PRIVACY POLICY - CHINA

Introduction

SellingPilot ("COMPANY," "we," "us," "our") and its affiliates are committed to protecting and respecting your privacy.

This policy aims to explain how we process your personal information. It also sets out your rights in relation to your personal information and who you can contact for more information or queries.

This website is not intended for children and we do not knowingly collect personal information relating to children. As a user, you must be at least 14 years old to access or use our website. If we become aware that we have inadvertently collected personal information of children under the age of 14, we will delete such information as soon as possible.

Our website may, from time to time, contain links to the websites of our partner networks, advertisers and affiliates. We provide those links for your convenience only, which does not mean that we are fully aware of and endorse their businesses or operational practice. Please note that those websites may have their own privacy policies, and that we do not undertake or assume any responsibility or liability under those policies. Please make sure you check and accept their policies before you provide or instruct us to provide any of your personal information to those websites.

It is important that you read and accept this policy before you allow us to process your personal information so that you are fully aware of how and why we are processing your personal information.

1. BASIC INFORMATION ABOUT US

SellingPilot is the personal information processor and responsible for your personal information.

We have appointed a privacy team who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, or if you have any complaint or report about personal information security issues, please contact our privacy team using the details set out below. We will properly handle your complaint or report in due course within the period required by applicable laws and regulations.

• Email address: [email protected]

2. THE INFORMATION WE COLLECT FROM YOU

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

• Identity information, including name, username or similar identifier, title, date of birth and gender.
• Contact information, including billing address, delivery address, email address and telephone numbers.
• Transaction information, including details about payments to and from you and other details of products and services you have purchased from us.
• Technical information, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, unique device identifier and other technology on the devices you use to access this website.
• Profile information, including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage information, including information about how you use our website, products and services.
• Marketing and communications information, including your preferences in receiving marketing information from us and your communication preferences.

We do not collect any sensitive personal information about you (this includes details about your biometric information, religion, specific identities, medical and health information, financial accounts, personal tracks, as well as the personal information of minors under the age of 14).

Many of our services require some personal information to be collected. You may refer to the purposes of using your personal information set out in How we use your personal information below. If you choose not to provide us with the personal information necessary to enable us to provide certain business functions, you may not be able to use those business functions, but that will not affect your right to use other business functions.

3. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We use different methods to collect personal information from and about you including through:

• Direct interactions. You may give us your personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

  • register to use our website;
  • subscribe to our service;
  • search for a product;
  • place an order on our website;
  • participate in discussion boards or other social media functions on our website;
  • enter a competition, promotion or survey; and
  • when you report a problem with our website.

The information you give us may include your name, address, email address, phone number, personal description and photograph.

• Automated technologies or interactions. As you interact with our website, we will automatically collect technical information about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies. Please see our Cookie Notice for further details.
• Indirect interactions. We may also collect and access your personal information that is provided by third parties who have lawful authorization or that is lawfully and publicly disclosed, such as legal news reports and government information disclosure. The information collected from such channels may include name, email address, usernames, photograph and phone number.

3. HOW WE USE YOUR PERSONAL INFORMATION?

We will only use your personal information when the law allows us to. We will use your personal information according to the specified purposes as set out in the table below:

Purpose or Activity	Type of Personal Information
To register you as a new customer	(a) Identity (b) Contact
To process and deliver your order including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and communications
To manage our relationship with you which will include:(a) Notifying you about changes to our policy(b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and communications
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and communications
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact(c) Technical
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and communications (f) Technical
To use personal information analytics to improve our website, products or services, marketing, customer relationships and experiences	(a) Technical (b) Usage
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and communications

We will only collect and use your personal information that is necessary to fulfil a particular business function at a reasonable minimum frequency.

You understand and agree that the use of certain personal information requires your device permissions (for example, microphone, camera and so on) and that by turning on those permissions, you are authorizing us to collect and use the relevant information corresponding to those device permissions to perform certain business functions. You can turn off the device permissions at any time by logging into your device and checking or unchecking relevant boxes to adjust your device permissions OR by clicking the opt-out links or buttons OR by contacting us. Once you turn off certain device permissions, we will no longer be able to collect or use such information about you or provide you with the business functions that correspond to those permissions, but that will not affect you to use other business functions offered by us.

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. We may use your identity, contact, technical, usage and profile information to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have opted in receiving that marketing.

You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by clicking the opt-out links on any marketing message sent to you OR by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product or service purchase, warranty registration, product or service experience or other transactions.

We will only use your personal information for the purposes for which we collected it as specified in this policy, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and seek your consent.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

5. DISCLOSURE OF YOUR PERSONAL INFORMATION

We may share your personal information with the parties set out below for the purposes set out in How we use your personal information above:

• Any member of our group, which means our affiliates and subsidiaries, our ultimate holding company and its subsidiaries.

• Selected third parties including:

  • business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you;
  • advertisers and advertising networks that require the information to select and deliver relevant advertisements to you; and
  • analytics and search engine providers that assist us in the improvement and optimization of our website.

We may also disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets.
• If SellingPilot or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, assist law enforcement, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of the COMPANY, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We require all third parties to ensure the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

6. CROSS-BORDER TRANSFERS

We share your personal information among SellingPilot's affiliates. This will involve transferring your personal information outside the territory of Mainland China. We ensure your personal information is protected by requiring all our group companies to follow the same rules when processing your personal information.

Many of our third-party service providers are based outside Mainland China so their processing of your personal information will involve a transfer of your personal information outside Mainland China.

Whenever we transfer your personal information out of Mainland China, we will inform you the name and contact information of the recipients, the processing purposes and methods, types of personal information to be transferred and other information as required by laws and regulations and seek your consent. In addition, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will enter into specific contracts with the information recipients and ensure their processing of your personal information is in accordance with the standards required under Chinese laws and regulations, and any other applicable conditions as required by laws.

7. PERSONAL INFORMATION SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

If our physical, technical, or management protection facilities are damaged and we cannot prove that we are not at fault, resulting in unauthorized access, public disclosure, tampering, or destruction of your personal information, thus causing damage to your legitimate rights and interests, we will be held legally responsible. However, considering the characteristics of information technology and cyberspace itself, under certain special circumstances (such as hacker attacks, telecommunications failures and so on), there is still a risk of personal information leakage despite the necessary measures we have taken as stipulated by laws and regulations. Although we are continuously working to enhance and strengthen our security measures to protect your data and personal information from accidents or damage, we cannot always guarantee that your personal information is 100% safe, so please make sure you take offline backup measures.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We strongly recommend that you do not send your personal information via unencrypted email, instant messages, or other unsecure forms of communication. Please use complex passwords to keep your account secure. Except as otherwise provided in this policy, to protect your personal and property security, we specifically remind you not to provide sensitive information, such as your account password, authentication code, communication content, property information, or physiological information to us or any third party providing services to you on our behalf, through public networks.

8. PERSONAL INFORMATION RETENTION

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. We will delete or anonymize your personal information where the processing purpose has been achieved, is impossible to achieve, or where it is no longer necessary to achieve the purpose.

9. YOUR LEGAL RIGHTS

You can exercise the following rights in relation to your personal information:

• Access your personal information held by us and request a copy of the information.
• Request us to update or correct your personal information if it is inaccurate or incomplete.
• Request us to delete your personal information if you no longer use our products or services or under other statutory circumstances, unless we have a legal or regulatory obligation to retain the information.
• Object or withdraw your consent to our processing of your personal information.
• Request us to deregister your account.
• Request us to transfer your personal information to another personal information processor designated by you, provided that such request complies with the conditions prescribed by the competent government authorities.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

You will not have to pay a fee to access your personal information (or to exercise any of the other relevant rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within fifteen (15) business days (or other period required by applicable laws and regulations). Occasionally it could take us longer than fifteen (15) business days if your request is particularly complex or you have made a number of requests. In this case, we will notify you in time and keep you updated.

10. CHANGES TO THE POLICY

We keep our policy under regular review. We may need to update the policy from time to time to comply with applicable laws and regulations or other legitimate purposes. We may separately advise you about the change according to laws. Please pay attention to the notices we post and review the contents of our policy periodically to keep abreast of relevant changes. Please understand that your continued use of our product or service after we post the notice of changes constitutes your acceptance of those changes.

This version was last updated on 1/31/2024. Historic versions can be obtained by contacting us.