Privacy Policy

Nocpix Membership

Effective Date: September 2026

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Part I – General Privacy Policy

1. Introduction

This Privacy Policy explains how Inlumen Technologies Co., Ltd. ("Company", "we", "us" or "our") collects, uses, stores, shares and protects personal data when you access or use the NOCPIX MEMBERSHIP platform, including the points mall, coupon redemption system, and related services (collectively, the "Service"), whether through our website, mobile interfaces, or other digital channels associated with Nocpix (the "Platform").

Our Service is designed to allow registered users to earn points through various activities (including account registration, daily check-in, product registration, social media engagement, event participation, and product purchases), redeem points for brand merchandise, product accessories, and virtual rewards such as discount coupons, and use coupons for online or in-store purchases. The Service also supports coupon issuance and redemption at authorized Nocpix retail partners.

By accessing, registering for, or using our Service, you acknowledge that your personal data will be processed as described in this Privacy Policy. If you are located in the European Economic Area, the United Kingdom, the United States, or Canada, the applicable provisions set out in Part II – Supplemental Terms: Jurisdiction-Specific Addenda will also apply to you.

2. Data Controller

For the purposes of applicable data protection laws, the data controller responsible for processing your personal data is:

Inlumen Technologies Co., Ltd.

Email: members@nocpix.com

If you have any questions regarding this Privacy Policy or our data practices, you may contact us using the details above.

3. Personal Data We Collect

We collect personal data in several ways when you interact with our Service.

3.1 User Account Registration and Login

When you register for a user account on the Platform, we collect the following information:

· Email address (used as your account identifier and for communication)

· Password (stored in encrypted form using industry-standard hashing)

· Nickname or display name

· Country or region

· Device information (device type, operating system, browser type) for security and service optimization

You may also register or log in using third-party authentication services, including Google and Facebook. When you choose to log in via these services, we receive basic profile information from the respective provider (such as your name, email address, and profile picture) in accordance with the provider's privacy settings and your authorization. You may disconnect your third-party account at any time through your account settings.

Each email address and each third-party account may only be associated with one NOCPIX MEMBERSHIP account.

3.2 Profile Completion

When you complete your user profile to earn points, we may collect additional information you voluntarily provide, including:

· Name

· Country/region

· Device information (e.g., Nocpix products you own)

3.3 Product Registration (SN Code Binding)

When you register your Nocpix product by entering the serial number (SN code) to earn points, we collect:

· Product model selected by you

· Product serial number (SN code)

· Purchase date and purchase country (where applicable)

· Proof of purchase (uploaded receipt or order confirmation, for brand-day purchase bonus points)

SN codes are validated against our product database. Each SN code may only be bound to one account. Once bound, an SN code cannot be used to earn points again. Internal test devices are excluded from the points program.

3.4 Points Earning Activities

When you participate in points-earning activities, we collect data related to your participation:

· Daily check-in records (dates and consecutive check-in streaks)

· Social media engagement (confirmation that you follow Nocpix on specified platforms; we do not collect content from your social media accounts)

· User-Generated Content (UGC) – when you submit original content (photos, videos, unboxing reviews, hunting stories, etc.) with designated campaign hashtags, we collect the content URL, platform, and submission date. All UGC is subject to manual review to ensure it is original, Nocpix-related, publicly accessible, and contains the required campaign tags.

· Survey and feedback responses submitted through in-platform forms or linked questionnaires

· Event participation records, including:

· Global map interaction (location markers you place)

· Share actions and generated share links

· Brand corner page views (with minimum dwell time verification)

· Video views (with minimum watch duration verification)

· Online-to-offline experience booking

· Referral information – when you invite friends to join, we track the referral link and the referred friend's registration and email verification status. Referred users must complete registration, email verification, first login, and device binding for the referral to be valid. Each user may invite a maximum of 10 friends per month.

3.5 Points Redemption – Physical Merchandise

When you redeem points for physical merchandise (brand merchandise, product accessories, etc.), we collect:

· Shipping address, including recipient name, street address, city, postal code, country, and contact phone number

· Redemption order details (items redeemed, points deducted, order date)

· Logistics and tracking information (to enable you to track your shipment)

Your shipping information is used solely for order fulfillment and delivery.

3.6 Points Redemption – Virtual Rewards and Coupons

When you redeem points for virtual rewards (such as cash vouchers or discount coupons), we collect and generate:

· Coupon codes (system-generated unique alphanumeric codes)

· QR codes associated with each coupon

· Coupon type, value, and validity period

· Redemption date and usage status (unused, used, expired)

· For in-store redemptions: redemption store location, redemption date and time, and the sub-account that processed the redemption

Coupons obtained through points redemption are automatically deposited into your "My Coupons" section. Coupons issued through marketing campaigns may be distributed via email or other channels.

3.7 Coupon Redemption at Retail Partners

When you redeem a coupon at an authorized Nocpix retail partner (offline store), the following data is processed:

· Coupon code and QR code verification

· Redemption timestamp

· Store identifier and sub-account (each sub-account is uniquely bound to a specific store and cannot process cross-store redemptions)

· Associated product purchase information (where applicable, such as SN code-linked verification)

This data is synchronized between the store terminal and our central management system for reconciliation, commission settlement, and fraud prevention.

3.8 Contact and Customer Support

If you contact us for support, inquiries, or feedback regarding the Service, we collect the information you provide, such as your name, email address, and the content of your communication.

3.9 Information Collected Automatically

When you access or use the Service, certain information is automatically collected, including:

· IP address (used for approximate geolocation, security, and fraud detection)

· Browser type and version

· Device type, unique device identifiers, and operating system

· Pages visited, features used, links clicked, and time spent

· Referring and exit pages/URLs

· Language preferences

· Approximate geolocation derived from IP address (used to display relevant store locations, region-specific content, and appropriate language versions)

This information is collected through cookies, server logs, and similar technologies. For more information, see Section 6 (Cookies and Analytics).

3.10 Fraud Prevention and Security Monitoring

To protect the integrity of the points system and prevent abuse, we monitor and may flag:

· Registrations from the same IP address or device in a short time period

· Multiple accounts bound to the same device

· Abnormal points earnings (e.g., exceeding 5,000 points per day or 10,000 points per week)

· Abnormal referral growth patterns

· Suspicious content submissions

· Repeated share-button clicks, page-refresh reward claims, or scripted sharing behavior

When anomalous activity is detected, the associated account may be placed under manual review, during which points may be frozen and redemption privileges suspended pending investigation.

4. How We Use Personal Data

We may use personal data collected through the Service for the following purposes:

· Account management: To authenticate your identity, create and manage your account, and provide access to Service features.

· Points program administration: To track points earned and redeemed, process point accrual from eligible activities, verify task completion (including manual review of UGC and purchase verifications), and maintain points transaction history.

· Order fulfillment: To process physical merchandise redemptions, provide tracking information, and deliver virtual rewards and coupons to your account.

· Coupon lifecycle management: To issue, validate, and track coupon usage; facilitate in-store redemption at authorized retail partners; reconcile redemptions; and prevent duplicate or fraudulent use.

· Customer support: To respond to your inquiries, resolve issues, and provide assistance with the Service.

· Service improvement and analytics: To analyze usage patterns, understand user behavior, improve platform functionality, optimize the points and rewards structure, and enhance user experience.

· Marketing communications: To send you updates about Nocpix products, events, promotions, and the Nocpix Day anniversary campaign, where you have opted in to receive such communications. You may unsubscribe at any time.

· Security and fraud prevention: To detect, prevent, and address fraud, unauthorized access, abuse of the points system, violations of our terms, and other harmful or illegal activities; to enforce anti-fraud rules including registration limits, SN code uniqueness, and behavioral anomaly detection.

· Legal compliance: To comply with applicable legal obligations, including responding to lawful requests from courts, law enforcement, or regulatory authorities.

· Multi-language support: To provide the Service in your preferred language based on your region or selection (supported languages include English, German, Italian, French, Spanish, and others).

5. Legal Bases for Processing

Where required by applicable data protection laws, we rely on one or more of the following legal bases to process your personal data:

· Consent: Where you have given consent, for example, when you opt in to marketing communications, submit UGC, or agree to the use of certain cookies. You may withdraw your consent at any time.

· Contract performance: Where processing is necessary to perform the services you have requested, such as administering your points account, processing redemptions, shipping merchandise, issuing and validating coupons, and providing customer support.

· Legitimate interests: Where processing is necessary for our legitimate business interests, including:

· Improving and optimizing the Service and user experience

· Analyzing usage patterns and platform performance

· Maintaining the security and integrity of the platform

· Detecting and preventing fraud, abuse, and unauthorized activities

· Protecting our rights and those of our users and partners

  We ensure that our legitimate interests do not override your fundamental rights and freedoms.

· Legal obligation: Where processing is necessary to comply with applicable laws, regulations, court orders, or legal requests.

We do not use automated decision-making, including profiling, that produces legal or similarly significant effects on you. Points anomalies flagged by automated systems are subject to human review before any action is taken.

6. Cookies and Analytics

Our Service uses cookies and similar technologies to enhance user experience, maintain session state, remember preferences, and collect information about how visitors interact with the Platform.

Cookies are small text files placed on your device when you visit a website. They enable the Platform to recognize your device and store certain information about your preferences or actions over time.

We use cookies and similar technologies for the following purposes:

· Strictly necessary cookies: Required for core platform functionality, such as user authentication, session management, security, points transaction processing, and shopping cart/checkout functions for redemptions. These cookies are essential for the Service to function properly.

· Functional cookies: Remember your preferences, such as language selection, country/region, and display settings, to provide a more personalized experience.

· Analytics and performance cookies: Collect anonymous or aggregated information about how users interact with the Platform, including pages visited, time spent, navigation paths, and features used, so that we can improve performance, usability, and the relevance of rewards and activities.

· Advertising and marketing cookies: Where permitted by applicable law, used to deliver relevant content and advertisements, measure campaign effectiveness, and support marketing activities. These cookies may track your browsing behavior across websites and services.

Cookies may be either session cookies (which expire when you close your browser) or persistent cookies (which remain on your device for a set period or until deleted).

You can control or manage cookies in several ways:

· By adjusting your browser settings to refuse or delete cookies;

· Where applicable, by using cookie consent or preference management tools made available on the Platform;

· By using opt-out mechanisms provided by certain third-party providers.

Please note that disabling certain types of cookies may affect the functionality and performance of the Service, and some features (such as staying logged in, maintaining your points session, or completing a redemption) may not be available.

We may use third-party analytics services (such as Google Analytics or similar providers) to help us understand usage of the Service. These providers may set their own cookies and collect information such as IP address, browser type, and usage data. For more information about how these providers process data, please refer to their respective privacy policies.

7. Sharing of Personal Data

We do not sell personal data collected through the Service.

We may share personal data with the following categories of recipients, where necessary to operate the Service and provide related services:

· Service providers and vendors: Companies that provide services on our behalf, including:

· Cloud hosting and infrastructure providers

· Payment and transaction processors (where applicable)

· Shipping and logistics partners (for physical merchandise delivery from China)

· Email and communication service providers

· Analytics and performance monitoring providers

· Customer support platform providers

· Security and fraud detection service providers

  These service providers are authorized to process personal data only as necessary to provide services to us and are required by contract to protect the confidentiality and security of such information.

· Authorized retail partners: When you redeem a coupon at an authorized Nocpix offline store, we share the minimum necessary coupon information (coupon code, validity, and associated terms) with that specific retail partner to verify and process the redemption. Each store sub-account is uniquely bound and can only access redemptions processed at its own location.

· Marketing and advertising partners: In certain circumstances, we may share limited, de-identified or aggregated data with advertising and marketing partners (for example, to measure campaign effectiveness or deliver relevant content), subject to applicable legal requirements. Where required by law, you will be provided with appropriate choices, including the right to opt out of such sharing.

· Legal and regulatory authorities: We may disclose personal data where required by applicable law, court order, subpoena, warrant, or legal process, or where we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

· Corporate transactions: In the event of a merger, acquisition, reorganization, sale of assets, or similar transaction, personal data may be transferred as part of that transaction, subject to appropriate confidentiality and data protection measures.

8. International Data Transfers

We operate our business globally and may transfer, store, and process your personal data outside of your country, state, or region of residence, including in China where our company is based and where physical merchandise is shipped from. As a result, your personal data may be subject to the laws of those jurisdictions, which may differ from the laws of your home country.

Where personal data is transferred internationally, we take appropriate measures to ensure such transfers comply with applicable data protection laws. In particular:

· Transfers to jurisdictions recognized as providing an adequate level of data protection are made in reliance on such adequacy decisions;

· Where personal data is transferred to countries not subject to an adequacy decision, we implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) or equivalent legal mechanisms;

· We require our service providers to implement appropriate technical and organizational measures to protect personal data and to process it only in accordance with our instructions.

Please note that in certain circumstances, personal data may be disclosed to courts, law enforcement authorities, or regulators in jurisdictions where data is processed, where such disclosure is required by applicable law or legal process.

We take reasonable steps to ensure that your personal data remains protected in accordance with this Privacy Policy and applicable legal requirements when transferred internationally.

9. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including administering the points program, providing the Service, performing contracts, complying with legal obligations, resolving disputes, and enforcing our agreements.

Where specific retention periods are not explicitly defined, the duration of storage is determined based on the following criteria:

· The duration of your account: Account information, points history, and redemption records are retained for as long as your account remains active, and for a reasonable period thereafter to handle any follow-up inquiries, disputes, or legal requirements.

· Contractual and transactional necessity: Order and shipping information is retained for the period necessary to fulfill orders, handle returns or issues, and comply with commercial and tax record-keeping obligations.

· Coupon records: Coupon issuance and redemption records are retained for the period necessary to validate usage, process partner reconciliation, and prevent fraud.

· Marketing preferences: Email addresses used for marketing communications are retained until you unsubscribe or request deletion.

· UGC submissions: Content submitted for points is retained for the period necessary to review, verify, and award points, and for a reasonable period thereafter for audit and dispute resolution.

· Security and fraud logs: IP addresses, device identifiers, and security-related logs are retained for a period necessary to detect and prevent fraud and abuse, and to maintain platform security.

· Applicable statutory retention obligations: Including those under commercial, tax, or consumer protection laws.

· Limitation periods for legal claims: In individual cases, storage may extend beyond the original purpose where required for the establishment, exercise, or defense of legal claims.

Where we use service providers, personal data may also be processed and stored by such providers in accordance with their own retention practices. These providers act on our behalf and are contractually required to process personal data only as necessary and in compliance with applicable data protection laws. We take reasonable steps to ensure that personal data is not retained longer than necessary.

10. Your Privacy Rights

Depending on your location and applicable laws, you may have certain rights regarding your personal data. These rights may include:

· Right of access: Request access to the personal data we hold about you.

· Right to rectification: Request correction of inaccurate or incomplete personal data.

· Right to erasure ("right to be forgotten"): Request deletion of your personal data, subject to certain exceptions.

· Right to restriction: Request restriction of processing of your personal data under certain circumstances.

· Right to data portability: Request receipt of your personal data in a structured, commonly used, machine-readable format, or transmission to another controller.

· Right to object: Object to processing based on our legitimate interests, or to processing for direct marketing purposes.

· Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

· Right to lodge a complaint: You may have the right to lodge a complaint with a supervisory authority in your country of residence.

If you wish to exercise any of these rights, you may contact us at members@nocpix.com. We will respond to such requests in accordance with applicable laws, typically within 30 days. Where required, we will take steps to verify your identity before processing your request. You may also designate an authorized agent to submit requests on your behalf, subject to applicable verification requirements.

Please note that if you request deletion of your account, you will lose access to your points balance, redemption history, and active coupons, and any unredeemed points or unused coupons will be forfeited.

11. Data Security

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. These measures include:

· Encryption of passwords using industry-standard hashing algorithms

· Encrypted data transmission (HTTPS/TLS)

· Access controls and authentication requirements for administrative systems

· Regular security assessments and monitoring

· Fraud detection and anomaly monitoring systems

· Employee training on data protection and security practices

While we strive to protect personal data, no method of transmission over the Internet or method of electronic storage can be guaranteed to be completely secure. We encourage you to use a strong password and to keep your account credentials confidential.

12. Children's Privacy

Our Service is not directed to children under the age of 16, and we do not knowingly collect personal data from individuals under 16. If we become aware that personal data from a child under 16 has been collected without appropriate parental consent, we will take reasonable steps to delete such information. If you believe we may have collected information from a child under 16, please contact us at members@nocpix.com.

13. Third-Party Links and Services

The Service may contain links to third-party websites, social media platforms, or services that are not operated by us (including Facebook, Google, YouTube, Instagram, and other social media platforms for UGC submission or following). We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access through or in connection with the Service.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we update the policy, the revised version will be posted on this page with an updated effective date. We encourage you to review this Privacy Policy periodically. Your continued use of the Service after changes become effective constitutes your acknowledgment of the updated policy.

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Part II – Supplemental Terms: Jurisdiction-Specific Addenda

The following terms supplement the General Privacy Policy above and apply only to individuals located in the specified jurisdictions.

1. European Economic Area (EEA)

If you are located in the European Economic Area, you have the following additional rights under the General Data Protection Regulation (GDPR):

· The right to request access to, rectification, or erasure of your personal data;

· The right to request restriction of processing, or to object to processing;

· The right to data portability;

· The right to withdraw consent at any time (without affecting the lawfulness of processing prior to withdrawal);

· The right to lodge a complaint with your local data protection authority (the lead supervisory authority for EU-related matters depends on your country of residence).

International transfers of your data outside the EEA are made pursuant to appropriate safeguards, including Standard Contractual Clauses where applicable.

2. United Kingdom

If you are located in the United Kingdom, your personal data is protected under the UK GDPR and the Data Protection Act 2018. You have rights similar to those described above, including the right to access, rectify, erase, restrict, or object to processing of your personal data, as well as the right to data portability. You may also lodge a complaint with the Information Commissioner's Office (ICO) if you believe your data protection rights have been infringed.

3. United States

If you are a resident of certain U.S. states, you may have additional privacy rights under applicable state privacy laws (such as the California Consumer Privacy Act/CPRA, Virginia CDPA, Colorado CPA, Connecticut CTDPA, and others). These rights may include the right to request information about the personal data collected about you, the right to request deletion, the right to request correction, the right to opt out of certain processing, and the right not to be discriminated against for exercising your privacy rights.

California Privacy Rights (CCPA/CPRA)

This section applies solely to residents of the State of California and supplements the information contained in this Privacy Policy. It is intended to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the "CCPA").

(1) Categories of Personal Information Collected

In the preceding twelve (12) months, we may have collected the following categories of personal information:

Category

Examples

Identifiers

Name, email address, postal address, phone number, IP address, device identifiers, third-party account IDs (Google/Facebook)

Customer records information

Contact details, account credentials (encrypted), profile information (nickname, avatar, country)

Commercial information

Points balance and transaction history, redemption records, coupons issued and used, product registrations (SN codes, models), purchase records

Internet or other electronic network activity information

Browsing history, pages visited, features used, interactions with the Service, device and browser information, referring/exit pages

Geolocation data

Approximate location derived from IP address; country/region from profile; shipping destination for physical rewards

Audio/electronic/visual content

UGC submissions (photos, videos, review links), profile avatars

Inferences

Preferences, activity patterns, reward interests inferred from platform usage

We collect this information directly from you, automatically through your use of the Service, from third-party authentication providers (Google/Facebook), and from service providers.

(2) Purposes for Collection and Use

We collect and use personal information for the following business and commercial purposes:

· Operating and maintaining the Service and the NOCPIX MEMBERSHIP PROGRAM

· Administering points earning, tracking, and redemption

· Processing and shipping merchandise orders

· Issuing and validating coupons, including in-store redemption at retail partners

· Providing customer support and responding to inquiries

· Communicating with you, including marketing communications where you have opted in

· Improving user experience, platform functionality, and reward offerings

· Analyzing usage and trends

· Ensuring security, preventing fraud, and enforcing program rules

· Complying with legal obligations

(3) Disclosure of Personal Information

We may disclose personal information to the following categories of third parties for business purposes:

· Service providers (hosting, analytics, shipping, email, security, customer support)

· Authorized retail partners (for coupon redemption verification)

· Marketing and analytics partners (where permitted)

· Legal or regulatory authorities where required by law

(4) Sale or Sharing of Personal Information

We do not sell personal information in the traditional sense. However, we may "share" certain personal information (as defined under the CCPA) with advertising or analytics partners through the use of cookies and similar technologies for purposes such as improving our services and delivering relevant content. You have the right to opt out of such sharing.

(5) Retention of Personal Information

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine retention periods include the nature of the data, the purposes of processing, applicable legal obligations, and fraud prevention needs. For specific retention details, see Section 9 (Data Retention).

(6) Your Rights Under the CCPA

If you are a California resident, you have the following rights:

· Right to Know: Request information about the personal information we collect, use, disclose, or share, including the categories and specific pieces of personal information.

· Right to Delete: Request deletion of your personal information, subject to certain exceptions (e.g., where we need the data to complete a transaction, comply with law, or detect fraud).

· Right to Correct: Request correction of inaccurate personal information.

· Right to Opt-Out of Sale/Sharing: Opt out of the sale or sharing of your personal information.

· Right to Limit Use of Sensitive Personal Information (if applicable).

· Right to Non-Discrimination: You will not be discriminated against for exercising your rights under the CCPA.

(7) How to Exercise Your Rights

You may exercise your rights by contacting us at members@nocpix.com. Where required, we will take steps to verify your identity before processing your request. You may also designate an authorized agent to submit requests on your behalf, subject to applicable verification requirements.

4. Canada

If you are located in Canada, your personal data is protected under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws. You may request access to or correction of personal data held by us, and may withdraw consent for processing where applicable, subject to legal and contractual restrictions. You may contact us with questions or concerns about how we handle your personal data at members@nocpix.com. You also have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada.

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This Privacy Policy was last updated in August 2026, in connection with the launch of the NOCPIX MEMBERSHIP PROGRAM for the Nocpix Day anniversary celebration.

LAST UPDATED: 2026-06-01

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