Privacy Policy Statement on the Use of this Website

Last Updated: August 12, 2026

Midooc Group Limited (“Midooc,” “we,” “us,” or “our”) is a company incorporated in Hong Kong. Midooc is the controller responsible for the personal information described in this Privacy Policy and, for the purposes of the Hong Kong Personal Data (Privacy) Ordinance, the relevant data user. Midooc’s registered office is located at RM 1801, Easey Commercial Building, 253-261 Hennessy Road, Wan Chai, Hong Kong. This Privacy Policy explains how information is collected, used, disclosed, retained, and protected when you visit www.midooc.com (the “Website”).

Our Chief Privacy Officer is based in Guangzhou, Mainland China and handles privacy compliance, inquiries, complaints, and applicable privacy-rights requests on behalf of Midooc. The Chief Privacy Officer does not act as a separate data controller.

The Website does not currently provide user accounts, online ordering, or newsletter registration. The Website provides a contact form through which you may voluntarily submit your first name, last name, email address, inquiry subject, message, and any other information you choose to include. Fields marked with an asterisk are required to submit the form. If you do not provide the required information, you will be unable to submit the form and we may be unable to respond to your inquiry.

The only non-essential analytics service that Midooc currently uses to measure Website usage is Google Analytics 4 (“GA4”), as described below. If you submit the Website contact form or contact us directly by email, we use the information you provide only to respond to your inquiry, provide the requested product, quotation, customization, technical, or project support, maintain appropriate business records, resolve disputes, protect our legal rights, and comply with applicable law.

This Privacy Policy applies only to this Website, information submitted through its contact form, and communications voluntarily initiated through the contact details displayed on the Website. It does not apply to third-party websites or services linked from the Website.

Collection, Use, and Disclosure of Information

1. Google Analytics Information

Subject to your cookie choices and applicable law, we use GA4 to understand how visitors use the Website and to improve its performance, structure, and content.

GA4 may collect information such as:

● the number of users and session statistics;

● a client or cookie identifier;

● pages visited and interaction events;

● referring pages or websites;

● browser and device information;

● approximate geographic information; and

● the date, time, and duration of a visit.

Google states that GA4 may process an Internet Protocol (“IP”) address during data collection to determine approximate geographic information, but does not log or store the IP address in Google Analytics.

Under Google’s default GA4 web implementation, a client ID may be stored in a first-party cookie named _ga to distinguish users and sessions when analytics storage is enabled. Where enabled in our GA4 property, enhanced measurement may also record page views, scroll activity, outbound clicks, site searches, video engagement, file downloads, and form interaction events.

We do not intentionally send names, email addresses, telephone numbers, communication content, or other directly identifying customer information to Google Analytics.

2. Essential Technical Information and Website Technologies

When you visit the Website, our hosting provider and the technologies used to build, deliver, maintain, and protect the Website may automatically process limited technical information. These technologies may include WordPress, website themes and plugins, security and performance tools, content delivery services, and embedded content where enabled.

The technical information processed may include an IP address, browser and device information, operating system, requested page or URL, referring page, date and time of access, response status, and information necessary to diagnose errors or protect the Website.

These technologies may use cookies, local storage, server logs, or similar mechanisms to deliver Website content, preserve user preferences, maintain security, prevent misuse, balance traffic, diagnose technical problems, and maintain Website availability.

We do not use essential technical information for targeted advertising, unrelated marketing, or independent behavioural profiling.

3. Information You Voluntarily Send to Us

You may submit a contact form containing your first name, last name, email address, inquiry subject, message, and any additional information you choose to provide. You may also contact us directly by email and provide the contact details and information contained in your message.

Our form, hosting, security, and email-delivery systems may also process the date and time of submission and limited technical information, such as an IP address, where necessary to deliver the message, prevent spam, maintain security, or diagnose technical problems.

We use this information only to respond to your inquiry, provide the product, quotation, customization, technical, or project-related information or support you request, maintain appropriate records, resolve disputes, protect our legal rights, and comply with applicable legal obligations.

Using the contact form or contacting us by email is voluntary. However, fields marked with an asterisk are required to submit the form. If you do not provide the required information, you will be unable to submit the form and we may be unable to respond to your inquiry.

Please do not submit sensitive personal information unless it is reasonably necessary for your request.

Purposes and Legal Bases

We use GA4 information only to:

● measure Website traffic;

● understand how visitors interact with Website pages;

● identify technical or usability issues; and

● improve the performance, structure, and content of the Website.

We process essential technical information only as reasonably necessary to operate, deliver, secure, maintain, and troubleshoot the Website.

We use information submitted through the Website contact form or voluntarily sent to us by email only to respond to the sender, provide the requested product, quotation, customization, technical, or project-related information or support, maintain appropriate business records, resolve disputes, protect our legal rights, and comply with applicable law.

Depending on the applicable law and the relevant processing activity, we rely on one or more of the following legal bases:

● your consent, including for GA4 analytics technologies where prior consent is required;

● our legitimate interests in operating, securing, understanding, and improving the Website and responding to business communications, provided those interests are not overridden by your rights and interests;

● taking steps at your request before entering into a contract or performing a contract; and

● compliance with applicable legal obligations.

Midooc does not sell or rent personal information. We do not use information collected through the Website for targeted advertising, unrelated direct marketing, automated decision-making, or independent behavioural profiling.

Cookies and Similar Technologies

The Website may use cookies and similar technologies that are strictly necessary to deliver the Website, maintain security, remember privacy choices, or provide functions requested by the user. Where permitted by applicable law, these technologies may operate without consent because they are necessary for the relevant function.

Subject to your consent where required by applicable law, we also use GA4 analytics technologies to measure Website traffic and understand how visitors interact with the Website. GA4 analytics technologies are not necessary for access to the main content of the Website.

Under Google’s standard GA4 web configuration, the first-party cookies _ga and ga each have a default expiration period of two years. Their actual duration may be shorter because of browser restrictions, cookie settings, consent choices, or earlier deletion by the user. If we materially change these settings, we will update this Privacy Policy, our cookie settings, or a separate Cookie Notice accordingly.

Optional analytics cookies and other non-essential technologies will not be activated before consent where applicable law requires prior consent. You may accept or reject these technologies and may change or withdraw your choice through the Website’s cookie settings. Rejecting analytics technologies will not prevent you from accessing the main content or functions of the Website.

Certain embedded content, such as externally hosted video or media, may be provided by third parties and may use their own cookies or similar technologies when the content is activated. Where required by applicable law, such content will remain unavailable or restricted until the applicable choice has been made.

The cookies and technologies used by the Website may change when Website components or service providers are updated. We will update this Privacy Policy, the Website’s cookie settings, or a separate Cookie Notice where a material change affects how information is processed.

For more information about Google’s processing practices, please review Google’s Privacy Policy and How Google uses information from sites or apps that use its services.

How We Disclose Information

We may disclose information only as reasonably necessary to:

● Google, as our Website analytics service provider;

● website hosting, form-processing, spam-prevention, infrastructure, content-delivery, security, and technical service providers that help deliver, maintain, and protect the Website and process inquiries;

● email-delivery service providers that transmit or store messages submitted through the Website contact form or sent directly by email;

● professional advisers where reasonably necessary to obtain legal, accounting, security, or other professional advice; and

● courts, regulators, law-enforcement authorities, or other competent authorities where disclosure is required by applicable law or a valid and legally binding request.

Our service providers may process information only for the relevant services they provide, subject to applicable contractual and legal requirements.

Midooc does not sell or rent personal information and does not disclose personal information to data brokers or third parties for targeted advertising.

International Processing of Information

The Website is hosted on servers located in the United States. Website access, security, and error logs, contact-form submissions, and other limited technical information required to operate the Website may therefore be stored or processed in the United States.

Midooc is incorporated in Hong Kong, and our Chief Privacy Officer is based in Guangzhou, Mainland China. Information submitted through the Website contact form or sent to us by email, including privacy inquiries, complaints, and requests, may therefore be accessed or processed in Hong Kong and Mainland China. GA4 information and information handled by our other service providers may also be processed in the United States or in other countries or regions in which Google or those providers maintain facilities.

The principal locations currently known to Midooc for the processing described in this Privacy Policy are the United States, Hong Kong, and Mainland China. Google and other service providers may use distributed infrastructure and may process information in additional countries or regions identified in their own privacy or data-location materials. Privacy and data-protection laws in those locations may differ from those in your country or region.

International processing takes place only for the hosting, analytics, communications, security, support, and legal-compliance purposes described in this Privacy Policy and only for as long as reasonably necessary for those purposes. Where required by applicable law, we use appropriate contractual, technical, organizational, and other lawful safeguards for international processing. GA4 is activated in accordance with the cookie choices described in this Privacy Policy. You may contact our Chief Privacy Officer to request further information about safeguards applicable to a particular transfer where you have a legal right to receive that information.

Data Retention

Our GA4 property is currently configured to retain user-level and event-level data associated with cookies and other identifiers for two months before it becomes subject to automatic deletion by Google Analytics. If we materially change this retention setting, we will update this Privacy Policy accordingly.

The GA4 retention setting does not affect certain standard aggregated reports, which may remain available for a longer period. GA4 cookie identifiers may also remain on a user’s device for their applicable cookie duration, including the default two-year period described above, unless they expire earlier or are rejected, deleted, or limited by browser or Website settings.

Google and other service providers may retain certain analytics information, aggregated information, consent records, and technical information according to their applicable settings, technical requirements, contractual obligations, and legal requirements.

Website access, security, and error logs are retained only for as long as reasonably necessary to operate and protect the Website, investigate technical or security incidents, prevent misuse, and comply with applicable legal obligations.

Information submitted through the Website contact form or sent to us by email is retained only for as long as reasonably necessary to respond, provide the requested information or support, maintain appropriate business records, resolve disputes, protect legal rights, or comply with applicable legal obligations. The same retention criteria apply where a form submission is stored in WordPress, our form system, or our email system.

When information under our control is no longer reasonably necessary for these purposes, we will delete it, anonymize it, or restrict further processing as required by applicable law.

Security

We use reasonable administrative, technical, and organisational measures designed to protect information against unauthorised access, loss, misuse, alteration, or disclosure.

No Internet transmission or storage system can be guaranteed to be completely secure. If a personal information security incident occurs, we will take appropriate remedial measures and notify affected individuals and competent authorities where required by applicable law.

Third-Party Links and Policies

The Website may contain links to websites or services operated by third parties.

When you leave our Website or interact with a third-party service, that third party’s privacy policy applies to its own processing of information. We encourage you to review the applicable third-party privacy policy.

Midooc remains responsible for information processed under its control as required by applicable law.

Your Privacy Rights

Depending on the laws applicable to you, you may have the right to:

● request confirmation of whether we process your personal information;

● request access to or a copy of your personal information;

● request correction or completion of inaccurate or incomplete information;

● request deletion of your personal information;

● request anonymisation, restriction, or blocking of information that is unnecessary, excessive, or processed unlawfully, where applicable;

● withdraw consent, without affecting the lawfulness of processing carried out before withdrawal;

● object to or restrict certain processing;

● request information about the categories and sources of personal information, the purposes for which it is processed, the recipients or categories of recipients, and applicable international-transfer safeguards;

● request data portability where applicable;

● appeal a decision concerning a privacy-rights request, or use an authorised agent to submit a request, where applicable; and

● submit a complaint to an applicable privacy or data protection authority.

Where applicable law provides such protection, we will not discriminate against you for exercising a privacy right.

Because GA4 information generally does not directly identify a visitor to Midooc, we may be unable to associate analytics information with a particular individual unless sufficient technical information is provided and the request can be reasonably verified.

To exercise an applicable privacy right, contact us using the details in the Contact Us section below. We may take reasonable steps to verify your identity and the scope of your request. We will respond within the period required by applicable law.

Privacy Complaints

If you believe that Midooc has handled your personal information inconsistently with this Privacy Policy or applicable law, you may submit a complaint to our Chief Privacy Officer using the details in the Contact Us section below. Please describe your concern and provide the information reasonably necessary for us to assess it.

We will acknowledge the complaint, investigate it fairly, and respond without undue delay and within any period required by applicable law. We may request additional information where reasonably necessary and will explain our response and any appropriate steps we propose to take.

If you are not satisfied with our response, you may have the right to submit a complaint to the privacy or data-protection authority competent for your country or region.

Do Not Track and Privacy Preference Signals

Some browsers transmit “Do Not Track” or other privacy preference signals. The Website does not currently respond specifically to all such signals.

You can control GA4 analytics technologies through the Website’s cookie settings. Midooc does not sell personal information or use personal information for targeted advertising.

Children’s Privacy

The Website is intended for business and professional audiences and is not directed to children.

Midooc does not knowingly collect personal information from children through the Website. If we become aware that personal information has been collected from a child contrary to applicable law, we will take reasonable steps to delete it.

Changes to This Privacy Policy

We may update this Privacy Policy when our Website practices, technology, service providers, or legal obligations change.

The “Last Updated” date at the beginning of this Privacy Policy indicates when it was most recently revised. Where required by applicable law, we will provide additional notice or obtain consent before making a material change to how personal information is processed.

Contact Us

Within the Midooc Group, Midooc Group Limited, a company incorporated in Hong Kong, is responsible for the use of your personal information. If you have questions, requests, or complaints about this Privacy Policy, including how we or our service providers handle your personal information, you may contact us in the following ways:

Hong Kong Registered Office:
Midooc Group Limited
RM 1801, Easey Commercial Building
253-261 Hennessy Road
Wan Chai, Hong Kong

a. If you are a corporate-level user of the Midooc Group, please email us at we@midooc.com.

b. If you are a Midooc user and a resident of the European Economic Area, please email us at midooc@outlook.com.

c. Otherwise, if you are a Midooc user, please email us at we@midooc.com.

Our Chief Privacy Officer is based in Guangzhou, Mainland China and handles privacy matters on behalf of Midooc Group Limited. You may contact the Chief Privacy Officer at the following privacy correspondence address:

Chief Privacy Officer
Midooc Group Limited
406 Huasui Road, Tianhe District
Guangzhou 510623, Guangdong Province
China

Alternatively, you may email we@midooc.com with “Attn: Chief Privacy Officer” in the subject line.