

In this Policy, “personal data” refers to various information related to an identified or identifiable natural person, excluding anonymized information.  “Sensitive personal data” refers to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership genetic data, biometric data uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation. 

2  How we collect your personal data 

1) Information that you proactively provide to us 

· Contact information: If you need to consult us regarding MGI product or service, get to know about potential opportunities for business cooperation, purchase and receive MGI products and after-sales services, provide feedback to our product, service, performance of order or problems in the cooperation, join online or offline seminar, exhibition, forum, competition and other marketing or promotional activities, visit our offices, and interact with MGI by other means, we may require you to provide your personal data and the information of your company (such as your name, title, email address, phone or cellphone number, address, company, object of interest and content of your interactions with or messages to us) for us to confirm your identity, provide your required service and information, handle your feedback, or respond to your request appropriately by other means.  

· Payment information: In connection with the transaction, you may also need to provide us with your payment information, such as bank account number and related verification data. 

· Employment application information: If you look for job opportunities from us, you may provide your contact information, the curriculum vitae or other information for application.    

2) Information that automatically collected when you use our Website or other services 

In order to fulfill our cybersecurity related legal obligations and to enhance your user experience and security when using our products or services, we may automatically collect data such as your device type, IP address and browsing history on our Website when you use the Website and other services. 

3) Information collected from third-party partners of MGI 

Where permitted by applicable law, we may obtain personal data generated or shared by you from third parties or public sources in connection with your use of third-party partner services. For example, you may authorize a third-party account to login and use our service, or authorize to import your account, nickname or other information from third-party platform. We will use your personal data in accordance with our agreement with the third party and subject to relevant laws and regulations. 

3  How we process your personal data 

1) Our purposes of processing your personal data and the legal basis for such processing: 

· To enable you or your company to use the online and offline services we provide from time to time, e.g., providing news on your interested products, based on the consent provided by you; 

· To respond to your or your company's needs or enquiries, where such processing is necessary to protect your interest; 

· To contact you about products, services or events that may be of interest to you or your company and to obtain feedback from you or your company, based on the consent provided by you; 

· To create and update account, order, and transaction information for you or your company where such processing is necessary to execute a contract between you or your company; 

· To communicate and sign contracts with you or your company where such processing is necessary to execute a contract between you or your company; 

· To fulfil contractual obligations to you or your company where such processing is necessary to execute a contract between you or your company; 

· To provide the requested services, information or product support where such processing is necessary to execute a contract between you or your company; 

· To comply with applicable statutory obligations where such processing is necessary for our compliance with relevant legal obligations; 

· To conduct financial and other necessary compliance reviews where such processing is necessary for our compliance with relevant legal obligations; 

· For analytical activities to improve the quality of our products and services, based on the consent provided by you; 

· For handling and responding to complaints, where such processing is necessary to protect your interest; 

· For recording our products or services, where such processing is necessary to execute a contract between you or your company and comply with relevant legal obligations;  

· For managing our Website where such processing is necessary for our compliance with relevant legal obligations; 

· For human resource management where such processing is necessary for our compliance with relevant legal obligations. 

2) Communication for Promotion 

We may use your email, transaction history, products of interest and other information to promote our newsletters, products or services to you. If you do not wish to receive promotions from us, or other emails not related to information necessary for your transaction such as your order, account, billing, etc., you may opt out of receiving such messages without any negative impact on your relationship with MGI by following the opt-out method provided in the email. In addition, we reserve the right to contact you if necessary, including in the case of legal requests, order tracking, billing updates, service-related account creation, product upgrade changes, product recalls, etc. 

3) You acknowledge and agree in the following situations we do not need to obtain your consent to process your personal data: 

·Where it is necessary to respond to a public health emergency, or in an emergency, to protect your life, health and property and that of other people; 

·Where it is necessary for the performance of our statutory duties or obligations; 

·When we conduct news reports, public opinion supervision and other acts for the public interest, and process personal data within a reasonable scope; 

·When we process personal data that you have disclosed or that has been legally disclosed within a reasonable range in accordance with applicable laws; 

·Where it is necessary to enter into and perform a contract to which you are a party; 

·In other circumstances as stipulated by applicable laws or administrative regulations. 

II.  How we share, transfer and publicly disclose your personal data 

MGI will not share, transfer, or publicly disclose your personal data to other third parties except as described in this Policy.  

1  Share 

To ensure the stable operation of our products or services, to ensure your user experience, and for other lawful and reasonable purposes, we may share your personal data with third parties in certain circumstances, and we will require such third parties to process your personal data in accordance with applicable legal requirements: 

· If you have requested it by yourself;

· Where your express consent has been obtained in advance;

· For potential business cooperation, enquiries about products and services or matters relating to product orders, payments, training, maintenance, etc., which you have requested, we may not be able to complete alone. To respond to your request, we may need to share your personal data with our affiliated companies or suppliers (such as after-sales service providers, logistics companies, etc.) that supporting our business;

·We may share the personal data you provide when participating in our marketing or promotional activities to event partners such as joint-organizers, co-organizers, sponsors, etc.;

·We may share your personal data with internet service providers in order to maintain and manage our Website and other media, to enhance your user experience and to perform our network security and safety obligations;

· We may share your personal data with external auditors, legal advisors, insurance companies and banks to meet regulatory requirements and secure transactions;

·In order to complete our cooperation with you or your company, and to achieve unified management of the MGI Group, your personal data may be shared between MGI and its wholly-owned and controlled subsidiaries;

·In order to respond to your job applications, we may need to forward your submitted CV to our affiliated companies, background check companies and recruitment service providers for screening and assessment;

·We may share your personal data as required by applicable law, or as requested by administrative, judicial or other regulatory authorities, and as necessary to fulfill other legal obligations. 

If you do not want us to share your personal data with third parties, you may contact us through the ways set out in section IX of this Policy, but this may affect the services you receive from us. 

2  Transfer 

We will not transfer your personal data to any company, organization or individual, except in the following circumstances: 

·If you have requested it by yourself; 

·Where your express consent has been obtained in advance; 

·If, as our business develops, we need to transfer personal data as a result of a merger, separation, dissolution or declaration of bankruptcy, we will inform you of the name and contact details of the recipient. The recipient shall continue to protect your personal data in accordance with the applicable legal provisions. 

3  Disclose publicly

We will only disclose your personal data publicly in the following circumstances: 

·If you have requested by it yourself; 

·Where your separate consent has been obtained in advance; 

·Where required by applicable law or in response to legal procedure, we may publicly disclose your personal data to the relevant regulatory authorities. 

III. How we use cookies and related technologies  

In order to ensure that our Website works properly and efficiently, to make your visit easier and to provide you with content that may be of interest to you, we use cookies (a small text file) to provide you with a more personalized user experience and service. For example, in the case of your use of the Website service, when you visit the Website for the first time, we store it on the device from which you visit the Website (where your browser allows it). When you visit the Website again, the Website will learn your relevant preferences (such as the language, font size and other browsing preferences of your computer or mobile device) by reading the cookies. The cookies we use include the following: 

1  Strictly necessary cookies 

These cookies are necessary for the operation of this Website and are used to perform the basic functions of the Website. The strictly necessary cookies do not require your consent and therefore they are not the optional cookies. The list of the strictly necessary cookies we use is as follows: