Ebuysourcing (HongKong) Co.,Ltd Personal Information Protection Policy
Dear user: Ebuysourcing (HongKong) Co.,Ltd (hereinafter referred to as “Ebuysourcing” or “we”) has always sincerely seen the protection of your personal information to be of significant importance. Prior to using services of Ebuysourcing, please read and understand this policy carefully, specifically the terms in bold or underlined. When you use or continue to use services of Ebuysourcing after this policy is updated, it is deemed that you have read, understood and agreed to this policy and its updated version, and agree that we will process your personal information in accordance with this policy.
1.1 Ebuysourcing user: refers to the Ebuysourcing official website (the domain name is https://www.ebuysourcing.com/) and the programs, systems, applications, website, customers and corresponding equipment used to provide the services.
1.2 Ebuysourcing: Refers to the single or collective name of user operators or service providers of Ebuysourcing, namely Shenzhen Ebuysourcing Co., Ltd. and/or Ebuysourcing (Hong Kong) Co., Ltd.
1.3 Personal information: refers to the information, content or data recorded by electronic or other means to work independently or in combination to identify the identity of a specific natural person or reflect the activities or details of a specific natural person.
3. Types of personal information we collect
Generally, the personal information we collect includes the following types:
3.1 You proactively provide Ebuysourcing with relevant information, including:
3.1.1 When creating an Ebuysourcing user account, you may choose to fill in and/or submit information according to the different available Ebuysourcing account creation methods, including your name, avatar, intended user name, email address, phone number and Ebuysourcing user login details. If the avatar you choose or the username you intend to use does not identify you, it is not your personal information.
3.1.2 When you perform the Ebuysourcing username authentication process, you need to fill in and/or submit according to the different real-name authentication methods prompted on the page.
3.1.3 When you perform Ebuysourcing user account qualification process, the information you fill in and/or submit are to be based on different certification requirements, including your work information, work email address, job position information, qualification documents, and a copy of your ID.
3.1.4 IS MISSING FROM ORIGINAL DOC
3.1.5 If you are the sender, in order to complete the service you have selected or the transaction entered into, the information you fill in and/or submit, including package information (including the name of the product/items contained in the package, the value/cost), and the sender information (including sender’s name, phone number, address), recipient information (including recipient’s name, phone number, address).
3.1.6 Before completing the service you have selected or the settlement of the transaction fee, the information you fill in and/or submit, including Paypal account number, credit card account number and identity information (including personal information related to your Paypal account), or your credit card account number and the identifying information it contains (including personal information related to your bank account).
3.2 During the use of the platform, Ebuysourcing will collect relevant information, including:
3.2.1 When using services of Ebuysourcing or accessing the Ebuysourcing user platform, Ebuysourcing automatically receives and records the information about your browser and computer, including but is not limited to your IP address, browser type, language used, date and time of access, software and hardware information and your requested web page records, cookies or similar technical information.
3.2.2 Ebuysourcing may also collect other relevant information about you for the reasonable needs of providing services and improving service quality, including relevant information you provide when you contact customer service team of Ebuysourcing, the questionnaire response information sent to Ebuysourcing when you participate in the survey as well as related information collected by Ebuysourcing when you interact with affiliates and partners of Ebuysourcing. Similarly, to improve the security of the use of services provided by the Ebuysourcing platform, and to further accurately prevent phishing website fraud and trojan viruses, Ebuysourcing may learn some of your network usage habits, your commonly used software information to assess the risk, and will record some URLs that Ebuysourcing considers as risky.
3.3 Ebuysourcing received related information from third parties. In order to provide you with better, improved and more personalized services, or to jointly provide you with services, or to prevent Internet fraud, third parties such as affiliates and partners of Ebuysourcing etc. will only share your personal information with Ebuysourcing should it be in accordance with the law, including:
3.3.1 Prior to completing the service you choose or finalizing the transaction, affiliates or partners of Ebuysourcing will share your personal information with Ebuysourcing, including the package information included in the order (including the name of the products/items contained in the package, the value/cost), sender information (including sender name, phone number, address), recipient information (including recipient name, phone number, address).
3.3.2 Your information may be included in information provided or shared by other users. For example: if you are the recipient, in order to complete the service selected by the sender or finalize the transaction, the information filled and/or submitted by the sender will include your name, phone number, and address.
4. How Ebuysourcing uses personal information
4.1 We will utilize your personal information for the basic functions and purposes set in this policy:
4.1.1 Finalize membership registration and name authentication for you, and verify your user account registration information.
4.2 We may use your personal information for the expansion of business operations and purposes set out in this policy, use your personal information:
4.2.1To enhance the services you use and provide you with information display, search and services and advertising that are more aligned with your personalized needs, Ebuysourcing will extract your browsing and search preferences, device data, location information and order details. Should you not want to receive commercial advertisements sent to you by Ebuysourcing, you can unsubscribe by prompting or directly contacting Ebuysourcing.
4.3 Providing you with security
4.3.1 Related parties and partners of Ebuysourcing will ensure the security of the operating environment and identify abnormal account statuses, to protect use of the services, protect the safety of your personal and property safety as well as other users or the public from damage, and better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions and other security risks, more accurately identify violations of laws and regulations or customer related agreement rules of Ebuysourcing. Ebuysourcing may use or integrate your account information, transaction information, equipment information, relevant network logs and information that related parties and partners have obtained after receiving your authorization or shared in accordance with applicable laws, then comprehensively assess your Ebuysourcing account and transaction risks, perform identity verification, detect and prevent security incidents, and take necessary records, audits, analysis and handling in accordance with the law.
4.4 Other business purposes:
4.4.1 Ebuysourcing may undertake research, statistical analysis and forecasting on the gathered information to improve the content and layout of the Ebuysourcing platform, provide product or service support for business decisions, and improve products and services of Ebuysourcing. For example: robotic learning or model algorithm training by utilizing anonymous data.
4.5 In the exception of a mandatory retention period required by law, Ebuysourcing will only retain personal information for the period necessary to achieve the purposes stated in this policy.
4.6 If Ebuysourcing uses the information for other purposes not specified in this policy, or uses the gathered information for other purposes, your prior consent will be asked for.
5. How Ebuysourcing shares, transfers and disclose information
5.1 Ebuysourcing is responsible to keep your personal information confidential and will not sell or lease any personal information to third parties for their marketing purposes. Ebuysourcing will only share your personal information with third parties under the following circumstances:
5.1.1 With your prior consent or authorization.
5.1.2 Sharing personal information in accordance with the laws and regulations or the requirements of administrative or judicial authorities.
5.1.3 Sharing personal information with affiliates of Ebuysourcing. For the convenience for Ebuysourcing to provide services to you based on the Ebuysourcing user platform, there will be recommended products and other information that you may be interested in,
5.1.5 Should you be a qualified intellectual property complainant and have filed a complaint with Ebuysourcing, you are to disclose your personal information to the respondent at the request of the respondent, so that both parties can deal with possible rights disputes.
5.1.6 Only by sharing your personal information can you receive the services provided by Ebuysourcing, or deal with disputes between you and others. For example, if an Ebuysourcing logistics partner makes a request for information disclosure due to the fulfilment of your order obligations, Ebuysourcing will provide the partner with necessary information such as the contact information of the sender/recipient, so as to facilitate the completion of the transshipment service.
5.1.7 If you violate relevant Chinese laws, regulations or Ebuysourcing related agreements or rules, you need to disclose it to a third party.
5.1.8 To maintain the personal and financial safety of Ebuysourcing, related parties and logistics partners of Ebuysourcing, users or the public from being infringed.
5.2 Ebuysourcing will not transfer your personal information to any company, organization and personnel, with the exception of the following cases:
5.2.1 Ebuysourcing will transfer your personal information to other parties after obtaining your explicit consent.
5.2.2 In the event of a merger, acquisition or bankruptcy liquidation of an Ebuysourcing service provider, or other situations involving merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved, Ebuysourcing will require new companies and organizations that hold your personal information to continue to comply to the constraints of this policy, otherwise Ebuysourcing will require the company, organization or personnel to seek authorization from you again.
5.3 Ebuysourcing will only disclose personal information under the following circumstances:
5.3.1 With your explicit consent or based on your active choice.
5.3.2 If Ebuysourcing confirms that you have violated laws and regulations or significantly violated related agreements and rules of Ebuysourcing, or to protect the personal and property safety of Ebuysourcing users or the public from harm, Ebuysourcing may disclose information about you in accordance with laws and regulations or with your consent personal information, including related violations and actions Ebuysourcing has taken against you.
5.4 Ebuysourcing does not need your prior consent to share, transfer and disclose your personal information in the following circumstances:
5.4.1 Related to national security and national defence security.
5.4.2 Related to public safety, public health, and major public interests.
5.4.3 Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and execution of court.
5.4.4 When to protect your or other personal life, property and other major legitimate rights and interests, but is difficult to obtain your consent.
5.4.5 When your personal information was already disclosed to the public by yourself
5.4.6 When personal information is collected from legally disclosed information, such as official news reports, government information disclosure and other related channels.
5.5 According to the law, if Ebuysourcing takes technical measures and other necessary measures to process your personal information, resulting in the data recipient not being able to be identified or recovered, then the sharing, transfer and disclosure of such processed data does not need to be notified to you or receive your consent.
6. Protection of personal information
6.1 To ensure the security of information, Ebuysourcing aims to take various appropriate physical, electronic and management security measures, so that your information will not be leaked, damaged or lost, including but are not limited to HTTPS protocol for transmission Encryption, SSL, encryption of information, data center access control. Also, Ebuysourcing proceeds with strict management of employees or outsourcers who may come into contact with your information, including but are not limited to adopting different authority controls according to different positions, signing non-disclosure agreements with them, monitoring their operations and other measures, conducting security and privacy protection training. Ebuysourcing will provide corresponding security measures to protect your information according to the existing technology, and provide appropriate security. Ebuysourcing will attempt to prevent information from being leaked, damaged or lost.
6.2 There are security protection functions on your user account, please safely keep your account and password information. Ebuysourcing will ensure that your information will not be lost, abused and altered through security measures such as backing up to other servers and using encrypted passwords. Despite the above mentioned security measures, please understand that there are no “perfect security measures”. Ebuysourcing recommends that you take active measures, including but not limited to using complex passwords, changing passwords regularly, and not disclosing your account password and other personal information to other personnel.
6.3 You inevitably have to disclose your personal information when using Ebuysourcing services, such as contact information or postal address information, to the company operating the express services business or the sender/receiver of the package or the actual sender/receiver of the package you entrusted. Please securely protect your personal information and only provide to others when necessary. If you believe your personal information has been leaked, specifically your account number and password, please contact Ebuysourcing immediately so that Ebuysourcing can take corresponding measures.
6.4 After acknowledging an unfortunate personal information security incident, Ebuysourcing will inform you in accordance with the requirements of laws and regulations, the general situation and possible impact of the security incident, the disposal measures that Ebuysourcing has taken or will take, and the suggestions you can undertake to avoid and reduce risks, etc. Ebuysourcing will notify you of the event-related situation by email, letter, telephone, push notification, etc. In the event where it is difficult to inform the subject of personal information separately, Ebuysourcing will take a reasonable and effective manner to publish an announcement. In the meantime, Ebuysourcing will also report the handling of personal information security incidents per the requirements of regulatory authorities.
7. Your Rights
In accordance with relevant Chinese legislations, regulations, standards, and common practices in other countries, we guarantee that you have the following rights to exercise, over your personal information:
7.1 Information inquiry and updateof your personal information.
7.1.1 Should you have the need to inquire about your personal information on your Ebuysourcing user account, you can log in directly to the Ebuysourcing user platform and view “My Personal Information” to inquire about your name, avatar, intended user name, email, phone number, Ebuysourcing user account details. If you cannot search for your personal information, you can contact Ebuysourcing directly.
7.1.2 If the information you provided during the registration of your user account or the use of the Ebuysourcing customer service changes, you can log in directly to the Ebuysourcing user platform and view “My Personal Information” to update your personal information. If you are unable to update your personal information, you can contact Ebuysourcing directly.
7.2 Removal of your personal information.
7.2.1 In the event of any of the following circumstances, you may request Ebuysourcing to delete the personal information on your Ebuysourcing user account according to the Ebuysourcing contact information listed in Article 12 of this policy.
184.108.40.206 Handling of personal information by Ebuysourcing violates laws and regulations.
220.127.116.11 When Ebuysourcing collects and uses your personal information without your direct consent.
18.104.22.168 Handling of personal information by Ebuysourcing seriously violates its agreement with you.
22.214.171.124 If you no longer use the Ebuysourcing service, or your Ebuysourcing user account has been cancelled according to the Ebuysourcing user account cancellation process.
126.96.36.199 If Ebuysourcing permanently ceases to provide you with products or services.
7.2.2 If Ebuysourcing decides to respond to your deletion request, Ebuysourcing will also notify the subjects, as many as possible, those who have obtained your personal information from Ebuysourcing, and request them to delete your information in a timely manner (unless otherwise provided by law and regulations, or these subjects have independently obtained your authorisation).
7.2.3 Once you or Ebuysourcing assists you to delete all relevant information, however because of applicable laws and security techniques, Ebuysourcing may not be able to immediately delete the corresponding information from the backup system, Ebuysourcing will securely store your personal information and isolate it from any further processing, until the backup can be cleared or become anonymous.
7.3 Log out of your user account
7.3.1 Should you like to cancel services with us, you can apply to cancel your account according to the contact information in section 11. Contact Ebuysourcing. After we agree to cancel your account, we will cease providing services to you, and per the requirements of applicable laws, will delete your personal information, or handle it anonymously. Since the operation of canceling the Ebuysourcing user account will make you unable to use our services, please operate with caution.
7.4 Receivea copy of your personal information
7.4.1 You have the right to obtain a copy of your personal information, and can be requested with the contact information in section 11. Contact Ebuysourcing.
7.4.2 Under circumstances of technical feasibility, if the data interface has been matched, we can also directly transmit a copy of your personal information to a third party designated on behalf of you, should you request.
7.5 In response to your above request
7.5.1 For security, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.
We will respond within 30 days. If you are not satisfied, you may make a complaint through the methods stated in section 11.
7.5.2 According to the requirements of laws and regulations, we will not be able to respond to your request if the following cases occur:
188.8.131.52 Relating to the controlling of personal information as per laws and regulations;
184.108.40.206 Those which directly relate to national security and national defence security;
220.127.116.11 Those which directly relate to public safety, public health, and major public interests;
18.104.22.168 Those which directly relate to criminal investigation, prosecution, trial and enforcements of law;
22.214.171.124 The controller of personal information has sufficient evidence to prove that the personal information subject has biased judgement or abuses rights;
126.96.36.199 Protection of legal rights of personal information, life and property is significant, but difficult to receive the consent of the individual in some circumstances;
188.8.131.52 Responding to the request of the personal information that may cause serious damage to the legal rights and interests of the subject of personal information or other individuals or organizations;
184.108.40.206 Those involving business trade secrets.
8.How we handle children’s information
8.1 Despite local laws and customs defining children differently, we treat anyone under the age of 14 as a child.
8.2 Our products, website and services are primarily aimed at adults. Ebuysourcing does not recommend the use of Ebuysourcing services by children. Unless permitted by local laws and with the consent of the guardian, children should not register an account or send personal information such as their name, address, phone number, email address, etc. If you believe that Ebuysourcing may be inappropriately displaying information about children, please contact Ebuysourcing.
9. How we store your information
9.1 Storage location
9.1.1 Unless your country/region or the country/region where you use Ebuysourcing services or the country/region where you access the Ebuysourcing or the country/region where Ebuysourcing collects information is expressly prohibited by law, or with your express authorisation, or your personal initiative behaviour, the personal information legally collected by Ebuysourcing will be stored in the territory of the People’s Republic of China.
9.1.2 If you use the Ebuysourcing service outside the People’s Republic of China, your personal information may be transmitted to the country/region where you are located or the country/region where you are using the Ebuysourcing service or the country/region where you access Ebuysourcing or the country/region where Ebuysourcing collects the information so that you can successfully use Ebuysourcing services in your country/region or successfully access Ebuysourcing in your country/region. Such countries may have different data protection laws or possibly no relevant laws. In such cases, we will ensure that your personal information is adequately and equally protected within the territory of the People’s Republic of China. For example, we may request your consent to transfer personal information across borders, or prior to cross-border data transfers we will implement security measures.
9.2 Storage period
9.2.1 We will only retain your personal information for the period necessary to achieve the purpose stated in this policy, unless there is a mandatory requirement by law, such as the “People’s Republic of China Electronic Commerce Law” requires information on goods and services as well as transaction information to be stored for at least three years after the transaction is matured. Our criteria for judging the storage period includes:
220.127.116.11 Complete the order transaction with you, maintain the respective transaction and business records, to respond to your possible inquiries or complaints;
18.104.22.168 Ensure the safety and quality of the services we provide you;
22.214.171.124 Whether you agree to a longer retention period;
126.96.36.199 Whether there is any other special agreement during the retention period.
10. How this policy is updated
10.2.1 A material change in our service model such as the purpose of processing personal information, the type of personal information processed, the method of using personal information, etc.;
10.2.2. Major changes in our ownership structure, organizational framework, etc such as changes due to adjustments to business operations, bankruptcy, mergers and acquisitions, etc.;
10.2.3 Change to the main target audience of personal information sharing, transfer or public disclosure;
10.2.4 Major change in your rights to participate in personal information processing and the manner they are exercised;
10.2.5 When our responsible department, contact details or complaint channel for handling personal information change;
10.2.6 When the personal information security impact assessment report indicates that there is a high risk.
10.2.7 We will also archive older versions of this policy for your potential review.
11. Contact Ebuysourcing
A dedicated department for personal information protection has been set up, if you have any questions, comments or suggestions about this personal information protection policy, you can contact us via email: firstname.lastname@example.org.
Generally, we will reply within 30 days. When we receive a request in relation to rights, inquiries, etc, or if the question relates to your personal information or a relatively important matter, we may ask to verify your identity.
Should you not be satisfied with our response, specifically if our personal information processing behaviour has impacted on your legitimate rights and interests, you can also seek solutions from China’s Internet, Telecommunications, Public Security, Commerce or other regulatory authorities.