Privacy Policy

Last Updated: June 26, 2025

You are welcome to use the software services provided by [Xtooltech Intelligent Co., Ltd ]and/or its affiliates, subsidiaries, and/or parent companies (collectively, “Xtool,” “we,” “us,” ) !

Xtool attaches great importance to user privacy, and strictly comply with relevant laws and regulations. Please read this Privacy Policy carefully before use. Continued use of our services means that you have fully understood and agreed to all the contents of this policy.

Privacy Notice

 We will strictly comply with data protection regulations such as the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the Personal Information Protection and Electronic Documents Act (PIPEDA), and handle your personal information in a transparent manner. When you use our software services (app/cloud platform), we may collect device serial numbers, operation logs, account information (email/phone numbers), and necessary diagnostic data (e.g., error codes) for purposes such as account management, technical support, algorithm optimization, and fulfilling legal obligations. We secure data through TLS encrypted transmission and hierarchical access control. You can access or delete non-essential data at any time through the [User Settings] or [Account Management] pages, and you have the right to refuse the collection of non-core information (which may affect the experience of some features). The processing of sensitive data (e.g., biometric information) requires your separate authorization. We may update this policy through in-app notifications or registered email addresses, and your continued use will be deemed as acceptance of the revisions. We may update the Policy via device-based notifications or registered email addresses, and your continued use will be deemed acceptance of the revisions.

We respect and protect the individual privacy rights of all users of our services. In order to provide you with a more accurate and better service, the Application will use and disclose your personal information in accordance with this Privacy Policy. Except as otherwise provided in this Privacy Policy, the Application will not disclose or provide this information to third parties without your prior permission. We will update this Privacy Policy from time to time. By using our products or services, you are deemed to have agreed to this Privacy Policy in its entirety.

This Privacy Policy applies to your access to and use of the services offered by Xtool by any means. This Privacy Policy is designed to help you understand what personal information we collect, why we collect it, what we do with it and how we protect it. We will collect and use your personal information in accordance with this Privacy Policy, but will not collect all of your personal information in a mandatory bundle simply because you have authorized your consent to this Privacy Policy. We will ask for your individual consent in certain circumstances in strict accordance with legal and regulatory requirements. If we provide you with a separate privacy policy for a particular product or service, that privacy policy will take precedence over the general privacy policy unless otherwise stated.

This Privacy Policy is relevant to the software services you use and the various business functions included in such services, and we hope that you will read it carefully and make sure that you fully understand what it says before using our products and/or services, and that it will allow you to make choices that you deem appropriate in accordance with the guidelines in this Privacy Policy. We have tried to keep the terms used in this Privacy Policy as concise as possible so that you can better understand them. By using or continuing to use our products and/or services after we have updated this Privacy Policy, you consent to the content of this Privacy Policy (including updated versions) and to the collection, use, storage and sharing of your information in accordance with this Privacy Policy.This Privacy Notice describes how Xtooltech Intelligent Co., Ltd and/or its affiliates, subsidiaries, and/or parent companies (collectively, “Xtool,” “we,” “us,” ) collect, use, disclose, transfer, store and otherwise process your personal data when you are using our services, including our websites, apps, online services and other products (hereinafter collectively referred to as "services"). Please read the Privacy Notice carefully and familiarise yourself with our privacy practices before using our services or providing your personal data.

This Privacy Policy is applicable to all products and services offered by Xtool. In the event that we do not have a distinct privacy policy for a particular product or service, this Privacy Policy will also govern that specific product or service. However, if we provide you with a separate Privacy Policy for a specific product or service, that Privacy Policy will take precedence over the general Privacy Policy, unless otherwise specified.

1. How We Collect Personal Data

What information we collect

We will ask you to provide personal information that is necessary for us to provide our services to you. We will only collect the information that is necessary for specified, concrete, explicit, and legitimate purposes and shall ensure that the information is not further processed in a manner that is incompatible with those purposes. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our products or services or respond to your queries.Depending on the service you choose, we may collect the following types of data:

1.1 Personal Data Directly Provided by You:

You may provide personal data to us directly, in which case you are generally free to choose which personal data you want to provide to us. However, if some personal data is required for the performance of our services and you choose not to provide that personal data, we may not be able to provide you with the services you requested. Personal data we directly collect from you may, for instance, include the following:

   • If you order a paid service from us, We may collect your delivery details, billing address and our 3rd party merchant provider will collect bank account number, credit card details other financial information relating to the transaction , order number, name and contact details, so we can process your order.

   • If you register an Xtool account：some of our services requires you to create an account and complete a personal profile. In these services, we may need to use theese information. Types of personal data include email address, username and password created, region, phone number.

   • We may ask you to provide personal data or collect it under other circumstances such as in connection with marketing: Such activities include when you use a promotional coupon or participate in promotional or marketing activities organised by us or our business partners on our behalf, complete questionnaires. To this extent, we may ask you to provide personal data such as your name, address, email address, phone number and other personal data as indicated in connection with such activities.

   • In case we provide you with a chat function or any other function on the platform to contact our customer service: We may collect your information including but not limited to your account ID, identity verification details, contact details, order details, chatting history, complaint or query related details, details about the product or services being enquired, etc.

1.2 Personal Data about use of our services and products: 

When you use our products and services, we may collect data about the type of device you are using, the unique identifier of your device, the IP address of your device, the serial number, the fixed version, the MAC address, the battery status and so on.

When you visit our Site/application, we may directly collect your account information, operating system, the type of internet browser you are using, usage information, diagnostic information, trouble codes, frequency of operation, error reports and location information. data about the type of device you use, your device’s unique identifier, the IP address of your device, your operating system, the type of Internet browser that you use, usage information, diagnostic information, and location information from or about the computers, phones, or other devices on which you install or access our products or services. Where available, our services may use the personalGPS, your IP address you provide, and other technologies to determine a device’s approximate location to allow us to improve our products and services. 

1.3 Other:

Special note regarding third-party services and SDKs:

Xtool's products and services may incorporate third-party products and services, which may involve payment, location services, and other types of functionalities. These third-party offerings could be provided through links to external websites or accessed through SDKs (software development kits), APIs (application programming interfaces), and similar means. It's important to note that when you utilize these third-party products and services, your information may also be collected.

2. How We Use Your Personal Data 

2.1 We will use your personal data for the following purposes:

• to provide you with Xtool 's services, process your orders or fulfil the contract between you and Xtool;

• to help you create and manage your Xtool account, activate services you have purchased, your warranty service and specific software licenses and provide notifications for software updates;

• to diagnose product issues and provide other customer care and support services;

• to conduct customer surveys in order to enhance your user experience and improve our services along with their security features;

• to analyse the efficiency of our business operations;

• to analyse error logs to improve app functions;

• to communicate with you and reply to your questions or comments submitted through email or our online platforms, including social media accounts;

• to ensure the functionality and safety of our services, verify your identity, conduct internal auditing and prevent and investigate fraud, cybersecurity threats or other improper use;

• to enhance and develop our services, so as to improve the product usage experience, user-friendliness, operational performance, functions and design;

• to pursue or defend against legal claims;

• to comply with our legal obligations.

2.2 When we want to use the personal data for other purposes not covered by this Privacy Notice, we will inform you thereof and ensure that said use of your personal data is lawful.

2.3 We do not make any decisions involving the use of algorithms or profiling that produces legal effects or other effects that significantly affect you.

3. How We Use Cookies and Similar Technologies

We use cookies and similar tracking technologies on our website and other services.

3.1 What Are Cookies?

Cookies are small text files that are transferred from our services and stored on your device. Our services may use "cookies" and other technologies such as pixel tags and web beacons (collectively referred to as "Cookies"). Cookies may be stored on your computer. Cookies not set by us will not be accessible to us.

3.2 How We Use Cookies

We use Cookies to better understand the functionality of our mobile software on your device, and to monitor and analyse how you use and interact with our services so that we can continue to improve them (such as to evaluate information on how often you use the services, events that occur on our services and where an app was downloaded). We do not link information that we store in analytics software to any personal data you may submit through our mobile apps.

4.How Long We Keep Your Personal Data

We will only store your personal data for as long as necessary to achieve the collection purposes set out in this Privacy Notice, unless a longer retention period is required by law. If we are required by law to store your personal data beyond this period (such as for tax and commercial law reasons), we will delete the personal data at the end of this storage period.

After the expiry of the aforementioned retention periods, we will delete or anonymise your personal data.

5.How We Transfer and Processing Your Personal Data

We transfer your personal information to, and process your personal information on, servers located in your registration region, a jurisdiction that may not provide equivalent levels of data protection as your home jurisdiction. Such transfers and processing of your personal information are necessary to provide our Services. We provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on executing Standard Contractual Clauses.

6. Privacy Protection for Minors  

6.1 Age Limits and Compliance Requirements  

The Products and Services are not intended for minors, and by registering, you represent that you meet the legal age requirements. Depending on the laws of your region, you must meet the following minimum age requirements to use the Services:  

-North America (U.S., Canada): 13 years of age or older;  

-European Union Member States: 16 years of age or older (or lower if your country requires it);  

-China: 14 years of age or older;  

-Other jurisdictions: please refer to local privacy regulations.  

6.2 Parental and Guardian Responsibilities  

If you are the guardian of a minor, please:  

- Supervise minors not to use the Device;  

- Avoid allowing minors to use your email address, cell phone number or other identification information to register for an account;  

- Contact us at [      ] to request deletion of the minor's account and related data.  

6.3 Data Processing Rules  

- No active collection: we do not knowingly process minors' data;  

- Active deletion: we will delete all associated data as soon as a minor account is discovered (except for logs required to be retained by law).  

6.4 Consequences of non-compliance  

- We reserve the right to temporarily freeze or permanently block suspected minor accounts.

 7.How We Process Children's Personal Data

1. Our Services are mainly intended for adults. A child should not use our Services without his/her legal guardian's consent. We treat anyone less than 18 years of age (or the equivalent minimum age for full legal capacity in the relevant jurisdiction) as a child.

2. If we discover that a child's personal data has been collected, we will delete the corresponding data as soon as possible.

3. If you believe that we might have any personal data concerning a child, please contact us using the "Contact Us" section.

8. How We Protect Your Personal Data

67.1 The security of your personal data is very important to us. We have taken reasonably practical, technical and organisational measures in accordance with industry standards to protect personal data collected in connection with our Service and prevent it from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

67.2  In case of a personal data security incident, we will act in accordance with applicable law and notify you and/or the competent data protection authority of any such security incident where required, and take measures to mitigate any risks arising therefrom.

9.Your Rights 

We take reasonable steps to ensure that your personal data is accurate, complete, and up to date. •You have the right to access, correct, or request that we delete the personal data that we collect.

•You are also entitled to restrict or object, at any time, to the further processing of your personal data.

•You have the right to receive your personal data in a structured and standard format.

•You may lodge a complaint with the competent data protection authority regarding the processing of your personal data.

•To protect the privacy and the security of your personal data, we may request data from you to enable us to confirm your identity and right to access such data, as well as to search for and provide you with the personal data we maintain.

•There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal data that we maintain.

You can exercise your rights by contacting us using the details set out in the “Contact Us” section below and we will response your request within 30 days.

10.How This Privacy Notice Is Updated

We reserve the right to update or modify this Privacy Notice from time to time. We will, as appropriate, send you notifications of material updates to this Privacy Notice in a form we deem appropriate and we will update the "last updated" date at the start of this Privacy Notice.

11.GDPR-Specific Provisions

The following provisions only apply to you if you live in Europe.

Legal Bases for the Processing of Personal Data

Our processing of your personal data is based on the following legal grounds:

1. Consent: We may process your personal data with your consent. In particular, we may ask for your consent to participate in promotional activities, such as to send you promotional messages or enable you to participate in the User Experience Program and certain services, including services through which we collect location information. You have the right not to provide consent, or to withdraw it at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal data before your withdrawal. If you have granted us consent to use your personal data, we will use it only for the purposes specified in the consent declaration. Please note that to the extent our processing is based on your consent and you deny your consent or withdraw it, we may not be able to provide the service relating thereto. Besides from that, neither the initial denial nor a withdrawal will have any negative consequences for you.

2. Perform or enter into a contract with you:

We rely on this legal basis in particular in the following cases:

• to provide you with Xtool's services, process your orders or fulfil the contract between you and Xtool;

   • to help you create and manage Xtool account, activate services you have purchased, your warranty service and specific software licenses and provide notifications for software updates;

   • to diagnose product issues, repair customer equipment and provide other customer care and support services.

3. Compliance with a legal obligation: Xtool may be obliged to process personal data to comply with our legal obligations, for example where Xtool is required to retain data for tax law or commercial purposes.

4. Legitimate interests: The processing of your personal data may also be necessary for Xtool's legitimate interests. In particular, such cases may include the following:

   • to conduct customer surveys to enhance your user experience;

   • to analyse the customer market on the basis of the country where you use our services, including the number of users for product marketing and promotion;

   • to analyse the efficiency of our business operations;

   • to analyse error logs to improve app functions;

   • to communicate with you and reply to your questions or comments submitted to us by any means;

   • to ensure the functionality and safety of our services;

   • to verify your identity;

   • to conduct internal auditing and to prevent and investigate fraud, cybersecurity threats or other improper use;

   • to enhance and develop our services, including relevant security features, so as to improve the product usage experience, user-friendliness, operational performance, functions and design;

   • to pursue or defend against legal claims.

Your personal data will only be processed on the above grounds after we have appropriately assessed and balanced our interests against your right to privacy.

How We Transfer Your Personal Data

1.We attach great importance to processing your data within the EU/EEA. However, it may happen that we use service providers who process data outside the EU / EEA. In these cases, we ensure that an adequate level of data protection comparable to the standards within the EU is established at the recipient before the transfer of your personal data. This can be achieved, for example, through EU standard contracts or binding corporate rules or special agreements to which the company can submit.

2. or in the absence of the above appropriate safeguards, we will ask you for your explicit consent for the cross-border transfer of your personal data or take any other measures that are recognised as providing a sufficient level of protection for your personal data.

Additional Information on Your Rights Regarding Personal Data

Subject to the legal requirements under the GDPR, you have the following rights:

   • The right to access: You may request access to the personal data we hold about you.

   • The right to rectification: If you find that the personal data we process about you is inaccurate or incomplete, you are entitled to ask us to make rectifications without undue delay and to request the completion of your personal data where appropriate.

   • The right to erasure: You can submit a request to us to delete personal data, and we shall have the obligation to erase it without undue delay in some circumstances – for example, if we do not have a legal reason to continue to process the personal data to the extent required by applicable laws and regulations. Please note in so far as you delete all the data that is contained in your device, this does not mean that you have deleted all data that Xtool collects and processes about you. Therefore, we encourage you to contact us (please refer to the section "Contact Us" above) to request that your personal data is deleted.

   • The right to restriction of processing: You have the right, in certain circumstances, to request Xtool to temporarily restrict the processing of your personal data, such as where the accuracy of that personal data is contested by you, while we verify the accuracy of that personal data. We will keep just enough data, or process such data as is necessary to ensure that we comply with your restriction request in the future.

   • The right to object: You have the right to object to any processing justified by legitimate interests based on grounds relating to your particular situation at any time. Should you decide to object to the processing of your personal data, we will stop processing personal data that concerns you, unless we can demonstrate compelling reasons for continuing to process your personal data that override your interests, rights and freedoms, or in the case that we establish, exercise or defend our legal claims. You can object to direct marketing activities at any time for any reason whatsoever.

   • The right to withdraw consent: If you have given us your consent to process your personal data but change your mind later, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal data before your withdrawal. If you want to withdraw your consent with regard to receiving promotional communications, you can unsubscribe through the method described in each promotional message. If you withdraw your consent, we may no longer be able to provide you with the corresponding Service.

   • The right to lodge a complaint: You have the right to lodge a complaint with a competent supervisory authority about the way we handle or process your personal data, or file a lawsuit in a court with jurisdiction.

   • The right to deactivate your Xtool account. If you wish to cancel the Xtool Account, please note that the cancellation will prevent you from using the full range of Xtool products and services.

12.California, United States Specific Provisions

Additional Information on What and How Your Personal Data Is Processed

Under California law, we are required to provide the following information regarding information that we collect from California residents. We may have collected the following personal data in the past 12 months:

Additional Information on Your Rights Regarding Your Personal Data

California residents are also entitled to the below rights:

1. the right to know and access information about the categories and specific pieces of personal data we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share the personal data we have collected;

2. the right to request the information regarding our disclosure of personal data to third parties for business purposes. To make such a request, please contact us using the details in the “Contact Us” section below;

3. the right to request the deletion of your personal data, subject to certain exceptions;

4. the right to opt out of the sale of your personal data to third parties. 

5. the right to not be discriminated against for exercising any of the rights mentioned above.

6. the right to deactivate your Xtool account.If you wish to cancel the Xtool Account, please note that the cancellation will prevent you from using the full range of Xtool products and services.

Whenever feasible for verification, we will match the identifying information provided by you to the personal data already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information. You may designate an authorised agent to make a request on your behalf. Such authorised agent must be registered with the California Secretary of State. We may deny a request from an agent that does not submit proof that they have been authorised by you to act on your behalf.

You can exercise your rights by contacting us using the details set out in the “Contact Us” section below and put “California Privacy Rights” in the subject line of your request and we will response your request within 30 days.

13.Contact us 

If you have questions or concerns regarding our Privacy Notice or practices, please submit your request through:

   • Email:supporting@xtooltech.com

   • Postal address: 17&18/F, A2 Building, Creative City, Liuxian Avenue,
Nanshan District, Shenzhen, China