PRIVACY NOTICE

Last Updated: July 22, 2026

TOPDON and its affiliated companies (collectively, "TOPDON", "we", "us", or "our") respect your privacy and are committed to protecting your personal information.

This Global Privacy Notice ("Notice") explains how TOPDON collects, uses, stores, protects, and processes personal information when you access or use TOPDON websites, official online stores, customer account services, product registration services, customer support platforms, community features, cooperation programs, and other online services that link to or reference this Notice (collectively, the "Services").

This Notice applies to personal information processed through TOPDON online services. Certain products, software, applications, subscriptions, or regional services may have additional privacy notices or specific privacy terms where required.

By using TOPDON Services, you acknowledge that you have read and understood this Notice.

1. Who We Are

TOPDON is a global technology company providing automotive diagnostic equipment, intelligent repair solutions, battery technology products, software-related services, technical support, and related digital services.

TOPDON operates globally through affiliated companies established in different jurisdictions. Depending on your location, the products or services you access, and the applicable transaction or service relationship, your personal information may be managed by the relevant TOPDON entity responsible for providing services in your region.

The TOPDON Group includes the following entities:

Headquarters – Mainland China

TOPDON TECHNOLOGY Co., Ltd.

20th and 25th Floors, Qianhai Shimao Tower, No. 3040, Xinghai Avenue, Nanshan Street, Qianhai Shenzhen-Hong Kong Cooperation Zone, Shenzhen, Guangdong, P.R. China

Hong Kong

HK Topdon Technology Co., LIMITED

ROOM 2512, WELL FUNG INDUSTRIAL CENTER, NO.68 TA CHUEN PING STREET, KWAI CHUNG, NT, HONG KONG

United States

TOPDON TECHNOLOGY USA INC.

114 Clinton Road, Fairfield, New Jersey 07004, United States

Europe

TOPDON EUROPE S.L.

Planta 2ª puerta 1ª de la Escalera B, C/ de Sant Elies, 29, 35, 08006 Barcelona, Spain

Australia

TOPDON AUSTRALIA PTY LTD

198 Newnham Road, Mount Gravatt East, Queensland, 4122, Australia

2. Regional Data Management Model

TOPDON follows a regional data management approach designed to support localized business operations and compliance with applicable privacy laws.

Personal information collected through TOPDON websites, official online stores, and related online services is managed by the applicable TOPDON entity responsible for the relevant region or service.

Each regional TOPDON entity independently manages personal information within its applicable business scope, including where applicable:

• customer services;
• order processing;
• product registration;
• warranty services;
• technical support;
• regional marketing activities; and
• other localized business operations.

TOPDON does not maintain a centralized global personal information database for routine business operations.

Personal information is generally stored and processed within the region where it is collected or where the applicable TOPDON entity provides services.

TOPDON does not routinely transfer personal information between regional TOPDON entities or across national borders.

Where a transfer of personal information is necessary due to legal requirements, user requests, technical requirements, or specific service arrangements, TOPDON will implement appropriate safeguards in accordance with applicable laws.

3. Scope of This Privacy Notice

This Notice applies to personal information processed through TOPDON online services, including but not limited to:

• TOPDON official websites;
• official online stores;
• customer account systems;
• product registration services;
• warranty and after-sales service platforms;
• technical support channels;
• community features;
• product review programs;
• cooperation and user participation programs;
• subscription-related services; and
• other online services that reference this Notice.

This Notice does not apply to third-party websites, platforms, products, or services that are not operated or controlled by TOPDON, even if they are accessible through links provided on TOPDON Services.

4. Information We Collect

The types of personal information we collect depend on how you interact with TOPDON Services, the products or services you use, and applicable legal requirements.

We collect only information that is reasonably necessary for providing, maintaining, improving, and securing our Services.

4.1 Information You Provide

When you create an account, place an order, register a product, contact customer support, participate in activities, or otherwise interact with TOPDON Services, you may provide information including:

• name;
• email address;
• phone number;
• account information;
• company name;
• business information;
• shipping and billing information;
• product purchase information;
• communication records; and
• other information you voluntarily provide.

We use this information to:

• create and manage accounts;
• process orders and provide services;
• provide customer support;
• communicate with you regarding products and services;
• manage warranty and after-sales services;
• process requests, feedback, or applications; and
• maintain business records.

4.2 Product and Service Information

When you register, activate, use, or request support for TOPDON products or services, we may collect information related to the products or services you use, including:

• product model information;
• serial number or product identification information;
• product registration information;
• device-related technical information;
• software or firmware-related information;
• service records; and
• information necessary to provide technical support, warranty services, or product-related assistance.

We use this information to:

• verify product ownership and authenticity;
• provide warranty and after-sales services;
• provide technical support and troubleshooting;
• maintain product service records;
• manage software updates and service eligibility;
• improve product quality and user experience; and
• provide services requested by you.

4.3 Transaction and Payment Information

When you purchase products or services through TOPDON official online stores or related platforms, we may process transaction-related information, including:

• order information;
• purchased products or services;
• transaction amount;
• billing information;
• shipping information;
• payment status;
• refund information; and
• transaction records.

Payments are generally processed through third-party payment service providers.

TOPDON does not request or require you to provide full payment card numbers, security codes, or other sensitive payment credentials through email, customer service communications, or other unsecured channels.

We use transaction information to:

• process and fulfill orders;
• arrange delivery;
• process refunds and returns;
• provide customer support;
• maintain transaction records;
• prevent fraud and unauthorized transactions; and
• comply with legal, accounting, and regulatory obligations.

4.4 Customer Support and Communication Information

When you contact TOPDON for assistance, we may collect information necessary to respond to your requests, including:

• your contact information;
• communication records;
• support requests;
• product-related information;
• troubleshooting information;
• repair or service records; and
• other information you provide during communications.

We use this information to:

• respond to inquiries;
• provide technical assistance;
• process service requests;
• improve customer support quality;
• maintain service records; and
• resolve disputes or complaints.

4.5 Automatically Collected Information

When you access or use TOPDON Services, certain information may be automatically collected through technical means, including:

• IP address;
• browser type;
• access time;
• pages visited;
• interaction records;
• language preferences;
• error logs; and
• similar technical and usage information.

We use this information to:

• operate and maintain website functionality;
• improve website performance;
• protect service security;
• detect abnormal activities;
• prevent fraud and misuse;
• analyze service usage; and
• improve user experience.

4.6 Cookies and Similar Technologies

TOPDON uses cookies and similar technologies to support website operation, improve user experience, analyze service usage, and provide relevant features.

Cookies may be used for purposes including:

• maintaining account sessions;
• remembering user preferences;
• supporting shopping cart functions;
• improving website performance;
• analyzing website traffic;
• measuring marketing effectiveness; and
• improving website content and functionality.

Where required by applicable law, TOPDON will obtain your consent before using non-essential cookies or similar tracking technologies.

You may manage or disable cookies through your browser settings. However, disabling certain cookies may affect the availability or functionality of some Services.

5. How We Use Personal Information

TOPDON uses personal information only for purposes that are reasonably necessary and consistent with the purposes described in this Notice.

We may use personal information to:

5.1 Provide Products and Services

Including:

• processing purchases;
• delivering products;
• providing product registration services;
• providing warranty services;
• providing technical support;
• managing subscriptions or digital services; and
• fulfilling service requests.

5.2 Manage Accounts and Customer Relationships

Including:

• creating and maintaining accounts;
• verifying user identity;
• communicating service-related information;
• responding to inquiries;
• managing customer requests; and
• maintaining service records.

5.3 Improve Products and Services

Including:

• analyzing service performance;
• improving website functionality;
• improving customer experience;
• developing new products and services;
• conducting quality analysis; and
• understanding user needs.

5.4 Security and Compliance

Including:

• protecting TOPDON Services;
• detecting and preventing fraud;
• preventing unauthorized access;
• maintaining system security;
• enforcing applicable terms;
• complying with legal obligations;
• responding to lawful requests from authorities; and
• protecting the rights, safety, and interests of TOPDON, users, and third parties.

5.5 Marketing Communications

Where permitted by applicable law, TOPDON may send information about products, services, promotions, events, or other updates.

Where required, we will obtain your consent before sending marketing communications.

You may unsubscribe from marketing communications at any time by using the unsubscribe mechanism provided in the communication or by contacting TOPDON through applicable support channels.

Please note that even if you opt out of marketing communications, we may still send important service-related communications, such as order updates, account notices, security notifications, or warranty-related information.

6. Legal Basis for Processing Personal Information

Depending on your location and applicable laws, TOPDON may process personal information based on one or more of the following legal grounds:

• performance of a contract with you;
• providing products or services requested by you;
• compliance with legal obligations;
• protection of legitimate interests of TOPDON or third parties;
• fraud prevention and security protection; and
• your consent where required by applicable law.

The applicable legal basis may vary depending on your jurisdiction, the nature of the service, and the relationship between you and the relevant TOPDON entity.

7. How We Share Personal Information

TOPDON does not sell your personal information to third parties for independent marketing purposes.

We may share personal information only when necessary to provide products, services, maintain business operations, comply with legal obligations, or protect legitimate interests.

The categories of recipients may include:

7.1 TOPDON Regional Entities

Depending on the products or services you use, personal information may be processed by the applicable TOPDON entity responsible for providing the relevant services.

Regional TOPDON entities operate independently within their respective business scope and manage personal information in accordance with applicable local laws and requirements.

TOPDON does not routinely share personal information between regional entities unless necessary for:

• providing services requested by you;
• supporting customer service;
• fulfilling contractual obligations;
• maintaining operational functions;
• complying with legal requirements; or
• protecting the security and interests of TOPDON and users.

7.2 Service Providers

TOPDON may engage trusted third-party service providers to support our business operations.

These service providers may include providers supporting:

• website hosting;
• e-commerce operations;
• payment processing;
• logistics and delivery;
• customer support;
• email communication;
• analytics services;
• security protection;
• website maintenance; and
• other technical or operational services.

Such service providers are permitted to process personal information only to the extent necessary to provide contracted services and are required to protect personal information in accordance with applicable agreements and legal requirements.

7.3 Business Transactions

If TOPDON undergoes a business transaction, such as:

• merger;
• acquisition;
• restructuring;
• transfer of assets;
• financing;
• or sale of part of a business,

personal information may be transferred as part of such transaction where legally permitted.

Where required by applicable law, TOPDON will provide appropriate notice and ensure continued protection of personal information.

7.4 Legal and Regulatory Requirements

TOPDON may disclose personal information where required or permitted by applicable laws, regulations, legal processes, or governmental requests.

This may include disclosures necessary to:

• comply with legal obligations;
• respond to lawful requests from authorities;
• enforce agreements or policies;
• protect the rights, safety, and property of TOPDON, users, or third parties; and
• prevent fraud, security threats, or unlawful activities.

8. Third-Party Services and External Links

8.1 Third-Party Services

TOPDON Services may use or integrate with third-party services to support website operation, online transactions, customer support, analytics, marketing activities, and other business functions.

Depending on the services provided, third parties may include:

• payment providers;
• e-commerce platforms;
• logistics providers;
• analytics providers;
• communication tools;
• customer relationship management platforms;
• website functionality providers; and
• marketing service providers.

These third parties may process personal information according to their own privacy policies and applicable agreements.

TOPDON selects and manages third-party service providers with consideration of security, privacy, and compliance requirements.

8.2 External Links

TOPDON Services may contain links to third-party websites, platforms, applications, or services.

These third-party services operate independently from TOPDON.

TOPDON is not responsible for the privacy practices, security measures, content, or activities of third-party services.

We encourage you to review the privacy notices and terms provided by third parties before using their services or providing personal information.

9. Data Storage and Retention

9.1 Data Storage

TOPDON follows a regional data management approach.

Personal information is generally stored and processed by the applicable TOPDON entity within the region where the relevant services are provided or where the information is collected.

TOPDON does not maintain a centralized global personal information database for routine business operations.

Regional TOPDON entities manage personal information independently within their respective business scope.

9.2 Data Retention

TOPDON retains personal information only for as long as reasonably necessary to fulfill the purposes described in this Notice, unless a longer retention period is required or permitted by applicable law.

Retention periods may vary depending on:

• the type of information;
• the purpose of processing;
• legal and regulatory requirements;
• business needs;
• dispute resolution requirements; and
• security considerations.

Examples include:

Account Information

Retained while your account remains active or for a reasonable period necessary to manage account-related services.

Transaction Information

Retained for a period necessary to:

• complete transactions;
• provide after-sales support;
• process refunds;
• maintain accounting records; and
• comply with tax or legal obligations.

Customer Support Information

Retained for a reasonable period after resolution of service requests to support follow-up services, quality improvement, and dispute handling.

Technical and Usage Information

Retained for a limited period necessary for:

• website operation;
• security monitoring;
• performance analysis; and
• service improvement.

9.3 Secure Disposal

When personal information is no longer necessary for the purposes described in this Notice, TOPDON will delete, anonymize, or securely dispose of such information in accordance with applicable laws and internal procedures.

Where retention is required for legal, regulatory, security, or dispute resolution purposes, TOPDON will retain only the minimum information necessary for the required period.

10. International Data Transfers

TOPDON adopts a regional data management model and does not routinely transfer personal information between regional TOPDON entities or across national borders.

Personal information collected through TOPDON websites, official online stores, and related services is generally managed and stored within the applicable region.

In limited circumstances, personal information may be transferred across jurisdictions where necessary, including:

• where required by applicable laws or regulations;
• where necessary to provide services requested by you;
• where required for technical operation or security purposes;
• where you provide consent; or
• in connection with legitimate business operations permitted by law.

Where cross-border transfer is required, TOPDON will take appropriate measures to protect personal information, including implementing applicable legal safeguards and ensuring the recipient provides appropriate protection consistent with applicable requirements.

11. Your Privacy Rights

Depending on your location and applicable privacy laws, you may have certain rights regarding your personal information.

These rights may include:

11.1 Right to Access

You may request information about whether TOPDON processes your personal information and, where applicable, request access to such information.

This may include information regarding:

• categories of personal information processed;
• purposes of processing;
• sources of information;
• categories of recipients; and
• other information required under applicable laws.

11.2 Right to Correction

You may request correction of personal information that is inaccurate, incomplete, or outdated.

Where appropriate, TOPDON will update or correct your information within a reasonable period.

11.3 Right to Deletion

You may request deletion of your personal information where permitted by applicable law.

TOPDON may decline deletion requests where retention is necessary for legitimate purposes, including:

• fulfilling contractual obligations;
• completing transactions;
• providing warranty or after-sales services;
• complying with legal, tax, accounting, or regulatory obligations;
• resolving disputes; or
• protecting security and preventing fraud.

11.4 Right to Withdraw Consent

Where TOPDON processes personal information based on your consent, you may withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing conducted before withdrawal.

11.5 Right to Restrict or Object to Processing

Where provided by applicable law, you may request restriction of certain processing activities or object to specific uses of your personal information.

For example, you may object to certain direct marketing activities.

11.6 Right to Data Portability

Where required by applicable law, you may request a copy of personal information that you have provided to TOPDON in a structured and commonly used format.

11.7 Right to Lodge a Complaint

If you believe that TOPDON has processed your personal information in violation of applicable privacy laws, you may contact TOPDON to seek resolution.

You may also have the right to submit a complaint to the relevant data protection authority or regulatory body in accordance with applicable laws.

11.8 Exercising Your Rights

To exercise your privacy rights, please contact the applicable TOPDON entity through the contact information provided in this Notice.

Before processing certain requests, TOPDON may ask you to provide information necessary to verify your identity and protect against unauthorized requests.

TOPDON will respond to privacy requests within the timeframe required by applicable laws.

12. Security of Personal Information

TOPDON takes reasonable technical, organizational, and administrative measures to protect personal information against unauthorized access, disclosure, alteration, loss, or misuse.

Security measures may include:

• access control management;
• authorization management;
• security monitoring;
• system protection measures;
• data encryption where appropriate;
• backup and recovery mechanisms;
• employee access restrictions; and
• security reviews and improvements.

TOPDON continuously evaluates and improves its security practices based on business operations, technological developments, and applicable legal requirements.

However, no method of transmission, storage, or processing can be guaranteed to be completely secure.

You are responsible for maintaining the security of your account credentials and should avoid sharing your account information with unauthorized persons.

13. Children's Privacy

TOPDON Services are not intended for children unless permitted by applicable laws and designed for such use.

TOPDON does not knowingly collect personal information from children without appropriate authorization where required by applicable law.

If you believe that TOPDON has collected personal information from a child in violation of applicable requirements, please contact us so that we can take appropriate action.

14. Changes to This Privacy Notice

TOPDON may update this Privacy Notice from time to time to reflect changes in:

• business operations;
• products and services;
• technology;
• privacy practices;
• legal and regulatory requirements; or
• security measures.

When we update this Notice, we will revise the "Last Updated" date displayed at the beginning of this document.

For material changes that significantly affect your rights or the way we process personal information, TOPDON may provide additional notice through reasonable methods, including:

• website announcements;
• account notifications;
• email communications; or
• other appropriate communication methods.

The updated Privacy Notice becomes effective when published unless otherwise stated.

15. Contact Us

If you have questions, requests, concerns, or complaints regarding this Privacy Notice or TOPDON's processing of personal information, please contact the applicable TOPDON entity responsible for your region or service.

TOPDON TECHNOLOGY Co., Ltd.

Address:
20th and 25th Floors, Qianhai Shimao Tower, No. 3040, Xinghai Avenue, Nanshan Street, Qianhai Shenzhen-Hong Kong Cooperation Zone, Shenzhen, Guangdong, P.R. China

Email:
support@topdon.com

HK Topdon Technology Co., LIMITED

Address:
ROOM 2512, WELL FUNG INDUSTRIAL CENTER, NO.68 TA CHUEN PING STREET, KWAI CHUNG, NT, HONG KONG

Email:
support@topdon.com

TOPDON TECHNOLOGY USA INC.

Address:
114 Clinton Road, Fairfield, New Jersey 07004, United States

Email:
support@topdon.us

TOPDON EUROPE S.L.

Address:
Planta 2ª puerta 1ª de la Escalera B, C/ de Sant Elies, 29, 35, 08006 Barcelona, Spain

Email:
support.eu@topdon.com

TOPDON AUSTRALIA PTY LTD

Address:
198 Newnham Road, Mount Gravatt East, Queensland, 4122, Australia

Email:
support.au@topdon.com