Privacy Policy

Last updated: June 17, 2026 · Effective: June 17, 2026

1. Introduction

Pivot Key, operated by Songyuan Zhuang Qi Technology Co., Ltd., respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at pivotkey.hair or engage with our services. By using our website or services, you acknowledge and agree to the practices described in this policy. If you have questions or concerns, please contact us using the information provided at the end of this document.

2. Information We Collect

2.1 Information You Provide

We collect information you voluntarily provide when you submit inquiries, request proposals, or communicate with us. This includes your name, email address, phone number, company name, and job title. We also collect project-related information including technical specifications, system requirements, architectural details, operational context, and business objectives shared during consultations or throughout the course of an engagement. We maintain records of our communications, including emails and meeting notes, to ensure consistent and informed service.

2.2 Information Collected Automatically

When you visit our website, we automatically collect certain information. This includes pages visited, time spent on each page, navigation patterns, referring URLs, browser type and version, operating system, IP address, device type and characteristics, and language preferences. This information is collected through cookies and similar tracking technologies, which are described in more detail in Section 5 of this policy.

2.3 Third-Party Information

We may receive information about you from business partners, analytics providers, search information providers, and publicly available sources where permitted by applicable law. Any information received from third parties is handled in accordance with this Privacy Policy and applicable data protection regulations.

3. How We Use Your Information

We process personal data for the following purposes: to respond to your inquiries and provide the information or services you have requested; to evaluate project requirements and develop technical proposals, assessments, and architectural recommendations; to communicate with you regarding your projects, service updates, technical bulletins, and relevant industry developments where you have consented to receive such communications; to improve our website, services, and user experience through analysis of usage patterns and feedback; to comply with our legal and regulatory obligations, enforce our terms of service, and protect our rights and the rights of others; and to detect, investigate, and prevent technical issues, security incidents, fraudulent activity, or other conduct that may violate our policies or applicable laws. We will not use your personal data for purposes that are incompatible with those described in this policy without first notifying you and, where required by law, obtaining your consent.

4. Legal Basis for Processing (GDPR)

For individuals located in the European Economic Area, our processing of personal data is conducted on the following lawful bases as set out in the General Data Protection Regulation: your consent, which you may withdraw at any time, for specific processing purposes such as the placement of non-essential cookies or direct marketing communications; the necessity of processing for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract; our legitimate interests in operating and improving our business, maintaining the security of our systems, communicating with our clients and prospects, and promoting our services, provided that these interests are not overridden by your rights and freedoms; and compliance with a legal obligation to which we are subject, such as retaining records for tax or regulatory purposes.

5. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance functionality, analyze how visitors use the site, and improve your experience. Essential cookies are strictly necessary for the operation of our website and cannot be disabled. Analytics cookies collect aggregated, anonymous information about how visitors interact with our website. Preference cookies remember your settings and choices for a personalized experience on return visits. You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality and performance of our website.

6. Data Sharing and Disclosure

We may share your personal data with trusted third-party service providers who perform services on our behalf, such as website hosting, data analytics, email delivery, and customer relationship management. These providers are contractually obligated to protect your data and may only process it for the specific purposes we authorize. We may disclose your information to professional advisors where reasonably necessary for legal or business purposes. In the event of a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction with appropriate notification. We may disclose information when required by law, regulation, or court order. We do not sell your personal data to third parties under any circumstances.

7. Data Retention and Security

We retain your personal data only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. When determining retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use, the processing purposes, and applicable legal requirements. When no longer needed, data is securely deleted or anonymized. We implement technical and organizational security measures including TLS/SSL encryption, access-controlled infrastructure with multi-factor authentication, regular vulnerability assessments, employee training, and incident response procedures to protect your data against unauthorized or unlawful processing and against accidental loss or damage.

8. Your Rights

Under GDPR (EEA Residents): You have the right to access your personal data and request a copy of the information we hold. You have the right to rectify inaccurate or incomplete data. You have the right to request erasure where there is no compelling reason for continued processing. You have the right to restrict processing in certain circumstances. You have the right to data portability. You have the right to object to processing based on legitimate interests or for direct marketing. You have the right not to be subject to solely automated decisions that significantly affect you.

Under CCPA (California Residents): You have the right to know what personal information we collect about you. You have the right to request deletion of your personal information, subject to exceptions. You have the right to opt out of the sale of your personal information. We do not sell personal information as defined by the CCPA. You have the right to exercise your privacy rights without discriminatory treatment.

To exercise any of these rights, please contact us at wind@pivotkey.hair. We will respond within the timeframes required by applicable law and may need to verify your identity before processing your request. You also have the right to lodge a complaint with your local data protection authority if you believe we have handled your data improperly.

9. International Data Transfers

Your personal data may be transferred to, stored, and processed in countries other than your own, including China and the United States, where our servers and service providers are located. When we transfer data across borders, we implement appropriate safeguards including Standard Contractual Clauses approved by the European Commission to ensure your data receives adequate protection.

10. Children's Privacy and Third-Party Links

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us immediately. Our website may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal data.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Changes are effective upon posting with an updated effective date. For significant changes, we may provide additional notice through our website or by email. We encourage you to review this policy periodically to stay informed about how we are protecting your information.

12. Complaints

If you believe that our processing of your personal data violates applicable data protection laws, you have the right to lodge a complaint with your local data protection authority. We encourage you to contact us first so that we can attempt to resolve your concerns directly. EEA residents may lodge a complaint with the supervisory authority in their country of residence. California residents may contact the California Attorney General's office for matters relating to CCPA compliance.

13. Contact Information