Privacy Policy

Last Updated: [2025.11]
Effective Date: [2025.11]

We operates the website Benthree.com (the “Site”) and sells headphones, speakers, smart audio devices, and related consumer electronics (collectively, the “Products”). We are committed to protecting your privacy and handling your personal data transparently and securely. This Privacy Policy explains what information we collect, how we use it, with whom we share it, your rights, and how to contact us.

1. Quick Summary (Plain-English highlights)

We collect information you give us (account, order, payment) and information we obtain automatically (device, usage, cookies).
We use your data to provide products and services, process orders, improve products, prevent fraud, and communicate with you.
We share data with service providers (payment processors, shippers, analytics), affiliates, and when legally required.
If you are an EU/EEA/UK resident, a California resident, or otherwise have data-protection rights, you have specific rights (access, correction, deletion, portability, objection, etc.). See the “Your Rights” section for details and how to exercise them.
We take commercially reasonable measures to protect your data, but no system is 100% secure.
We do not knowingly collect personal information from children under 13. If we discover such data, we will delete it.

2. Scope and Applicability

This Privacy Policy applies to personal data collected through our Site, customer service channels, mobile applications (if any), in-store interactions (if any), and when you interact with our Products that connect to our services (e.g., smart devices, firmware updates, companion apps). It does not apply to data collected by third parties (e.g., social networks, external retailers) except as described below.

3. Definitions

“Personal Data” or “Personal Information”: Any information that identifies or can reasonably be used to identify you.
“Customer Content”: Content captured by your device (for devices that capture audio, voice commands, usage recordings, etc.) that you upload, stream, or otherwise provide. (Only applicable if you purchase a Product that collects such content.)
“Service Providers”: Third-party vendors performing services on our behalf (payments, hosting, shipping, analytics, marketing).

4. Information We Collect

We collect the following categories of information. Where applicable, we also list common examples and purposes.

A. Information You Provide Directly

Account & Contact Information: name, email address, phone number, shipping/billing address, username, password — to create and manage your account, process orders, and communicate.
Order & Transaction Data: order history, purchases, product selections, returns, payment card metadata (we do not store full card numbers; card processing is handled by PCI-compliant processors).
Customer Support Communications: emails, chat transcripts, call recordings (if you contact support and consent to recording) — to respond to inquiries and improve service.
Customer Content: if you use a smart Product that records audio/voice or other media (e.g., a smart speaker), such content may be uploaded or stored if you enable those features. We only process such content consistent with your settings and applicable law.

B. Information Collected Automatically

Usage & Analytics: pages visited, products viewed, clicks, session times, search queries, error logs — for product and Site improvement, analytics, and troubleshooting.
Device & Technical Data: IP address, device model, browser type and version, operating system, unique device identifiers, firmware versions (for connected Products) — used for security, compatibility, and diagnostics.
Location Data: approximate location derived from IP address or precise location if you enable location services on a device or app — used for shipping estimates, product features, and fraud prevention.
Cookies & Tracking: cookies, web beacons, pixel tags, local storage — used to remember preferences, provide core Site functionality, and for analytics and advertising.

C. Information from Third Parties

Payment Processors: confirmation of payment, fraud screening results.
Shipping & Fulfillment Partners: shipping status, tracking numbers.
Public Sources & Partners: contact details or business information purchased or obtained from third-party sources for fraud prevention, identity verification, or marketing (only where permitted).
Social Networks: information you choose to make public via your social account if you connect or sign in via social login.

5. How We Use Your Information (Purposes)

We use collected information for the following principal purposes:

To provide and fulfill orders and Services. Process purchases, payments, shipping, returns, and warranty claims.
To operate and improve Products and Site. Analyze usage trends, fix bugs, optimize features, and perform device diagnostics and firmware updates.
To provide customer support. Respond to inquiries, manage returns, handle complaints, and provide technical assistance.
To communicate. Send transactional messages (order confirmations, shipping info), product updates, security alerts, and, where you consented, marketing communications.
To personalize and recommend. Tailor content, offers, and product recommendations based on your preferences and behavior.
To detect and prevent fraud and misuse. Verify identity, prevent unauthorized transactions, and secure our systems.
To comply with legal obligations. Respond to lawful requests by public authorities and retain records for tax and accounting.
For legitimate business interests. Such as analytics, product development, and maintaining the security and integrity of our services — where those interests are not overridden by your rights.

If we ask for consent for a specific processing activity (e.g., analytics cookies, marketing emails, or audio recording in a device), we will make that clear and provide an opt-in/opt-out mechanism.

6. Legal Basis for Processing (for EU/EEA/UK residents)

When we process personal data of data subjects in the EU/EEA/UK, our legal bases include:

Performance of a contract: processing necessary to fulfill our contract with you (e.g., order fulfillment).
Legal obligation: processing required to comply with law (e.g., tax or customs obligations).
Consent: where you have provided consent (e.g., marketing communications, non-essential cookies).
Legitimate interests: for activities such as fraud prevention, network and information security, product improvement, and certain direct marketing activities — balanced against your rights and freedoms.

7. Sharing and Disclosure

We may disclose personal data to the following categories of recipients:

Service Providers & Subprocessors: payment processors (e.g., Stripe, PayPal), cloud hosts, CRM and ticketing providers, analytics providers, email and SMS delivery services, logistics/shipping partners. They act on our behalf and are contractually limited to processing data for specified purposes.
Affiliates & Subsidiaries: to manage accounts, orders, and services across our corporate group.
Advertising & Marketing Partners: for delivering personalized ads or marketing campaigns (only with lawful basis or your consent).
Law Enforcement, Regulators & Courts: when required by law or to protect rights, property, safety, or in response to legal process.
Mergers & Business Transfers: in connection with a merger, acquisition, reorganization, sale of assets, financing, or bankruptcy — recipient will be required to use personal data in a manner consistent with this policy.
Aggregated or De-identified Data: we may share or publish aggregated or anonymized information that does not identify you.

We require third parties to implement reasonable safeguards and to use your personal data only for the purposes for which we disclose it.

8. International Data Transfers

Because we operate internationally, personal data may be transferred to, stored, and processed in countries other than your country of residence (including the United States, China, EU member states, etc.). Those countries may have different data protection laws. When we transfer personal data abroad, we use appropriate safeguards such as: standard contractual clauses, reliance on adequacy decisions where available, or other lawful transfer mechanisms. If you would like details about the specific transfer mechanism used in your case, please contact us (see “Contact” below).

9. Data Retention

We retain personal data only as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Typical retention periods include:

Order information and transaction records: retained for a period required for tax, accounting, and warranty obligations (commonly 6–10 years depending on jurisdiction).
Account information: kept while your account is active and for a reasonable period after account closure for fraud prevention and legal obligations (commonly 2–7 years).
Support records: retained for as long as necessary to resolve support issues and improve service (commonly 2–5 years).
Log files and analytics data: retained for operational and analytics purposes (commonly 12–36 months unless aggregated/anonymized).
Customer Content: retained according to your account settings and applicable law; you may be able to delete or export such content via your account or device settings.

If you request deletion of your personal data, we will delete it except where we must retain it to comply with legal obligations, resolve disputes, enforce agreements, or for other legitimate business reasons.

10. Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, disclosure, alteration, and destruction. Safeguards include encryption in transit, access controls, network security, data minimization, and regular security assessments. However, no security system is impenetrable. In the event of a data incident, we will follow applicable breach notification laws and take appropriate remedial steps.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Site and enhance your experience. Typical categories:

Essential cookies: necessary for core Site functions (account, checkout).
Performance & analytics cookies: collect aggregate usage information to improve the Site.
Functional cookies: remember preferences and settings.
Advertising/Targeting cookies: used to deliver personalized ads or measure ad performance.

You can manage cookie preferences via our cookie banner (where implemented), the settings in your browser, or opt-out tools provided by third parties (e.g., Google Analytics Opt-Out Browser Add-on). Blocking certain cookies may affect Site functionality.

12. Your Privacy Rights & Choices

A. EU/EEA/UK Residents

You may have the following rights under applicable data protection laws:

Access: request a copy of your personal data.
Rectification: correct inaccurate or incomplete data.
Erasure (“Right to be forgotten”): request deletion where lawful.
Restriction of processing: ask us to limit processing in specific cases.
Data portability: receive your data in a commonly used format.
Object: object to processing based on legitimate interests or direct marketing.
Withdraw consent: where processing is based on consent, you may withdraw it.

We will respond to requests within the timeframe required by law (generally within 1 month), possibly extendable by another month for complex requests. We may request information to verify your identity before fulfilling requests.

B. California Residents (CCPA/CPRA)

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

Right to Know: request categories and specific pieces of personal information we collected, disclosed, or sold about you in the prior 12 months.
Right to Delete: request deletion of personal information we collected from you (subject to exceptions).
Right to Opt-Out: opt out of the “sale” or “sharing” of your personal information for cross-context behavioral advertising.
Right to Correct: request correction of inaccurate personal information.
Right to Non-Discrimination: you have the right not to be discriminated against for exercising privacy rights.

To exercise these rights, submit a request as described below. We will verify your identity before responding and will comply with applicable timelines (generally within 45 days, with a possible 45-day extension for complex requests).

C. Other Jurisdictions

If you live elsewhere, you may have similar rights under local law. Please contact us to learn what rights apply to you.

How to Submit a Request

To exercise any rights, contact us via:

Email: support@benthree.com
Web form: https://benthree.com/privacy
Mail: Benthree.com

Please include sufficient details for us to locate the data and verify your identity. We may request additional information to confirm your identity.

13. Verification Process & Security for Requests

To protect your information and prevent unauthorized access, we will verify your identity before fulfilling your request. Verification may include confirming account details, sending a verification code to a registered email or phone, or requesting government ID for high-risk requests. We will retain the minimum information necessary about the request to comply with legal obligations.

14. Third-Party Links and Embedded Content

Our Site may contain links to third-party sites, embedded content (e.g., videos), or widgets. This Privacy Policy does not apply to those third parties. We encourage you to review third parties’ privacy policies before interacting with them.

15. Children’s Privacy

Our Site and services are not directed to children under the age of 13. We do not knowingly collect or maintain personal information from children under 13. If we become aware that we have inadvertently collected personal information from a child under 13, we will take steps to delete such information as soon as reasonably practicable.

16. Do Not Track

Some browsers transmit “Do Not Track” signals. At present, our Site does not respond to Do Not Track browser settings. For information on controlling tracking and advertising preferences, see the “Cookies and Tracking Technologies” section.

17. Changes to This Privacy Policy

We may modify this Privacy Policy to reflect changes to our practices, legal requirements, or product features. When we make material changes, we will update the “Last Updated” date and, where required by law, provide prominent notice (e.g., email notification to account holders). Your continued use of the Site after the effective date constitutes acceptance of the updated policy.

18. International Users

By using our Site or purchasing Products, you acknowledge that your personal data may be transferred to, stored, and processed in countries other than the country in which you reside (including China, the United States, and others). See “International Data Transfers” above for more information on safeguards.

19. Contact Information

For privacy inquiries, requests, complaints, or to exercise your rights:

Email: support@benthree.com
Mail: support@benthree.com
Data Protection Officer (if applicable): [DPO Name or “Not Appointed”]

If you are an EU/EEA/UK resident, you have the right to lodge a complaint with a supervisory authority in your country.

20. Additional Notices (if applicable)

Payment Card Data: We rely on PCI-compliant third-party payment processors. We do not store full payment card numbers on our servers.
Marketing & Promotional Communications: You may opt out of marketing emails by clicking the “unsubscribe” link in any promotional email or by changing your communication preferences in your account. Transactional messages (order confirmations, shipping notices, security alerts) are not removable unless required by law.
Firmware, Device Data & Cloud Features: For connected Products, device telemetry, firmware version info, and crash logs may be transmitted to our servers to enable updates and diagnostics. If your Product offers cloud features (storage of audio clips, voice recordings, or device videos), those features and the associated data retention and sharing practices are governed by your device settings and this Privacy Policy. We will request explicit consent for any cloud or audio recording features where required by law.

Final Note

This Privacy Policy is a template and starting point intended to be comprehensive and consistent with the structure and breadth commonly used by smart device companies (e.g., Ring). It does not constitute legal advice. We recommend you (or your legal counsel) review and adapt this policy to reflect your actual data flows, service providers, local legal requirements (GDPR, UK GDPR, CCPA/CPRA, China’s Personal Information Protection Law, etc.), and any device-specific data processing.

Benthree