Privacy policy

Last updated — 1 September 2026

Who is the controller

Controller	Unykonn
Address	Building 16-1, No. 25 Chuangxin East Road, Ningbo Southern Coastal New Area, Ninghai County, Ningbo City, Zhejiang Province, People's Republic of China
Contact	info@unykonn.com
Company name	Unykonn
Operating site	Building 16-1, No. 25 Chuangxin East Road, Ningbo Southern Coastal New Area, Ninghai County, Ningbo City, Zhejiang Province
Unified Social Credit Code	91330226MA28YHQD14
General contact	info@unykonn.com

Why this notice applies to you in the EU

The controller is established in China and has no establishment in the European Union. This notice applies under art. 3(2)(a) GDPR, because the website offers goods and services to people located in the Union.

Where your message is read

Messages sent to info@unykonn.com are read at the manufacturing site in Ningbo, China, and nowhere else. Your message, and everything you put into it, is processed there.

Why this is not an international transfer

When you write to us you send your data directly to a controller outside the European Union. Under the EDPB Guidelines 05/2021 on the interplay between art. 3 and Chapter V, this is not a transfer in the sense of the Regulation: the data are not passed on by an exporter, they are collected directly from you by a controller already bound by the GDPR through art. 3(2). No standard contractual clauses apply to it.

That does not make the destination irrelevant. Your data is processed in China, under a legal system whose rules on access by public authorities differ from those in the Union. We state it plainly so you can weigh it before writing, and we ask for no more than we need to answer you.

Chinese law

Personal information of people located in China is also subject to the Personal Information Protection Law. Because the mailbox is read in China and nowhere else, that information does not leave the country: the cross-border rules of art. 38 and 39 PIPL do not apply to it.

What data we process, and why

a. Contact and design-in requests

When you write to us we process the identification and contact data contained in your message, plus the technical content of your request. We do not operate a contact form: messages reach us as ordinary email.

• Purpose — replying to your request and, where applicable, taking steps prior to entering into a contract.
• Legal basis — art. 6(1)(b) GDPR (pre-contractual measures).
• Retention — 24 months from the last exchange, if the enquiry does not lead to a business relationship. If it does, the correspondence follows the commercial records and is kept for 10 years, the period for which accounting documents must be retained.
• Providing the data is optional, but without it we cannot reply.

b. Navigation data

Web servers record technical data by their own operation: IP address, browser, pages requested, timestamps. These are used for security and to keep the service running, and are not used to identify visitors.

• Legal basis — art. 6(1)(f) GDPR (legitimate interest in the security of the service).

c. Statistics

Only with your consent, and only if a measurement tool is active. See the cookie policy for what is installed and what is not.

• Legal basis — art. 6(1)(a) GDPR (consent), revocable at any time.

Sharing within the group

Unykonn operates within an industrial group alongside Circular Identity and Reflexallen. A request that concerns materials or integrated systems may be handled by the company of the group that is competent for it, so that you get a technical answer rather than a referral.

• Legal basis — art. 6(1)(b) GDPR for handling your request, and art. 6(1)(f) for the group's legitimate interest in internal administration, expressly recognised by recital 48 GDPR.
• Scope — Circular Identity, for questions that concern compounds and recycled-content materials, and Reflexallen, for questions that concern integrated systems and assemblies. Only the content needed to answer is passed on, and only when the question actually falls to them. Your data is not shared for commercial or marketing purposes, and no group company adds it to a mailing list.

Each group company acts as a separate controller for what it receives: there is no joint controllership arrangement between them, and each answers for its own processing under its own privacy notice.

Who else can access the data

This site is static. It loads no scripts, fonts or resources from third parties, runs no analytics and has no forms: browsing it sends nothing to anyone outside this domain.

Two categories of supplier process personal data on the controller's instructions, as processors under art. 28 GDPR, and for no purpose of their own:

• the hosting provider of this website, which keeps IP addresses and technical request data in its server logs;
• the email service provider that runs info@unykonn.com, which stores the content of your message and its metadata.

We will name them on request. No other supplier has access. We do not sell personal data and we do not disclose it for third-party marketing.

Your rights

Under articles 15 to 22 GDPR you may request access, rectification, erasure, restriction, portability, and object to processing based on legitimate interest. Where processing is based on consent you may withdraw it at any time, without affecting the lawfulness of processing carried out beforehand.

Write to info@unykonn.com. You also have the right to lodge a complaint with a supervisory authority — in Italy, the Garante per la protezione dei dati personali.

Changes

This policy may be updated. The date at the top of this page always shows the version in force.