Privacy Policy

Effective date: 12 April 2026  |  Last updated: 12 April 2026

Tone Cooling Technology Co., Ltd. (“ToneCooling”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you visit tonecooling.com, communicate with us, or engage with us as a business customer, supplier, or partner.

This Policy is designed to meet the requirements of the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), the California Consumer Privacy Act (CCPA) as amended by the CPRA, the EU / UK General Data Protection Regulation (GDPR), and the Personal Information Protection Law of the People’s Republic of China (PIPL).

1. Who we are

The data controller / “APP entity” for the purposes of this Policy is:

• Legal entity: Tone Cooling Technology Co., Ltd.
• Trading name: ToneCooling
• Registered office: Huizhou, Guangdong, China (Greater Bay Area)
• General contact: info@tonecooling.com
• Privacy contact: privacy@tonecooling.com
• Australian subsidiary: TONECOOLING AUSTRALIA PTY LTD
• ABN: 96 653 174 040  |  ACN: 653 174 040
• Australian location: Victoria 3124, Australia
• Australian phone: +61 420 936 669

ToneCooling is a business-to-business (B2B) manufacturer of custom liquid cooling products. In Australia, ToneCooling operates through its registered subsidiary, TONECOOLING AUSTRALIA PTY LTD (ABN 96 653 174 040), which is an APP entity under the Privacy Act 1988 (Cth). We do not knowingly market or sell to consumers and do not knowingly collect personal information from children under 16.

United States — ToneCooling Texas LLC

For US customers, your personal data is processed by ToneCooling Texas LLC, a Texas Limited Liability Company (TX Filing #806504501), located at 2106 House Ave Suite 677, Cheyenne, WY 82001. We comply with applicable US federal and state privacy laws including the California Consumer Privacy Act (CCPA) and other state privacy regulations. Contact: info@tonecooling.com | +1 (832) 720-7542.

2. What personal information we collect

We collect only the personal information reasonably necessary for our business functions. Categories of information we may collect include:

• Identity & contact data: name, job title, company name, business email, business phone number, postal or shipping address.
• Project & technical data: CAD drawings, specifications, RFQ content, performance requirements, and other engineering details you voluntarily share to obtain a quote.
• Commercial data: purchase orders, invoices, bank account or payment data required to process international payments (handled by regulated banks; we do not store full card numbers).
• Website & device data: IP address, approximate geolocation, browser type, device type, operating system, referring URL, pages viewed, time on page, and interactions.
• Cookies and similar technologies: see our Cookie Policy.
• Communications: records of emails, messages, support tickets, and call notes.

We collect information directly from you when you submit a contact or quote form, email us, or interact with our site. We may also receive information from publicly available business directories, trade shows, or introductions from mutual business partners.

3. How we use personal information

We use personal information for the following purposes, relying on lawful bases including your consent, the performance of a contract, our legitimate business interests, and compliance with legal obligations:

• To respond to enquiries and provide quotes, technical proposals, and samples.
• To manufacture, ship, and invoice products you order.
• To manage supplier, customer, and partner relationships.
• To comply with export control, customs, anti-money-laundering, tax, and accounting laws.
• To maintain website security, prevent fraud, and investigate misuse.
• With your consent, to send direct marketing about related products and industry content. You can opt out at any time (see Section 9).
• To improve our products, website, and service based on aggregated analytics.

4. Cookies, analytics, and advertising

We use strictly necessary cookies to operate the site. With your consent, we also use analytics cookies (e.g. Google Analytics via Google Tag Manager) and may use advertising cookies. Detailed information and opt-out controls are available in our Cookie Policy.

For California residents, please note: to the extent any cookie-based data sharing with third-party advertising partners qualifies as a “sale” or “share” under the CCPA/CPRA, you may opt out at any time using the “Do Not Sell or Share My Personal Information” link or by emailing privacy@tonecooling.com. See our CCPA Notice.

5. Disclosure of personal information

We disclose personal information only where necessary and only to the following categories of recipients:

• Our manufacturing, engineering, logistics, and customer-service staff, on a need-to-know basis.
• Carriers, freight forwarders, and customs brokers for international shipping.
• Payment processors and banks.
• IT, hosting, email, CRM, and analytics service providers bound by written data-processing terms.
• Professional advisers (lawyers, accountants, auditors) under confidentiality obligations.
• Government authorities where required by law, a valid subpoena, court order, or export-control regulation.

We do not sell personal information in the traditional sense (for money). We do not share personal information with data brokers.

6. Cross-border data transfers

ToneCooling is headquartered in China and our servers and service providers are located in multiple jurisdictions including China, the United States, and Europe. When you submit information to us, you acknowledge that it may be transferred to, stored in, and processed in countries other than your own, including China.

Where we transfer personal data from the EU/UK, we rely on the European Commission’s Standard Contractual Clauses (SCCs) and equivalent UK IDTA, together with supplementary measures, where required. Where we transfer personal information from Australia to a foreign recipient, we take reasonable steps to ensure the recipient handles the information consistently with the Australian Privacy Principles, as required by APP 8.

7. Data retention

We retain personal information only for as long as necessary for the purposes for which it was collected, or as required by law. For example:

• Business correspondence and quotes: up to 7 years.
• Contracts, invoices, and tax records: up to 10 years (per accounting law requirements).
• Website analytics data: up to 26 months in aggregated form.
• Marketing opt-in records and unsubscribe lists: as long as needed to honour your preferences.

When information is no longer needed, we delete or anonymise it.

8. Data security

We implement reasonable technical and organisational measures to protect personal information from loss, misuse, unauthorised access, disclosure, alteration, and destruction. These measures include encryption in transit (TLS/HTTPS), access controls, password policies, employee confidentiality agreements, and physical security of our offices and production sites. No method of transmission over the internet is 100% secure; we cannot guarantee absolute security.

9. Your privacy rights

Subject to applicable law, you may have the following rights:

• Access — request a copy of the personal information we hold about you.
• Correction — ask us to correct inaccurate or incomplete information.
• Deletion / erasure — ask us to delete personal information, subject to legal retention obligations.
• Objection / restriction — object to, or restrict, certain processing (e.g. direct marketing).
• Data portability — receive a machine-readable copy of data you provided to us.
• Withdraw consent — where processing is based on consent.
• Opt out of marketing — by clicking “unsubscribe” in any email or emailing us.
• Do Not Sell or Share — California residents: see the CCPA Notice.
• Lodge a complaint — see Section 12.

To exercise any right, email privacy@tonecooling.com with sufficient information to identify you and the request. We will respond within 30 days (or the period required by your local law) and will not discriminate against you for exercising a right.

10. Automated decision-making

We do not use personal information to make decisions that produce legal or similarly significant effects through solely automated means.

11. Children

Our site and services are directed exclusively to business users. We do not knowingly collect personal information from children under 16. If you believe a child has provided us with personal information, please contact us immediately so we can delete it.

12. Complaints and supervisory authorities

If you believe we have breached your privacy, please first contact us at privacy@tonecooling.com. We will investigate and respond within 30 days.

You also have the right to lodge a complaint with a supervisory authority:

• Australia: Office of the Australian Information Commissioner (OAIC) — oaic.gov.au.
• European Union: your national Data Protection Authority.
• United Kingdom: Information Commissioner’s Office (ICO) — ico.org.uk.
• California: California Privacy Protection Agency — cppa.ca.gov.

13. Changes to this Policy

We may update this Policy from time to time. We will post the updated version on this page and revise the “Last updated” date. Material changes will be highlighted on our homepage or by email where appropriate.

14. Contact us

Tone Cooling Technology Co., Ltd.
Huizhou, Guangdong, China (Greater Bay Area)
Privacy enquiries: privacy@tonecooling.com
General enquiries: info@tonecooling.com