This Privacy Policy (the "Policy") is effective as of January 1, 2020 (the "Effective Date") and pertains to ARROW Brands Holdings, Inc. (collectively, "ARROW", "we", and "us").

This Policy describes ARROW's practices with respect to information we collect and receive from users of our websites, social media pages, and emails (the "Site") and in the process of fulfilling orders and performing customer service (together with the Site, the "Services"), including the categories of information collected, how that information is used, and with whom that information is shared.

By accessing and using the Services, you agree and consent to the collection, maintenance, use, and disclosure of your Personal Information by BuBuBear. If you do not agree to the terms of this Policy or do not consent to the collection, maintenance, use, and disclosure of your Personal Information (as defined below) by BuBuBear as described within this Policy, you should leave the Site and stop using our Services immediately.


The Sites are general audience websites. We do not intentionally collect Personal Information from users of this Site who are under the age of thirteen (13). If we become aware that a user of our Site is under the age of thirteen (13) and has provided Personal Information to us by using our Site (e.g., placing an order or entering a sweepstakes, contest or other promotion, etc.), we will remove that child's Personal Information from our files. Where necessary, we may use such information to provide notice to the parents of the users under the age of thirteen (13) who are using the Sites.


"Personal Information" is any information that identifies, relates to, or describes, directly or indirectly, a particular individual, such as your first and last name, your postal address and zip code, your e-mail address, your telephone number, your hobbies and interests, and/or information regarding your purchases.

We collect Personal Information through our Sites, when delivering products, customer service and otherwise, and use it for typical business management, operational and commercial purposes (including to defend and protect us and others from harm or legal claims, and as required by applicable law) and as described more specifically below:

Submitted through a Site. We may collect Personal Information from you if you register with our Site, sign up for our newsletter, purchase products on our Site, enter a sweepstakes, contest, or other promotion, submit a rebate or coupon request, or otherwise voluntarily provide such information to us (e.g., via our "Contact Us" webpage or in connection with ratings, reviews, requests for advice, suggestions, testimonials, or any user-generated content, such as photographs and/or videos).

Personal identifiers. We receive personal identifiers (such as your name, phone number, email address, billing address, shipping address, password, device ids, and IP address) and use them to respond to requests, send you newsletters and other requested information, process rebate or coupon requests, fulfill and deliver orders for products and services, deliver product samples, process returns or exchanges, contact you or others about an order or delivery, facilitate surveys, product reviews, product ratings, promotions, sweepstakes, and contests, manage accounts and preferences, manage accounts, communicate with you for marketing purposes for ARROW or on behalf of its marketing partners, and facilitate personalized online advertising and informational communications (such as for warranty and product issues). We will also create a customer number when you make a purchase so we can identify you in our systems.

Personal characteristics. We receive personal characteristics (such as your date of birth and gender) when you submit it to sign up to receive newsletters and offers or to participate in a contest. We use such information to send you information we think is relevant to you, personalized online advertising, and determine eligibility for contests.

Financial information. We may receive your payment card related information when you make payments to us, and we will provide it to our payment processor. We also receive information about completed purchases from our payment processor when you make a purchase.

Commercial transaction information. We collect and generate commercial transaction information (such as records of products and services purchased, frequency of delivery, and quantity of items purchased) when you make purchases on a Site. We use this information to deliver and fulfill your orders, process your returns or exchanges, improve our service and product offerings, tailor our marketing efforts and administer accounts, and for internal operations and reporting purposes.

Message and product review content. We collect the messages you submit through contact, sign-up, surveys, purchase and product review forms on a Site. We use this information to respond to and fulfill your requests, better understand your needs and preferences, enhance and personalize our product offerings to you and improve the Sites and our service and product offerings.

Inferences from the information listed above. We will use the information listed above to draw inferences about your preferences (such as your preferred brands) to help us provide you with personalized content and offers and help us develop and provide better products and services.

Received to Deliver an Order. When you submit an order for ARROW's products from a retailer or other company, the retailer or other company may send us personal identifiers and commercial transaction information so we can ship the products you purchased directly to you and for the purposes listed above.

Automatic Collection of Device and Site Usage Information. We and our service providers and third-party partners, such as advertising networks, social media widgets, and analytics providers, may automatically collect Personal Information using cookies and similar technology when you use a Site and our emails. We use this information to provide and improve our Sites, systems, and order processing, for anti-fraud purposes, to tailor your experience on our Sites and our marketing efforts, and to create aggregate internal reports on website usage and activity, such as views of certain products. These additional categories may consist of:

Online identifiers. We and our service providers and third-party partners may collect your IP address and other device and online identifiers when you use the Sites. In addition to the uses described above, we may use this information to determine the city, state and country in which you are located.

Website activity information. We and our service providers and third-party partners may monitor and collect Site usage activity information and device characteristics, such as website clicks, content and page views, the website each visitor visited prior to our website, the search engine and search terms that you used, and information about your previous visits to our Site, domain type, browser version, the length of your visit, your Internet service provider, the language settings on your computer, and/or certain software (e.g., Java support).

Inferences from the information listed above. We and our service providers and third-party partners will use the information listed above to draw inferences about your preferences (such as your preferred brands) to help us provide you with personalized content and offers and help us develop and provide better products and services.

An "HTML Cookie" is a small amount of data that is sent to your browser from a webserver and stored on your computer's hard drive. HTML Cookies provide a means for websites that you visit to keep track of your online usage patterns and preferences. Among other things, HTML Cookies help us identify returning users and customize our services to a user's needs. By understanding which areas of the Site a user has visited, HTML Cookies allow us to present information, products, and specials that may be of the user's interest.

ARROW may also use "Flash Cookies" which tracks a person's Internet use across multiple websites and are not deleted or controlled by users in the same manner as standard HTML Cookies. You can see a list of cookies and similar technology used on a Site by clicking on the Cookie Notice link in the footer of the Site.

As a visitor to the Sites, you may have the option to deactivate the ability of us and our third-party partners to analyze your browsing and purchasing behavior on our website. We currently use Google Analytics to collect and process certain website usage data.

When you opt out of personalized advertising, you may continue to see online advertising on the Sites and/or our ads on other websites and online services. Since this opt-out relies on cookies, if you delete your cookies, you will need to opt-out again.

De-identified or Aggregated Information. We de-identify and/or aggregate data we receive and may use and disclose it for any business or commercial purpose.


We share any of the categories of Personal Information we receive (listed above) for our business and commercial purposes and as more specifically described below.

Service providers. We share any of your Personal Information with service providers that provide services to us, including to help us conduct maintain our databases and Sites, administer emails, facilitate product registration, and perform marketing and advertising.

Third parties. We also share any of your Personal Information with third parties to help us provide products and services to you such as fulfilling and delivering orders, processing payments, facilitating and publishing product ratings and reviews, social media functions, product sampling, and administering drawings or contests. In these situations, you are using and directing us to intentionally disclose Personal Information (including personal identifiers and financial information) so our products and services can be provided to you and we can respond to your requests.

Public. If you choose to participate in a survey, product review or rating, or rate a review as helpful or not helpful, you may be providing information to a third party that we use to process product ratings and reviews. Product ratings and reviews may be published on the Sites, in emails, on television, and on social media platforms. Published ratings and reviews may identify the author's review nickname and locale. In these situations, you are using and directing us to intentionally disclose Personal Information (including personal identifiers) so your product ratings and reviews can be available to the public.

Legal and similar disclosures. We may disclose Personal Information about you with law enforcement, the courts, our advisors, attorneys, and others who participate in the legal process, if necessary to do so by law or based on our good faith belief that it is necessary to enforce or apply our Site Terms of Use, conform or comply with the law or is necessary to protect us, the users of the Sites, or others.

Merger, sale, or other asset transfers. In the event of a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another business unit (whether by private sale, through operation of law, as part of a divestiture plan, or otherwise), we will provide any Personal Information (including commercial transaction information) associated with each such business unit to the persons and/or entities assuming control of such business unit and our advisors or as otherwise necessary to complete the transaction as permitted by law or contract.

Do Not Track Disclosure. ARROW does not track users' behavior across websites for the purpose of serving targeted ads, and, the Site does not respond to browser Do Not Track (DNT) signals.


Information transmitted on the Internet and/or stored on systems attached to the Internet is not 100% secure. As a result, we do not ensure, warrant, or guarantee the security or integrity of such information. We take steps in an effort to treat your information securely and in accordance with this Privacy Policy. However, we will not be responsible for disclosure of any information due to errors in transmission or the unauthorized acts of third parties.


Certain jurisdictions impose specific legal requirements and grant data subject rights with respect to Personal Information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete Personal Information we have about you, or to consent or withdraw consent to certain uses or sharing of Personal Information. When you make a request, we may require that you provide information and follow procedures so that we can validate a request you make before responding to it. We will respond to your request within the time period required by applicable law. However, we may not always be able to fully comply with your request, and we will notify you in that event. As permitted by applicable law, we may charge a reasonable fee to help cover the cost of responding to your request, and we will inform you of the fee before completing your request. Specific provisions for some jurisdictions are set forth below.

For other jurisdictions, please direct your request to the address below.

ARROW Brands, Inc.

Attention: 205 Shuanggao Rd.

Qiqiao Ind. Park, Gaochun District

Nanjing, Jiangsu, China


You may choose not to provide Personal Information to us by leaving the Site immediately.


If you are using the Services, you agree to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy. If you are located in the European Economic Area, you may have the option of visiting the version of the Sites intended for individuals in that location.


We reserve the right to revise this Policy at any time. When we do, we will give you notice of the revised Policy by posting it on the Site and by updating the Effective Date at the top of the Policy. If we make any material changes, we will let you know through the Site, by email, or other communication. You are responsible for regularly reviewing the current Policy. The most current version of the Policy may be reviewed by clicking on the "Privacy" or "Privacy Policy" hypertext located at the bottom of the Site. Your continued use of the Site after we post any revisions constitutes your agreement to any such revisions. If any such revisions are unacceptable to you, do not access the Site and do not submit any information to us.


While you are using a Site, you may be linked or directed to other third party sites outside of our Site that are beyond our control. Each of these third party sites may have a privacy policy that differs from ours. For example, you might click on a link or banner advertisement that takes you off of our Site. These links and banners may take you to the sites of advertisers, sponsors, and co-branding partners. It is your responsibility to review the privacy policies of those sites. We are not responsible for any actions or policies of such third parties.


We welcome your comments regarding this Policy. If you have questions or concerns regarding this Policy, please contact us by regular mail at the following address:

For other jurisdictions, please direct your request to the address below.

ARROW Brands, Inc.

Attention: 205 Shuanggao Rd.

Qiqiao Ind. Park, Gaochun District

Nanjing, Jiangsu, China

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