Privacy Policy

Last updated: October 1st, 2026

1. Introduction

Welcome to the VAROLO related products/services (hereinafter referred to as "VAROLO") provided by OKAI GmbH , a company incorporated in the Germany, whose registered number is HRB 104896, located at Niederkasseler Lohweg 189, 40547 Düsseldorf, Germany (hereinafter referred to as "we," "us," or "the Company") .

We are the data controller of your personal information and are responsible for determining how and why your personal information is processed. We and our parents, and affiliated entities fully understand the importance of your privacy and handling your data responsibly.

This Policy is closely related to your use of our services. We recommend that you read and understand the entire contents of this Policy carefully, and only commence use after confirming that you fully understand and agree to it. If you are a minor, your guardian must read this Policy carefully and consent to your use of our products or services in accordance with this Policy. We have marked in bold those provisions in this Policy that are of significant relevance to your rights and interests, in order to draw your attention thereto.

By accessing and using our services, you agree to be bound by all of the terms and conditions set forth in this policy. If you do not agree to these terms, please do not access or use our Services. As used herein, the term “Service” or “Services” includes our websites, content, applications, and other online products and services where this Privacy Policy is posted (including products, interactive features, events, newsletters, advertisements, and other services).

If you have provided your consent to the collection, processing, and transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances.

For any questions regarding how we manage your personal information, your privacy, or this Privacy Policy, please contact us:

By email: support@varologear.com

This Privacy Policy explains how we collect, use, share, and safeguard your data when you use our products, services, websites, and mobile applications. If we request that you provide certain information to verify your identity when using VAROLO, we will strictly use such information in accordance with this Privacy Policy and our User Terms and Conditions.

In this Privacy Policy, "personal information" refers to data that can identify a specific individual, either alone or when combined with other information. Such personal information may include information you provide to us, device information (including operating system and device model), IP address, carrier information, network information, application information (package name and version), and other similar data.

When you use VAROLO, we commit to complying with the European Union's General Data Protection Regulation (GDPR) and any locally applicable data protection laws. We undertake to protect the privacy, confidentiality, and security of your personal information in accordance with applicable laws (including data protection laws in your jurisdiction). At the same time, we commit to ensuring that all our employees and agents fulfill these obligations.

This policy applies to the use of:

Our website https://www.varologear.com (the "Website")
The services we offer (the “Services”), such as, but not limited to, placing an order and purchasing through our platforms, getting in touch with customer support (email, form, or via channels), enabling IoT aka Smart Connect features, etc.
VAROLO App (the “App”),

It does not apply to third-party services, websites, or platforms that may be linked from our services. Their handling of personal data is governed by their own privacy policies.

2.1 We collect information about you in the following ways:

You authorize us to collect your personal information through the following methods:

2.1.1 We will collect and store information that you voluntarily provide to us when you browse or access the VAROLO Website and when you use VAROLO.

2.1.2 We will collect and store information about you that we record in the course of providing VAROLO to you.

2.1.3 We will collect and store information that you actively submit or provide as feedback through our customer service personnel and other channels.

2.1.4 We will collect and store information about you that our affiliated companies, business partners, and third-party independent data sources have lawfully obtained.

2.1.5 We will read your account Information when you register for an account.

2.2 The categories of information we collect

2.2.1 Information You Share with Us

Account Information: When you create a VAROLO Account, we collect your name, email address, date of birth, gender, username, and password.

Profile Information: You can choose to provide additional information for your profile, such as a photo, location, and activity data.

Orders and Payments Information: If you make a purchase, we collect Recipient name, address, contact details, items ordered, order number, shipping/billing details.

Communications: If you contact us or sign up for our newsletter, we collect your email address and any other information you provide in your communication.

2.2.2 Information Collected Automatically

Device and Usage Information: We collect information about your device and internet connection automatically, such as your IP address, operating system, and browser type. We also collect information about your device type, mobile ad identifier, the time and length of your visit, the website you came from, and the topics of your clicks and scrolls.

Usage logs: Crashes, errors, diagnostics, user behavior patterns

Cookies and Similar Technologies: We use cookies and similar technologies to track your activity on the Site and personalize your experience.

You can manage your cookie settings through your browser or device preferences.

3. How We Use Your Information and Legal Basis

3.1 Legal Basis for processing your personal Information

If you reside in the European Economic Area (“EEA”), United Kingdom (“UK”), or a jurisdiction with similar legal requirements, we process your personal information based on one or more of the following legal grounds:

3.1.1 Consent: When you consent to the processing of your personal information, including for example: when you register an account, download our apps, or sign up for our newsletters, offers, and other promotional events or communications.

3.1.2 Performance of a Contract: When the processing is necessary to perform a contract with you or to take steps at your request, including, for example: (i) to facilitate product purchases, process payments, and deliver goods ordered; (ii) to provide customer support and warranty services; (iii) to provide our Services and other features that you may request or enable; and (iv) to perform and enforce the terms of our agreements with you.

3.1.3 Legal Obligation: When the processing is necessary to comply with a legal obligation, including a court order, subpoena, or any other applicable laws.

3.1.4 Protection of Vital Interests: When the processing is necessary for protecting the vital interests of you or another individual. For example, to prevent and respond to any fraud, abuse, or other unlawful activities that may harm our users or other natural persons.

3.1.5 Legitimate Interests: When the processing is necessary for our (or a third party's) legitimate interests, provided these interests are not overridden by your interests or fundamental rights and freedoms. For example, (i) to analyze trends, enhance customer experience, and improve and develop our Services; and (ii) to detect and resolve any bug, security vulnerabilities and technical issues.

3.2 How We Use Your Information

We may use your Information for the following purposes, and on the basis of the corresponding legal basis for processing:

Provide, Tailor, and Improve the Services: We use your personal information to perform our contract with you, including processing payments, fulfilling orders, managing your account, arranging shipping, handling returns and exchanges, remembering your preferences and items you are interested in, and personalizing your shopping experience (e.g., recommending products related to your purchases). We also use your information to continuously improve our services.

Marketing and Advertising: With your consent, we may send you marketing and promotional communications via email, text message, or postal mail, and show you advertisements on our services or other websites based on your activity (e.g., items you have viewed or added to your cart). We strictly abide by the data protection laws in your location (which may require independent express consent), and will only use your personal information with your prior express consent or when you indicate through actions or instructions that you do not object. You have the right to terminate our use of your personal data intended for direct marketing. If you no longer wish to receive certain types of emails, you can email support@varologear.com. We will not transfer your personal data to our business partners for their direct marketing purposes. You can unsubscribe at any time.

Security and Fraud Prevention: We use your personal information to verify your account, ensure a secure payment and shopping experience, and detect, investigate, or prevent fraudulent, illegal, or malicious activities. You are responsible for keeping your account credentials safe. We strongly recommend that you do not share your username, password, or other access details with anyone.

Communicating with You: We use your personal information to provide customer support, respond to your inquiries, and maintain our business relationship with you.

Legal Reasons: We may use your Personal Information to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

4. How We Share Your Information

Except for the following exceptions, we will not share your personal information with any other company, organization or individual:

4.1 Where you have given your prior express consent.

4.2 Information sharing with third-party service providers: We may, from time to time, disclose your personal information to third-party service providers (such as our mailing stores, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and promotion service providers, and agents acting on behalf of VAROLO) and affiliated entities in accordance with this Privacy Policy and applicable local data regulations, in order to provide the products or services you have requested.

In each of the circumstances described in this section, we ensure that your personal information will be shared only in accordance with your authorization. Your authorization to us will enable sub-processors to process your personal information. You should understand that in any of the situations described below, when we share your personal information with third-party service providers, we will stipulate the practices and obligations of such third-party service providers by contract, requiring compliance with applicable local data protection laws and this Privacy Policy.

If you no longer wish to permit us to share this information, please contact us by sending an email to support@varologear.com. Please ensure that you provide your correct contact information so that we may respond to your request in a timely manner. Additionally, we may share de-identified information and statistical data in aggregated form with third parties (such as advertisers on our website) for commercial purposes; we may share general usage trends of our services with them, such as the number of customers within specific groups who purchase certain products or engage in certain transactions.

Service Providers: We rely on trusted third-party companies to help us run our business, including payment processing, order shipping, marketing support, analytics, and customer service. These providers are bound by contract to handle your information only on our behalf and to keep it secure.

Analytics Partners: We work with analytics tools such as Google Analytics and Facebook to better understand how users interact with our services. These partners may use cookies and similar tracking technologies to collect information about your activity.

Business Transfers: If we are involved in a merger, acquisition, or sale of all or part of our assets, your information may be transferred to the new owner as part of that transaction.

4.3 Legal Compliance and Protection: We may share your information without further consent when required by law, regulation, legal process, or a government request. We may also disclose it to protect our rights, property, or safety, or those of others, to comply with requirements of local governmental authorities, or to assist in the investigation of illegal activities, as permitted by law.

5. How We Protect Your Information

The security of your Information is important to us. We protect your personal data through technical, administrative, and physical safeguards — such as encrypted communications, access controls, anonymisation where possible, and regular system monitoring. That said, no online system is entirely risk‑free. Please help keep your account safe by using a strong password and secure devices.

6. Your Data Protection Rights

If you live in the EU or EEA, under applicable data protection laws (including the GDPR), you have the following rights in relation to your personal information. We will actively respond to your requests to exercise these rights:

6.1 Right of Access

You have the right to obtain from us confirmation as to whether or not your personal information is being processed, and, where that is the case, access to such information and information about the related processing activities.

If you wish to request access to the personal data we hold about you, or if you believe that any information we hold about you is incorrect or incomplete, please contact us as soon as possible by letter or by sending an email to the email address provided below: support@varologear.com.

6.2 Right to Rectification

If you find that the information we hold about you is incorrect or incomplete, you have the right to request that we correct or supplement it.

Before processing your request, we may require verification of your identity. Once we have obtained sufficient information to process your request for access to or rectification of your personal information, we will respond to your request within the time limits prescribed by applicable data protection laws.

6.3 Right to Erasure

You have the right to request that we delete your personal information in the following circumstances: the information is no longer necessary; you withdraw consent and there is no other legal basis for processing; you have successfully exercised your right to object; the information has been unlawfully processed; or there is a legal obligation requiring deletion.

6.4 Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal information in the following circumstances: you contest the accuracy of the information (for the period during which we verify its accuracy); the processing is unlawful but you oppose the erasure of the information; we no longer need the information but you require it for the establishment, exercise, or defense of legal claims; or you have objected to processing (for the period during which we verify whether our legitimate interests override yours).

6.5 Right to Data Portability

For personal information that you have provided to us based on consent or for the performance of a contract, and which is processed by automated means, you have the right to receive such information in a structured, commonly used, and machine-readable format, and have the right to transmit it to another data controller.

6.6 Right to Object

You have the right to object at any time to processing based on "legitimate interests" (including direct marketing). We will cease processing unless we demonstrate compelling legitimate grounds for the processing which override your interests.

6.7 Right Not to be Subject to Automated Decision-Making

We will not use your personal information to make decisions based solely on automated processing (including profiling) that produce legal effects concerning you or similarly significantly affect you.

6.8 Right to Withdraw Consent

You may withdraw your consent to the collection, use, or disclosure of your personal information held or controlled by us by submitting a request. This can be done by contacting support@varologear.com. We will process your request within a reasonable time after you make it, and, in accordance with your request, will no longer collect, use, or disclose your personal information thereafter.

Please note that withdrawing your consent may result in certain legal consequences. Depending on the scope of your withdrawal of consent for us to process your personal information, this may mean that you will not be able to enjoy Varolo's products and services.

6.9 Right to Lodge a Complaint with a Supervisory Authority

You have right to complain to a Supervisory Authority (e.g. that of Your usual place of residence or work or place of the alleged infringement).

7. Data Retention

We keep your personal information only as long as needed to deliver our services, meet legal requirements, or fulfil our contract with you.

Contact Information (e.g., your name, email address, and phone number) used for marketing purposes will be kept until you unsubscribe. Once you unsubscribe, we will add your details to our suppression list to avoid sending you any further marketing communications by mistake. The unsubscribe process will be completed within 6 months after the application.

Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.

8. Children's Privacy

Our services are not meant for children under 16. In line with the GDPR, minors under 16 cannot consent alone to the use of their personal data. That means we will not knowingly serve them without proven parental or guardian consent, nor will we knowingly collect data from them. If you are a parent or guardian and think your child has given us personal data, please contact us.

9. International Date Transfers

Please note that we may transfer, store and process your personal information outside the country you live in.

If we transfer your personal information out of the European Economic Area or the United Kingdom, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection. Where such transfers take place, we take appropriate measures to ensure that your data is protected in accordance with this Privacy Policy when it is transferred internationally.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on this website, update the "Last updated" date and provide notice as required by applicable law. Your continued use of or access to the website following the posting of any changes constitutes acceptance of those changes.

10.1 Material Changes: When significant changes involve the purposes of data processing, the means of processing, the identity of the data controller, or other material matters, we will notify you by sending notices to your registered email address, or by other means, and the changes will take effect only after we have obtained your express consent again where required by law.

10.2 Non-material Changes: We will publish the updated policy on our official website, and update the "Last Updated Date" at the top. We recommend that you review this page regularly to obtain the latest information on our privacy practices.

11. Contact Us