Last Updated: July 23, 2026
Effective Date: July 23, 2026
For inquiries regarding this Privacy Policy or Personal Information protection matters, please contact us via the following channels. We shall respond to your inquiry within seven (7) business days.
Contact Email: survey@hbwlyc.com
Contact Phone: +86 188 5375 7270
Registered Address: Room 109, Yanzhao Financial Center, Qiaoxi District, Shijiazhuang City, Hebei Province, P.R.China
Important Reminders
Your trust is of great importance to us. We fully recognize how critical your Personal Information is to you. In compliance with Applicable Laws and regulations, we will adopt corresponding security protection measures to ensure the security and controllability of your Personal Information.
Hebei Wanlian Cloud Warehouse Technology Co., Ltd. (hereinafter referred to as “the Company” or “we”), acting as the Personal Information processor, attaches paramount importance to the protection of users’ Personal Information and privacy. This Privacy Policy stipulates the rules governing the collection and processing of your Personal Information (hereinafter referred to as “Personal Information”) when you use the TrustArk APP (including its back-end ERP system).
It is expressly clarified that this Privacy Policy does not apply to third-party services, which shall be governed by their respective independent privacy notices.
Before using our products or services, please read and fully understand this Privacy Policy to learn how to protect your privacy rights. You shall pay close attention to clauses marked in italics, bold type, or bold underlines. You may only start using our services after you fully understand and provide your explicit prior consent to all terms herein. Key clauses closely related to your rights and interests are highlighted for your special attention. If you have any questions regarding this Privacy Policy, you may suspend your use of our services and contact us via the contact information we have published. By accessing and using our services, you acknowledge and agree that we may collect, process, store, use, share, transfer and disclose your Personal Information in accordance with this Privacy Policy.
This Privacy Policy is organized to help you understand the following contents:
I. How We Collect and Use Your Information
II. How We Use Cookies and Similar Technologies
III. How We Share, Transfer and Publicly Disclose Your Information
IV. How We Protect Your Information
V. How You May Manage Your Information
VI. How We Process Minors’ Information
VII. Cross-border Transmission of Your Information
VIII. Updates to This Privacy Policy
I. How We Collect and Use Your Personal Information
To improve service quality and user experience, we shall retain information about your use of our services and your related usage behaviors. The types of data collected vary depending on different product features. We hereby provide the following statement regarding the information we collect and store when you use our corresponding products:
(I) Personal Information You Voluntarily Provide to Us When We Supply Products and/or Services to You
To enable business functions of the APP, we need to collect your Personal Information. Below is a detailed list of the Personal Information you voluntarily provide during your use of our products or services, along with the Personal Information required to realize basic business functions. If you decline to provide the Personal Information required for a specific function, you shall be unable to use such functions. Please note that if you provide the Personal Information of another individual, you must ensure that you have obtained authorization from the corresponding data subject.
1. Membership Services: To register as a member and access our membership services, you are required to provide your company name, landline number, mobile phone number, contact person and email address for the creation of your platform account. If you only wish to browse and search content, you are not required to register or provide the foregoing information. We collect different types of information based on whether you are an individual user or an enterprise user. Based on your registration preferences and service usage records, we shall provide you with personalized page displays and content recommendations.
We collect such information to perform the Terms of Service of the APP, deliver the services we promise to you, enable potential partners and our staff to contact you in a timely manner, facilitate the conclusion of trade cooperation, and resolve any issues that may arise. You may log in via your email address or mobile phone number to modify part of the above information.
2. Corporate and Product Information: You are required to provide your email address and mobile phone number, so that potential partners and our staff can contact you promptly, secure trade cooperation opportunities, and resolve any potential issues.
3. Advertising Push Notifications: To better provide recommendation services to you, we may reasonably send commercial advertisements, the platform’s latest information concerning management and goods, as well as other service notices necessary for registered users including but not limited to system notifications, SMS and emails. We may also display personalized third-party promotional information to you through the system. If you do not wish to receive the aforementioned messages, you may opt out via the built-in unsubscribe feature (or by calling +86 188 1003 9392).
4. Customer Service: When you contact us, we may record your communications with us and collect other necessary information required to resolve your inquiries for the purposes of verifying your identity and assisting you in resolving issues.
5. Image/Video/File Access and Upload Functions: You may use the photo and video shooting tools to upload images or videos to the material library normally, and quickly select inquiry attachments when replying to inquiries.
6. Email: You may communicate with the platform or overseas warehouse factories by sending emails. We shall obtain your email receipt records to support real-time communication reminder functions.
7. Electronic Signature: When you use the electronic signature service, you are required to provide your name, identity document number, mobile phone number, facial biometric information, and corporate bank account details for identity verification purposes.
8. Corporate Account Opening: When you apply for the corporate account opening service, you are required to submit identity documents of the enterprise’s legal representative, actual controller and ultimate beneficial owner, including their full names, identity document numbers, document validity terms, nationality or region, detailed residential addresses, and photos of such identity documents.
(II) Personal Information We Collect and Use Proactively When Providing Products and/or Services to You
During your use of our services, we may automatically collect your usage data and store it as network log information to identify abnormal account statuses, evaluate product compatibility, and deliver page displays and search results that better match your needs, including:
1. Device Information:After you consent to this Privacy Policy, we may receive and record device related information of your device based on your specific operations during software installation and/or usage, including but not limited to device model, operating system version, device settings, unique device identifiers (IMEI, Android ID, OAID), device environment, list of mobile applications, IP address, carrier information, as well as location related information of your device(including but not limited to GPS location authorized by you, WLAN access points and Bluetooth information).
Note: Explanation on IMEI (International Mobile Equipment Identity):
(1) Purpose of collection: For account security risk control, abnormal device identification, fraud prevention and ensuring stable business services;
(2) Collection method: Automatically obtained via system interfaces;
(3) Scope of usage: Used solely for risk control scenarios of this APP and shall not be used for cross application tracking;
(4) Supplementary note: Due to system permission restrictions on high version Android systems, where IMEI cannot be obtained on some devices, OAID / Android ID will be adopted as alternative device identifiers.
2. Service Log Information: When you use the products or services provided through our website or client APP, we shall automatically collect detailed records of your service usage and store such data as service logs. Such logs include, without limitation, browsing records, clicks and views, transactions, followed and shared content, published content, together with operation records, timestamps and exception data contained in business logs.
(III) Personal Information We Obtain from Third Parties
We may collect and use your Personal Information from third parties (our partners) within the scope of your explicit prior consent. We guarantee to process your Personal Information in strict compliance with the contracts signed with such third parties and Applicable Laws and regulations. Meanwhile, you are advised to carefully read the privacy policy and user agreement of the relevant third parties. If you refuse to allow third parties to collect, use or transmit your Personal Information in the course of providing services, you may not be able to access corresponding functions of the APP.
(IV) Other Purposes
We shall use your Personal Information in compliance with legal requirements or with your explicit prior consent to provide you with services, improve service quality and optimize your user experience.
1. We may use your Personal Information to verify your identity, as well as prevent, detect and investigate potential fraud, security risks, illegal acts, or acts in breach of agreements, policies or rules of us and our affiliates, so as to protect the legitimate rights and interests of you, other users, us and our affiliates.
2. Invite you to participate in surveys regarding our products and services to enhance your user experience and upgrade our service quality.
3. We may combine Personal Information and transaction data obtained from one service with information collected from other services for comprehensive statistics, analysis and processing, so that we can deliver more personalized services to you.
4. Other purposes approved or authorized by you.
(V) Exceptions to Explicit Prior Consent
Pursuant to Applicable Laws and regulations, we may collect and use necessary Personal Information without obtaining your explicit prior consent under the following circumstances:
A. Circumstances where we must fulfill statutory obligations prescribed under Applicable Laws and regulations;
B. Matters directly connected with national security and national defense security;
C. Matters directly connected with public security, public health and major public interests;
D. Matters directly connected with criminal investigation, public prosecution, trial and judgment enforcement;
E. Where it is necessary to protect material legitimate rights and interests including personal life and property of you or other individuals, and explicit prior consent from the data subject cannot be readily obtained;
F. The Personal Information concerned is voluntarily disclosed to the public by you;
G. Necessary for the performance of long-term and successive contracts concluded between you and us;
H. Your Personal Information collected from legally published public information, such as legitimate news reports and government open information channels;
I. Necessary to maintain the safe and stable operation of our products and/or services, for instance, detecting and troubleshooting faults of products or services;
J. Other circumstances stipulated by Applicable Laws and regulations.
II. How We Use Cookies and Similar Technologies
To ensure normal website operation, deliver a smoother browsing experience and recommend content that may interest you, we may place Cookies, Flash Cookies and other browser-supported local storage technologies on your device. Such storage data includes identifiers, site names and unique alphanumeric strings (collectively "Cookies"). Cookies allow us to record your preferred product selections.
III. How We Share, Transfer and Publicly Disclose Your Information
(I) Sharing
We shall not share your Personal Information with any third party, except in the following scenarios:
1. Sharing under statutory circumstances: We may share your Personal Information externally in accordance with laws and regulations, for the settlement of litigation disputes, or upon lawful requests submitted by administrative and judicial authorities.
2. Sharing with your explicit prior consent: We shall share your Personal Information with other parties only after obtaining your explicit prior consent.
3. Sharing upon your voluntary choice: With regard to information you disclose voluntarily, information we obtain from legal public channels, or information you actively submit via the APP, we may share necessary transaction-related data contained in your order information with relevant goods or service providers in accordance with your selection, so as to fulfill your transaction and after-sales service functions.
4. Sharing with Affiliated Companies: To facilitate providing you with products and services under your account, recommending content that may interest you, identifying abnormal member account activities, and protecting your personal and property rights against infringement, your Personal Information may be shared with our affiliated companies and/or their designated service providers. We shall only share the minimum necessary Personal Information, and such sharing shall be limited to the purposes stated in this Privacy Policy. If we share your Sensitive Personal Information, or if our affiliates alter the purposes for processing your Personal Information, we shall obtain your explicit prior consent again.
5. Sharing with Authorized Partners: To provide you with more comprehensive and high-quality products and services, certain services of the APP are provided by our partners. We will obtain your explicit prior consent before entrusting authorized partners to provide services or perform functions on our behalf. We shall complete a Personal Information Protection Impact Assessment (PIPIA) and keep records of entrusted processing activities as required by the Personal Information Protection Law of the People’s Republic of China.We shall share your information solely for the legal, legitimate, necessary, specific and explicit purposes set forth in this Privacy Policy. Authorized partners shall only have access to the information required for them to perform their duties and shall not use such Sensitive Personal Information for any other purposes.
At present, our authorized partners fall into the following categories:
i. Advertising monitoring, data statistics and data analysis service providers
We shall not share your Personally Identifiable Information (PII) with advertising and data analytics partners without your explicit prior consent. We may entrust such partners to process information relevant to advertising coverage and effectiveness, but shall not disclose your personally identifiable information to them. Alternatively, we shall de-identify such information so that it cannot be used to identify you individually. Such partners may combine the foregoing information with other data they lawfully obtain to deliver the advertising services or analytical insights entrusted by us.
ii. Suppliers, service providers and other partners
We transmit information to suppliers, service providers and other partners that support our business operations. Such support includes provision of technical infrastructure services, software and hardware product services, system product services, analytics usage services, measurement of advertising and service effectiveness, customer service, payment facilitation, academic research and surveys, as well as enabling third-party products accessible via the APP, authorized software logged in and used through the APP, and other integrated third-party services within the APP.
During the processing of Sensitive Personal Information, we shall adopt technical measures to process such information and sever its connection with specific information such as your identity, so that no specific individual can be identified therefrom. If you refuse to allow our partners to collect the Personal Information necessary for service provision during service delivery, you may be unable to use the services provided by such partners through the APP.
iii. If you participate in lucky draws or similar advertising promotions, and the APP or relevant prize and merchandise suppliers need to deliver prizes and goods to you, your recipient information (full name, mobile number and delivery address) may be shared with courier providers.
(II) Transfer
We shall not transfer your Personal Information to any company, organization or individual, except under the following circumstances:
1. Transfer with your explicit prior consent: We shall transfer your Personal Information to other parties only after obtaining your explicit prior consent.
2. Circumstances involving merger, acquisition, asset transfer, bankruptcy liquidation or similar transactions: If such transactions involve the transfer of your Personal Information, we shall require the acquiring entity to remain bound by this Privacy Policy. If the new entity refuses to be bound, we shall require it to obtain your new explicit prior consent.
(III) Public Disclosure
Your Personal Information is an integral part of the services we provide to you, and we shall keep your information confidential in compliance with Applicable Laws. We shall only publicly disclose your Personal Information including your name, gender, department and job title under any of the following circumstances:
1. After obtaining your explicit prior consent;
2. Disclosure required by law: We may publicly disclose your Personal Information if required by laws, legal procedures, litigation or mandatory requests from competent government authorities.
3. If we determine that you have violated laws and regulations or seriously breach the APP’s relevant agreements and rules, or to protect the personal and property safety of APP users or the general public from infringement, we may disclose your Personal Information in compliance with Applicable Laws, or with your explicit prior consent.
4. In accordance with legal provisions and reasonable commercial practices, when we plan to merge with or be acquired by another company, carry out other capital market activities (including IPO and bond issuance), or undergo due diligence by other entities under other circumstances, we shall provide your information to necessary parties. We shall require such entities to adopt reasonable confidentiality measures to protect your Personal Information by signing confidentiality agreements with them.
IV. How We Protect Your Personal Information
(I) We adopt various security measures to protect the security of your Personal Information
To protect the security of your information, we implement industry-standard physical, technical and administrative Security Controls to safeguard your Personal Information against unauthorized access, public disclosure, use, alteration, damage or loss. We shall take all reasonable and feasible steps to ensure that we do not collect Personal Information irrelevant to the provision of service functions.
(II) Adopt relevant measures for the storage and deletion of Personal Information
Information and data collected about you via the APP may be stored and processed at locations of our company and/or our affiliates, as well as with entities we deem necessary to have access to such information. Upon your account cancellation or our termination of your account, we shall delete or anonymize all your Personal Information as required by law.
We retain your Personal Information only for the minimum period necessary to achieve the collection purposes, unless mandatory retention is required by Applicable law. After such retention period expires, we shall delete or anonymize your Personal Information.
(III) The Internet is not an entirely secure environment. We strongly recommend that you follow security best practices to help us secure your account
When using the APP’s services, you will inevitably need to disclose your Personal Information to potential transaction counterparts. Please properly protect your Personal Information and only provide it to others when necessary. If you discover any leakage of your Personal Information, especially the leakage of your account or password, please contact our customer service immediately so that we can take corresponding measures.
Public information refers to any information you voluntarily share publicly. Such information may be viewed or accessed by anyone whether or not they use the APP. Please note that information you voluntarily share while using our services may contain Personal Information, and even Sensitive Personal Information, belonging to you or other individuals. We recommend that you exercise extra caution when deciding whether to share or publicly upload relevant information when using our services.
The Internet environment is not 100% secure, and we shall make every effort to ensure the security of any information you send to us. In the event that our physical, technical or administrative protection facilities are compromised, resulting in unauthorized access, public disclosure, tampering or destruction of information and consequent damage to your legitimate rights and interests, we shall bear corresponding legal liabilities.
(IV) Notification, Reporting Obligations and Disposal Measures for Security Incidents
In the unfortunate event of an information security incident, we shall promptly notify you in compliance with Applicable Laws and regulations, including the basic facts and potential impacts of the security incident, disposal measures we have taken or shall take, recommendations for you to independently guard against and mitigate risks, and remedial measures available to you. We shall inform you of relevant incident details via email, letter, phone call or push notifications. Where individual notification to each information subject is impracticable, we shall issue announcements through reasonable and effective channels.
Meanwhile, we shall proactively report the disposal progress of the information security incident to regulatory authorities as required.
V. How You May Manage Your Information
We attach great importance to your concerns regarding Personal Information and shall make every effort to protect your rights to access, correct and delete your Personal Information, cancel your account, and withdraw explicit prior consent, so that you are fully empowered to safeguard your privacy and security.
You may access and manage your information through the following methods:
(I) Access, correct and supplement your Personal Information
You have the right to access, correct or supplement your Personal Information. You may complete such operations by yourself via the following method: After logging into your account on the desktop portal, you may view, modify and supplement your Personal Information under Personal Information > My Account.
(II) Delete Your Personal Information
You may delete part of your Personal Information through the methods specified in "(I) Access, Correct and Supplement Your Information".
You may submit a request to us for deletion of your Personal Information under the following circumstances:
1. Our processing of Personal Information violates Applicable Laws and regulations;
2. We have collected or used your Personal Information without obtaining your explicit prior consent;
3. Our processing of Personal Information materially breaches the agreement concluded with you;
4. You cease to use our products or services, or voluntarily cancel your account;
5. We permanently stop providing products or services to you.
If we decide to grant your deletion request, we shall, to the greatest extent practicable, simultaneously notify all parties that have obtained your Personal Information from us and require them to delete such Sensitive Personal Information in a timely manner (unless otherwise stipulated by laws and regulations, or such parties have separately obtained your authorization).
After you delete relevant information or we assist you with deletion, we may not be able to immediately erase the corresponding data from backup systems due to Applicable legal requirements and security technical constraints. We shall securely store your Personal Information and isolate it from any further processing until such backups can be purged or anonymized.
(III) Account Cancellation
You may contact our online customer service or call the service hotline at +86 188 1003 9392 for assistance, and we shall process your account termination request within fifteen (15) business days upon receipt.
After you voluntarily cancel your account, we shall cease providing products and services to you, and delete or anonymize your Personal Information in compliance with Applicable legal requirements.
(IV) Restrict Automated Decision-Making by Information Systems
For certain business functions, we may make decisions solely through non-manual automated decision-making mechanisms including information systems and algorithms. Prior to adopting Personal Information for automated decision-making, we shall conduct a Personal Information Protection Impact Assessment (PIPIA) to ensure that the purposes and methods of Personal Information processing comply with the principles of lawfulness, legitimacy and necessity. Meanwhile, we shall assess impacts on personal rights and interests as well as security risks, and ensure that adopted protective measures are lawful, effective and proportionate to the level of risks.If such decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us, and we shall also provide appropriate remedies.
(V) Response to Your Foregoing Requests
To ensure information security, you may be asked to submit a written request and complete identity verification for security purposes. We may ask you to verify your identity before processing your request.
Ordinarily, we shall respond to you within seven (7) business days. If you are dissatisfied with our reply, you may file a complaint via online customer service or by calling our service hotline at +86 188 1003 9392. We reserve the right to reject requests that involve information not directly linked to your identity, groundless repeated requests, requests requiring excessive technical measures (such as developing new systems or fundamentally changing existing practices), requests posing risks to the legitimate rights and interests of others, or impractical requests.
We shall not be able to respond to your requests under the following circumstances:
1. Matters involving national security and national defense interests;
2. Matters related to public security, public health and major public interests;
3. Matters related to criminal investigation, prosecution, trial and judgment enforcement;
4. Where sufficient evidence proves that the Personal Information subject acts with subjective malice or abuses his/her rights;
5. Where complying with your request would seriously impair the legitimate rights and interests of you or other individuals and organizations;
6. Matters involving commercial secrets.
VI. How We Process Minors' Personal Information
The APP’s products, websites and services are primarily intended for adults. Accordingly, we do not target minors (the age of minors shall be determined in accordance with the laws of your country and cultural practices of relevant countries and regions) as our users, nor do we intentionally collect Personal Information of minors. Meanwhile, we urge guardians to actively supervise and pay attention to minors’ online activities, interests and hobbies. If we discover that a minor’s Personal Information has been collected without the guardian’s explicit prior consent, we will promptly delete such information.
VII. How Your Information Is Transferred Globally
In principle, all Personal Information collected and generated by us within the territory of the People’s Republic of China shall be stored within the territory of the People’s Republic of China. You acknowledge and agree that we provide products and services through globally distributed resources and servers. Subject to Applicable cross-border data transfer laws, we may store your collected information on servers located outside the Chinese mainland, and may provide part or all of your Personal Information to overseas affiliates or third parties outside Chinese mainland that maintain cooperative relationships with our affiliates based on actual business operational needs.
Such jurisdictions may have differing data protection laws or even no relevant legislation in place. In such circumstances, we shall ensure that your Personal Information receives protection equivalent to that afforded within the People’s Republic of China. For example, we shall obtain your explicit prior consent prior to the cross-border transfer of Personal Information, or implement security measures such as data de-identification before cross-border data transmission. If you do not provide explicit prior consent to the outbound transfer of your information or wish to obtain further details, please send an email to survey@hbwlyc.com, and we shall properly handle your inquiry. Our authorized software and online services may become unavailable if you withhold explicit prior consent for the outbound transfer of information. The following sets out detailed rules governing how we provide your Personal Information to overseas parties.
(I) Basic Circumstances of Outbound Transfer of Personal Information
1. Purposes of Outbound Personal Information Transfer
Outbound data transfers are conducted to complete necessary business links required under our core business model, including: providing one-stop services to facilitate international trade between buyers and sellers; boosting customer credibility to complete order transactions smoothly; and enabling smooth international trade between domestic suppliers and overseas buyers.
2. Methods of Outbound Personal Information Transfer
Overseas buyers are the overseas recipients of your information. After your information is transferred overseas, it shall be stored on our overseas servers and made available for viewing by overseas buyers.
i. Storage of Personal Information on Overseas Servers
Overseas buyers may only view your information through web pages and are prohibited from downloading or exporting any of your Personal Information.
ii. Provision of Personal Information to Overseas Buyers
As overseas recipients, overseas buyers may access your Personal Information through the following channels: First, overseas buyers may publicly view your full name, gender, workplace and job title without logging in. Second, after logging in but before sending you inquiries or generating any order and other business data, they may view your mobile phone number. Third, if an overseas buyer sends you an inquiry and you reply to it, or after you complete a transaction with an overseas buyer, we shall provide your email address and IP address to such buyer upon obtaining your explicit prior consent.
The information involved in the first two scenarios constitutes Personal Information voluntarily disclosed by you. The bolded information above shall be publicly displayed on the APP with your explicit prior consent. The email address and IP address mentioned in the third scenario are Personal Information transmitted from within the territory of China to overseas jurisdictions.
iii. Scope of Personal Information Exported Overseas
The Personal Information exported overseas includes your full name, workplace, mobile phone number, email address and IP address. All cross-border data of the APP is collected from the information you submitted during registration on the APP. The exported data does not cover data generated by other products or services outside the APP, nor internal employee data and operational management data of the Company.
iv. Procedures for Providing Personal Information to Overseas Parties
Pursuant to business demands and Article 39 of the Personal Information Protection Law of the People's Republic of China, we shall provide your email address and IP address to overseas buyers in accordance with the following rules: When an overseas buyer logs in, sends an inquiry and receives your reply to such inquiry, we shall obtain your explicit prior consent before disclosing your email address and IP address to the overseas buyer.
Before providing your email address and IP address to the overseas buyer, we shall display the overseas buyer’s basic information when you view the buyer’s details. On the page for replying to the overseas buyer’s inquiry, we shall present items including the overseas buyer’s name, contact information, purposes and methods of Personal Information processing, categories of Personal Information, as well as the channels and procedures for you to exercise your rights stipulated under the aforesaid Law. You must actively click to confirm to authorize us to share your email address and IP address.
v. Personal Information Protection Impact Assessment
Pursuant to Article 55 of the Personal Information Protection Law of the People’s Republic of China, we shall conduct a Personal Information Protection Impact Assessment (PIPIA) prior to providing your email address and IP address to overseas buyers. We shall retain the PIPIA report for no less than three years.
vi. Purposes of Processing by Overseas Recipients
We provide your information to overseas buyers solely for the purpose of conducting commercial transactions.
vii. Methods of Processing by Overseas Recipients
Your information is provided to overseas buyers, who may send emails to you via your received email address to fulfill the aforementioned processing purposes.
(II) Administration and Re-transfer of Personal Information Overseas
1. Storage Locations of Personal Information Overseas
Your information will be stored on servers under our control in Germany and the United States. We will not grant overseas buyers any access to download or export such information, who may only view the information via webpage browsing.
2. Retention Period of Personal Information Overseas
Personal Information shall only be retained for the minimum period necessary to complete transactions and retrieve historical transaction records. With reference to Article 31 of the Measures for the Supervision and Administration of Online Transactions of the People’s Republic of China and the Personal Information Protection Law of the People’s Republic of China, we will keep your exported Personal Information for three years after you cancel your account.
3. Disposal Measures for Personal Information Overseas
Upon expiry of the retention period, completion of agreed processing purposes or termination of relevant legal documents, we will delete or anonymize all Personal Information (including all backups), unless we obtain your separate consent to extend the retention period.
4. Re-transfer of Overseas Data
Binding restrictions shall apply if overseas recipients re-transfer exported data to other organizations or individuals. Overseas recipients undertake not to transfer your Personal Information to any third parties outside China unless all applicable regulatory requirements are satisfied, and they shall record all secondary transmission activities.
(III) Rights of the Personal Information Subject
1. Your Right to Know and explicit prior consent
Pursuant to Article 39 of the Personal Information Protection Law of the People’s Republic of China, as the Personal Information processor, we shall perform the following obligations to you:
Prior to disclosing your email address and IP address to overseas buyers, we shall inform you of the overseas buyer’s name, contact details, and an explanation regarding the cross-border transmission of Personal Information.
Basic information of us, the Personal Information processor, is set forth below:
Personal Information Processor: Hebei Wanlian Cloud Warehouse Technology Co., Ltd.
Contact Email: survey@hbwlyc.com
Contact Phone: +86 188 1003 9392
Address: Room 109, Yanzhao Financial Center, Qiaoxi District, Shijiazhuang City, Hebei Province, P.R.China
2. Your Rights as a Third-Party Beneficiary
We hereby inform you that we shall safeguard your Personal Information rights and interests by executing legal documents with overseas recipients containing clauses for the protection of your Personal Information. Under such legal documents, we undertake the following commitments: The documents stipulate that you shall be regarded as a third-party beneficiary. If you raise no explicit objection within thirty (30) calendar days, you may exercise rights as a third-party beneficiary under such legal agreements.
3. Your Other Rights
We stipulate in the contracts concluded between us and overseas recipients the methods and procedures for you to exercise your rights with respect to exported Personal Information, including the right to access, right to obtain copies, right to rectify and supplement, and right to deletion. You have the right to request us and overseas recipients to interpret and explain the Personal Information processing rules, so as to fully and effectively safeguard data security and your rights and interests related to Personal Information.
When you intend to exercise the aforesaid rights over exported Personal Information, you may request us to take appropriate measures to facilitate such exercise, or submit requests directly to overseas recipients. If we are unable to fulfill your request, we shall notify and require overseas recipients to provide assistance.
Overseas recipients shall, in response to our notice or your direct request, enable the Personal Information subject to exercise their rights as prescribed by Applicable Laws and regulations within a reasonable time limit. Overseas recipients shall provide true, accurate and complete relevant information to you in a prominent manner using clear and easy-to-understand language.
If you submit excessive or unreasonable requests, particularly repetitive ones, overseas recipients may charge reasonable fees after taking into account the implementation and operational costs of fulfilling such requests, or decline to act in accordance with your demands.
If an overseas recipient intends to reject your request, it shall inform you of the grounds for rejection, as well as the channels for you to file complaints with relevant regulatory authorities and seek judicial remedies.
(IV) Breach of Contract and Remedies
1. Remedies Available to You
Where exported data faces risks such as tampering, damage, disclosure, loss, unauthorized transfer, illegal access or illegal utilization, overseas recipients shall properly conduct emergency response to protect your Personal Information rights and interests. Both we and overseas recipients agree that if a dispute arises between you and either us or an overseas recipient in connection with compliance with the legal documents, all parties shall notify each other of relevant circumstances and cooperate to resolve the dispute in a timely manner.
If the dispute cannot be settled amicably, you may exercise your rights as a third-party beneficiary in accordance with the aforesaid provisions, and overseas recipients shall accept the following claims you raise to safeguard your legitimate rights and interests:
A. File complaints with regulatory authorities;
B. File a lawsuit with the people’s court having jurisdiction at TrustArk APP operator’s registered domicile.
Overseas recipients acknowledge that any remedy you choose shall not prejudice your substantive or procedural rights to seek relief under other Applicable Laws and regulations.
2. Remedial Measures
If we detect any breach of contract committed by an overseas recipient, we may cease providing Personal Information to such recipient by adopting the aforesaid protective measures, including without limitation suspending the display of your Personal Information to the overseas recipient, blacklisting the overseas recipient, and terminating relevant services provided thereto.
VIII. Statistical Analysis Service
To analyze application operation performance and optimize product functionality and user experience, this application integrates third-party statistical analysis SDKs. We select different service providers based on users’ geographic regions.
1. Users in Chinese Mainland
SDK Name: DCloud uni-stat 2.0
Developer: Digital Paradise (Beijing) Network Technology Co., Ltd. (DCloud)
Types of collected information: Application operation logs, user access behaviors and anonymous identifier information;
Purpose of use: Conduct operational data analysis, troubleshoot operational anomalies and optimize service experience;
Privacy Policy Link: https://dcloud.net.cn/license/uni-stat.html
2. Users outside Chinese Mainland
SDK Name: Google Firebase Analytics
Developer: Google LLC
Types of collected information: Basic device information, in-app operation behaviors and crash logs;
Purpose of use: Collect application usage statistics to support product iteration and optimization;
Privacy Policy Link: https://policies.google.com/privacy
IX. Updates to This Privacy Policy
To provide you with better services, our business operations may change from time to time, and this Privacy Policy shall be adjusted accordingly. We shall not limit or reduce any rights granted to you under this Privacy Policy without your explicit prior consent. Any amendments made to this Privacy Policy shall be published on this page.
For material changes, we shall issue more prominent notifications, including releasing updated versions via the APP or reminding you of relevant updates through other means. You are also advised to visit our platform regularly to stay informed of the latest Privacy Policy. Under the aforesaid circumstances, your continued use of our services shall constitute your acceptance to be bound by the revised Privacy Policy.
Material changes referred to in this Privacy Policy include but are not limited to:
1. Material adjustments to our service model, such as changes to the purposes of Personal Information processing, categories of processed Personal Information, and methods for using Personal Information;
2. Material changes to our control rights, such as a change of Personal Information controller arising from merger, acquisition or restructuring;
3. Changes to main recipients with whom Personal Information is shared, transferred or publicly disclosed;
4. Material adjustments to your rights concerning Personal Information processing and the ways to exercise such rights;
5. Changes to the department responsible for Personal Information security, contact information and complaint channels;
6. High risks identified in the Personal Information security impact assessment report.
If you disagree with such revisions, you may stop using the APP’s services. Your continued use of the APP’s services shall constitute your full reading, understanding and acceptance of the revised Policy. We prioritize your satisfaction in all revisions of this Privacy Policy. We encourage you to review this Privacy Policy each time you use the APP services.