Effective Date: June 16, 2026

Operator: Shenzhen UWELL Technology Co., Ltd.

Contact Email: service@uwellcrew.com

1. Scope

This Privacy Policy explains how UWELL CREW collects, uses, discloses, stores, protects, and otherwise processes personal information in connection with the UWELL CREW website, membership program, rewards program, product registration functions, referral features, user-generated content features, and related services in Canada.

This Privacy Policy is intended to support compliance with Canada’s private-sector privacy framework, including PIPEDA, and to address website and technology-based collection disclosures expected under Quebec Law 25 where applicable.

By using UWELL CREW, creating an account, registering a product, submitting content, or otherwise interacting with the Program, you acknowledge this Privacy Policy and any related consent choices you make.

2. Who This Policy Applies To

This Privacy Policy applies to:

visitors to the UWELL CREW website;
individuals who create or attempt to create an account;
members of the UWELL CREW program;
individuals who register products;
individuals who receive or send referral-related communications;
individuals who submit reviews, photos, videos, comments, or other content;
individuals who contact customer support or otherwise communicate with UWELL CREW.

3. Personal Information We Collect

Depending on how you interact with UWELL CREW, UWELL may collect the following categories of personal information:

Identity and profile information, such as name, date of birth, province or territory, age-confirmation status, username, and account ID.
Contact information, such as email address, phone number, shipping address, and billing-related contact details.
Account and membership information, such as enrollment date, tier status, points balance, rewards activity, referral status, and account preferences.
Product registration information, such as product model, serial number, batch or identifier data, proof of purchase, retailer information, purchase date, uploaded images, and related verification records.
Transactional and fulfillment information, such as reward redemption history, shipment details, delivery status, and customer service records.
Communications data, such as email consent status, SMS consent status, unsubscribe records, communication preferences, and message history.
Technical and usage information, such as IP address, browser type, device identifiers, operating system, session logs, pages visited, clickstream data, and interaction data collected through cookies or similar technologies.
Content submissions, such as reviews, photos, videos, testimonials, comments, and related metadata.
Risk, compliance, and fraud-prevention data, such as account verification results, suspicious activity flags, duplicate-account checks, and abuse-prevention records.

4. How We Collect Personal Information

UWELL may collect personal information:

directly from you when you fill out forms, create an account, verify age, register a product, redeem a reward, submit UGC, contact support, or opt in to marketing;
automatically through your use of the website and related technologies, including cookies, pixels, logs, and analytics tools;
from service providers that support hosting, analytics, communications, fulfillment, moderation, fraud screening, and customer service;
from retailers, distributors, logistics providers, or verification partners where needed to validate product registration, fulfillment, or fraud prevention;
from referral flows and campaign tools when you participate in allowed referral activities.

5. Why We Collect and Use Personal Information

PIPEDA requires organizations to identify the purposes for which personal information is collected, and to limit collection, use, disclosure, and retention to those purposes.

UWELL may collect, use, and process personal information for the following purposes:

to create, administer, and secure your account;
to determine membership eligibility, including age and province eligibility;
to operate the loyalty, points, referral, and rewards features;
to verify product registrations, product authenticity, and eligibility for points or benefits;
to fulfill rewards, ship merchandise, and provide customer support;
to communicate with you about your account, transactions, product registration, security, legal notices, and service messages;
to send marketing communications where you have provided the required consent or where otherwise permitted by law;
to operate surveys, engagement campaigns, contests, or sweepstakes where offered;
to moderate, display, reuse, or administer UGC in accordance with applicable terms and permissions;
to prevent fraud, abuse, duplicate registrations, unauthorized access, and other misuse;
to improve website performance, user experience, campaign effectiveness, and product or service quality;
to comply with legal, regulatory, tax, audit, dispute-resolution, and recordkeeping obligations;
to establish, exercise, or defend legal claims.

6. Consent

Under PIPEDA, consent is a core requirement for the collection, use, and disclosure of personal information, subject to limited legal exceptions.

UWELL will seek consent in a manner appropriate to the sensitivity of the information and the context of collection.

Depending on the circumstance, consent may be express, implied, or obtained through a clear affirmative action where permitted by law.

Express consent will generally be used for sensitive activities such as marketing opt-in, optional profiling fields, certain tracking technologies where required, and the submission of UGC for broader reuse.

You may withdraw consent to certain uses of personal information at any time, subject to legal or contractual restrictions and reasonable notice.

Withdrawing consent may limit UWELL’s ability to provide some features, including parts of the membership program, rewards fulfillment, product verification, or marketing communications.

7. Marketing Communications

UWELL may send you transactional or relationship messages related to your account, membership, product registration, reward fulfillment, security alerts, policy notices, and other service-related matters.

UWELL will send promotional or marketing electronic messages only where the required consent or other lawful basis exists under applicable Canadian law.

Marketing messages will include the sender’s identification information, contact information, and an unsubscribe mechanism where required by law.

You may unsubscribe from marketing emails or SMS at any time using the unsubscribe method provided in the communication or available account settings.

Unsubscribing from marketing does not prevent UWELL from sending non-marketing service or compliance communications where permitted by law.

8. Cookies and Similar Technologies

UWELL may use cookies, pixels, SDKs, tags, local browser technologies, and similar tools to operate the website, remember preferences, maintain sessions, measure traffic, understand engagement, detect abuse, and support marketing and analytics.

These technologies may collect technical and usage information such as IP address, browser type, device information, referral source, session behavior, and pages viewed.

Where required by applicable law, UWELL will provide a cookie banner, consent tool, or similar control for non-essential cookies and tracking technologies.

Quebec privacy guidance is stricter for technology-based collection and tracking disclosures, and organizations collecting personal information through technological means are expected to publish a clear website notice addressing those practices.

You may manage cookie preferences through UWELL’s consent tools where available and through your browser settings, although disabling certain technologies may affect site functionality.

9. Children and Age-Restricted Use

UWELL CREW is intended only for individuals who are of legal age to purchase vaping products in their province or territory of residence.

UWELL does not knowingly collect personal information from individuals who are under the applicable legal age for the Program.

If UWELL learns that personal information has been collected from an ineligible minor, UWELL may delete the information, deactivate the account, and take any other appropriate compliance action.

10. How We Disclose Personal Information

PIPEDA requires limiting disclosure to the purposes for which information was collected, unless further consent is obtained or disclosure is otherwise required or permitted by law.

UWELL may disclose personal information to:

service providers that host, secure, maintain, analyze, support, moderate, or operate the platform;
email, SMS, CRM, analytics, cloud, identity, fraud-prevention, shipping, and customer-service vendors;
logistics, warehouse, and fulfillment providers to process reward shipments;
payment, reimbursement, tax, or finance support providers where relevant;
professional advisers, including lawyers, auditors, insurers, and compliance consultants;
regulators, courts, law enforcement, or government bodies where required or permitted by law;
counterparties involved in a merger, acquisition, reorganization, financing, or sale of all or part of the business, subject to appropriate safeguards where required.

UWELL does not sell personal information for cash consideration.

If UWELL ever uses data-sharing practices that require a separate opt-in or opt-out under applicable law, UWELL will provide the required notice and control.

11. Service Providers and Cross-Border Processing

An organization remains accountable under PIPEDA for personal information transferred to third parties for processing on its behalf.

UWELL may use service providers located inside or outside Canada for hosting, storage, analytics, communications, moderation, support, and fulfillment.

As a result, personal information may be processed in jurisdictions outside your province or outside Canada and may be subject to the lawful access requirements of those jurisdictions.

UWELL uses contractual and organizational measures designed to require service providers to protect personal information and process it only for authorized purposes.

12. Data Accuracy

PIPEDA requires personal information to be as accurate, complete, and up to date as necessary for the purposes for which it is used.

UWELL asks users to provide accurate information and to update account details when they change.

UWELL may update certain records where needed for fraud prevention, fulfillment, compliance, or correction of verified errors.

13. Retention

PIPEDA requires organizations to retain personal information only as long as necessary for the identified purposes, subject to legal or business recordkeeping obligations.

UWELL retains personal information only for as long as reasonably necessary to operate the Program, fulfill the purposes described in this Privacy Policy, resolve disputes, enforce agreements, maintain appropriate records, and comply with legal obligations.

Retention periods may vary depending on the type of information, the sensitivity of the information, whether an account remains active, whether a reward or registration is under review, whether consent has been withdrawn, and whether records are needed for fraud prevention, tax, audit, litigation, or regulatory compliance.

When personal information is no longer required, UWELL may delete, anonymize, aggregate, or securely destroy it, subject to applicable law and legitimate recordkeeping requirements.

14. Safeguards

PIPEDA requires organizations to protect personal information with safeguards appropriate to the sensitivity of the information.

UWELL uses administrative, technical, and physical safeguards designed to protect personal information against loss, theft, unauthorized access, unauthorized disclosure, copying, misuse, modification, or destruction.

These safeguards may include role-based access controls, least-privilege permissions, password and authentication controls, encryption in transit and where appropriate at rest, logging, monitoring, staff training, vendor controls, and secure disposal practices.

No system can be guaranteed to be completely secure, and UWELL cannot promise absolute security.

15. Confidentiality Incidents and Security Events

Where a privacy or confidentiality incident occurs, UWELL may investigate, contain, document, remediate, and notify affected individuals or regulators where required by applicable law.

Quebec Law 25 guidance expects organizations to keep a register of confidentiality incidents and to notify the Quebec regulator and affected persons in certain circumstances.

UWELL may maintain internal incident records, assess risk of harm, and take reasonable steps to reduce the risk of recurrence.

16. Individual Access and Correction Rights

PIPEDA gives individuals the right, subject to certain exceptions, to request access to personal information held about them and to request correction of inaccurate or incomplete information.

You may request access to your personal information, ask how it has been used or disclosed, and request correction where appropriate.

UWELL may need to verify your identity before processing an access or correction request.

UWELL may decline or limit a request where an exception under applicable law applies.

If UWELL refuses a correction request, you may ask UWELL to record your disagreement where required by law.

17. Privacy Contact and Complaints

PIPEDA’s accountability principle requires organizations to designate an individual responsible for privacy compliance and to make information about privacy practices readily available.

Questions, access requests, correction requests, consent-withdrawal requests, and privacy complaints may be directed to UWELL’s Privacy Contact or Privacy Officer at:

Email: service@uwellcrew.com

UWELL will review privacy complaints and respond within a reasonable period in accordance with applicable law.

18. Quebec-Specific Technology Notice

Where UWELL collects personal information through technological means, UWELL may provide additional just-in-time notices, confidentiality notices, or interface disclosures on the website or app.

Where required by applicable law, privacy-protective settings for technological products or services offered to the public should be enabled at the highest level of confidentiality by default.

If UWELL launches or materially overhauls an information system involving personal information, UWELL may conduct privacy impact assessments where required by applicable law.

19. Changes to This Privacy Policy

UWELL may update this Privacy Policy from time to time to reflect legal, operational, technical, or business changes.

The updated version will be posted with a revised effective date.

Where required by law, UWELL will provide additional notice or obtain renewed consent for material changes.

20. Contact Information

For privacy questions or requests, contact:

UWELL CREW Privacy Contact / Privacy Officer

Email: service@uwellcrew.com

UWELL CREW PRIVACY POLICY