ABO Privacy Policy

Effective date: [2026.10.16] Last updated: [2026.10.16]

1. Who we are and what this Policy covers

This Privacy Policy explains how [Abo Company Limited], trading as ABO ("ABO", "we", "us" or "our"), collects, uses, discloses, stores and otherwise processes personal information through [aboglass.com], the ASK ABO AI assistant, product inquiry lists, inquiry forms and related business communications. For the processing described in this Policy, we act as the data controller or equivalent responsible entity under applicable law.

ABO provides a website for business customers worldwide to explore glassware products, obtain AI-assisted product recommendations and submit inquiries to our sales team. The website does not provide online payment functionality or collect payments.

Personal information means information relating to an identified or identifiable individual, including a business representative's name and professional contact details. Information does not lose its protection merely because it is provided in a business context.

This Policy addresses personal information processing. Website use, intellectual property, product information, quotations and any subsequent sales arrangements may be governed by separate applicable terms. Reading this Policy or continuing to browse the website does not, by itself, constitute consent to every processing activity described here.

2. Personal information we collect

Contact and company information. When you submit an inquiry, we collect the information requested in the form, including your full name, business email address, company name and destination country or region. If you choose to provide additional business contact information, such as a telephone number or job title, we also process that information.

Product and inquiry information. We collect information about the products you select or add to your inquiry list, including product references, quantities where provided, specifications, customization requirements and other purchasing requirements. We also collect the notes and delivery targets you submit and your subsequent communications with our sales personnel.

ASK ABO information. When you use ASK ABO, we process the messages, keywords, product preferences and other information you enter, together with the recommendations generated in response. If you provide personal information in a conversation, it becomes part of the information processed through that service.

Technical and usage information. Depending on the website's actual configuration, we collect [confirm actual categories: IP address, browser type, device information, operating system, access times, pages viewed, referral information, session identifiers, cookie identifiers and error or security logs]. The destination country or region you enter is used to handle your inquiry and does not, by itself, mean that we collect your device's precise location.

Please also avoid providing passwords, government identification numbers, health information or other sensitive personal information that is unnecessary for a product inquiry. If such information is submitted inadvertently, we will assess and handle it in accordance with applicable law, including deleting or restricting it where appropriate.

3. How we collect information

We collect information directly when you communicate with ASK ABO, select products, maintain an inquiry list, complete an inquiry form or contact our team. Certain technical information is collected automatically when you access the website, subject to applicable consent requirements and your choices.

Information entered into ASK ABO is processed when you send a message and may therefore be processed before you submit a final inquiry.

4. Why we use personal information

Product assistance and inquiries. We use relevant information to understand your requirements, recommend products, maintain your inquiry list, answer questions, prepare quotations, assess destination and delivery requirements and arrange sales follow-up.

Website operation and security. We use necessary technical and session information to operate website functions, diagnose errors, maintain service reliability and protect against spam, fraud, unauthorized access and misuse.

Service improvement. Where lawful, we use appropriately limited information to assess service quality and improve product search, recommendations and website usability. Any use of identifiable conversations for AI training is governed by the specific disclosures in Section 6 and cannot be inferred from this general improvement purpose.

Compliance and legal protection. We use necessary information to fulfill legal obligations, respond to lawful requests, handle privacy requests, investigate genuine security incidents and establish, exercise or defend legal claims.

We do not use personal information for an incompatible new purpose without first providing required information and establishing the appropriate legal basis, including obtaining consent where required.

5. Legal bases

Where applicable law requires a legal basis, we identify the basis appropriate to each activity. Depending on the circumstances and jurisdiction, this may include your consent, steps requested before entering into a contract with you, performance of a contract with you, compliance with legal obligations or legitimate interests where legally recognized.

Where you act on behalf of a company, responding to your inquiry and managing the business relationship may rely on legitimate interests where permitted, rather than on the assumption that you personally are a party to a contract. Relevant interests include responding to genuine business requests, maintaining service security and protecting legal rights, subject to balancing your rights and interests.

Where consent is the legal basis, you may withdraw it at any time through the relevant control or by contacting us. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal. We do not rely on legitimate interests where the applicable law does not recognize that basis for the processing concerned.

6. ASK ABO and AI processing

ASK ABO is an AI assistant designed to help users explore products and identify items relevant to their requirements. It uses your keywords, messages and conversation context to generate responses and product recommendations. This may involve inferring commercial product preferences from the information you provide.

AI-generated responses may contain errors or omissions. Product suitability, specifications, availability, pricing and delivery arrangements require confirmation by authorized ABO sales personnel before any subsequent transaction.

ASK ABO uses AI services supplied by a provider based in mainland China to process the keywords, messages and necessary conversation context you submit, understand your requirements and recommend relevant products. For questions or to exercise your privacy rights, please contact [privacy@aboglass.com].

ASK ABO is intended to assist product selection, rather than make solely automated decisions that produce legal or similarly significant effects on individuals. You may contact our sales team for human assistance.

7. Inquiry lists and submission

Products selected through ASK ABO or added while browsing may be placed in an inquiry list. Selecting a product, adding it to a list or submitting an inquiry does not constitute a completed purchase, payment or binding purchase order. The website does not provide payment functionality.

When you submit an inquiry, your contact details, company name, destination, selected products and notes are sent to authorized ABO personnel responsible for quotations and follow-up, including through email.

Required fields are used to identify the business contact, respond to your request and assess destination requirements. If you do not provide information genuinely necessary for the requested service, we may be unable to process your inquiry. Optional notes may be left blank.

Submitting an inquiry requests a business response. It does not automatically subscribe you to unrelated marketing communications. Any subsequent sale is subject to separate confirmation and applicable sales terms.

8. Marketing

We send promotional communications only where permitted by applicable law and obtain prior consent where required. Consent to optional marketing is separate from requesting a quotation or acknowledging this Policy.

You may unsubscribe through the link in a promotional email or contact us. We respect applicable rights to object to direct marketing and related profiling. We may retain a minimal suppression record to ensure that your opt-out remains effective.

Opting out of marketing does not stop necessary responses to inquiries you initiate, communications about a subsequent business relationship or legally required notices.

9. Information recipients

Authorized personnel. Information is accessible to ABO personnel who need it to handle inquiries, provide technical support, maintain security or perform other disclosed responsibilities.

Business partners. Where your request requires an independent distributor or another partner, we disclose only necessary information on an appropriate legal basis. We identify recipients or recipient categories and obtain separate consent where required. Independent recipients may have their own privacy policies.

Professional advisers and authorities. We may disclose necessary information to advisers, regulators, courts or other authorized recipients where legally required or lawfully necessary to protect safety, investigate fraud or establish, exercise or defend legal claims. We assess the legal basis and applicable restrictions before disclosure.

Business transfers. If a merger, acquisition or business transfer involves personal information, we apply required confidentiality and privacy safeguards and provide legally required notices. Such a transfer does not cancel applicable data protection obligations.

10. International processing

Where information from the EEA, United Kingdom or Switzerland is transferred to a location without an applicable adequacy determination, we use an appropriate legally recognized mechanism where required, such as standard contractual clauses and any necessary transfer assessment and supplementary safeguards. You may request information about the applicable mechanism and relevant safeguards through our privacy contact.

For other regulated international transfers, we complete applicable notices, consents, assessments, contracts, filings or other required procedures before transferring information. A general acknowledgment of this Policy does not replace a legally required separate consent or transfer mechanism.

11. Information security

We apply technical and organizational safeguards appropriate to the risks, including [insert verified safeguards, such as encrypted transmission, access controls, confidentiality obligations, provider assessments and incident response procedures]. Access is limited according to job responsibilities.

No internet service can guarantee absolute security. This does not exclude or reduce any legal security obligation or liability that cannot lawfully be excluded. If a personal information breach occurs, we assess and respond to it and notify individuals and authorities where required.

12. Your rights

Depending on applicable law, you may have rights to receive information about processing; access or obtain a copy of your information; request correction or deletion; restrict or object to processing; receive portable information; withdraw consent; and request human review of certain automated decisions.

Some laws also provide rights concerning sensitive information, sale or sharing, targeted advertising, appeals and instructions concerning information after death. These rights apply subject to the conditions and exceptions in the relevant law.

To exercise rights, contact [privacy@aboglass.com]. Where permitted, an authorized representative may submit a request for you. We request identity or authority verification only where appropriate and proportionate, and do not use verification to obstruct lawful requests.

We respond within applicable statutory deadlines. Requests under the GDPR are generally handled within one month, with extensions only where permitted and properly notified. Different deadlines may apply to other rights and jurisdictions. We explain any lawful refusal and any available appeal or complaint options.

13. Children

The website and inquiry services are intended for adult business users and are not directed at children. Individuals under 18 should not use ASK ABO or submit personal information. This intended audience does not remove any protection required by applicable children's privacy laws.

If we discover that children's information has been collected contrary to applicable law, we take appropriate steps to delete it or otherwise handle it lawfully. Parents or guardians may contact [privacy@aboglass.com].

14. Accurate information and misuse prevention

Please provide information that is accurate to the best of your knowledge and that you are entitled to disclose. Do not impersonate another person or submit another individual's personal information without appropriate authority. Avoid including unnecessary confidential business material.

Where reasonably necessary and lawful, we may verify suspicious submissions, filter automated abuse, limit malicious activity and retain relevant evidence for a justified period. These measures must be proportionate and must not obstruct legitimate privacy requests or complaints.

An inaccurate submission, disagreement or unsuccessful complaint does not, by itself, establish bad faith. Nothing in this Policy prevents lawful complaints or legal claims, waives non-waivable rights or excludes liability that cannot lawfully be excluded.

15. Policy updates and language

We may update this Policy to reflect changes in services, processing practices or applicable requirements. We publish the revised version and update the date. Where legally required, we provide additional notice or obtain renewed consent before implementing relevant changes.

Updates do not retrospectively authorize processing that was unlawful when undertaken. Continued website use does not replace any fresh consent required by law.

The English and Chinese versions are intended to have the same meaning. If an inconsistency arises, we will clarify and correct it, subject to applicable mandatory law and legally required language protections.

16. Contact us

For privacy questions, rights requests or complaints, please contact: Email: [info@aboglass.com]