PERSONAL DATA PROTECTION POLICY
Your trust matters to us. Zongteng and its operating subsidiaries and divisions (hereafter “Zongteng”or “we”) are committed to delivering the excellent services to you. At Zongteng, we are committed to protecting your privacy and the security of information that can directly or indirectly be used to identify a natural person (hereafter “Personal Data”). Zongteng has created this Personal Data Protection Policy (hereafter “Policy”) to explain how Zongteng collects, uses, processes, stores, shares and transfers your Personal Data when you visit our website or use our services.
Last update: May 26, 2022
Effective date: June 2, 2022
When this Policy mentions “Zongteng”or “we”, it is referring to Fujian Zongteng Network Co., Ltd. that is deciding on the purposes and means of the processing of your Personal Data under this Policy.
Contact Information:
Fujian Zongteng Network Co., Ltd.
Address:Floor 15-19, Chuanghui International Center, Intersection of Banxuegang Avenue and Yongxiang Road, Longgang District, Shenzhen City, Guangdong Province
For questions or requests regarding your Personal Data, you may contact our Personal Data Protection Officer at DPO@ztn.com.
Overview
This Policy answers the following questions:
1. Does this Policy apply to you?
2. What Personal Data does Zongteng collect and how does Zongteng use?
3. How does Zongteng share, transfer and publicly disclose your Personal Data?
4. What measures does Zongteng take to protect your Personal Data?
5. Where does Zongteng store and how long will Zongteng retain your Personal Data?
6. What rights can you exercise in relation to your Personal Data?
7. Will there be updates to this Policy?
8. How to contact Zongteng?
1. Does this Policy apply to you?
This Policy applies to you if you are a customer of Zongteng or if you contact Zongteng, for instance, by visiting website www.mikailgraham.com including any pages, mobile apps or social media (hereafter “Websites”),or if you receive emails from Zongteng.
Our Websites are for a general audience and not aimed at children. In principle, we do not collect Personal Data from children under age 14. If you are under the age of 14 and you want to use our services, please rely on a parent or guardian to assist you.
If a child under the age of 14 may have disclosed Personal Data to us, the parent or guardian can contact us and we will remove Personal Data if required.
2. What Personal Data does Zongteng collect and how does Zongteng use?
In the course of its business activities and providing the services, Zongteng will need to process Personal Data. Without your Personal Data, we will not be able to provide you with the requested services.
The Personal Data you voluntarily provide to us for the purpose of using our services
When you visit our Websites and want to get our customer service or get a quotation, you voluntarily submit your name, phone number, email address, WeChat ID, QQ number, company name, company city via the online contact form available on the Websites or other necessary information displayed on the online contact form. We may use the information you submit to contact you to respond your service needs.
Automatically generated information
When you visit our Websites, we may automatically collect certain information from your device. This will include IP address, unique device or user identification number, system and browser type, date and time, the content and pages you visit on our Websites, the date, time and location where the online activities occur.
Collecting this information allows us to better understand the visitors to our Websites, where they come from and what content they are interested in on our Websites. We use this information for internal analysis purposes and to improve the quality and relevance of our Websites to visitors. We are also required to keep logs in accordance with Chinese laws and regulations to record the network activities on our Websites.
Principles to process your Personal Data
We will follow the principles of legitimacy, lawfulness, and necessity, and for the above purposes described in this policy, to collect and use the personal data that you actively provide during your visit to our Websites or use of our services or that are automatically generated in the course of use of our services. If we need to use your Personal Data for other purposes not specified in this Policy, or use your Personal Data collected for a specific original purpose for other purposes, we will inform you in a reasonable manner and obtain your consent before processing.
Legal grounds to process your Personal Data
Please fully understand that we may collect and process your Personal Data in the following circumstances. Its legal basis may vary depending on the type of personal data, the intended business activities and services, and/or as otherwise required or permitted by Chinese law.
To the maximum extent permitted by Chinese law, we will rely on the following legal bases for processing where your consent is not required:
Where the processing of Personal Data is necessary for the conclusion or performance of a contract to which the relevant individual is a party;
Where the processing of Personal Data is necessary for the performance of statutory duties or obligations;
Where the processing of Personal Data is necessary to respond to public health emergencies, or to protect the life, health and property safety of natural person in an emergency;
Where Personal Data are processed within a reasonable scope for the purposes of news reporting, public opinion supervision and other acts conducted in public interests;
Where Personal Data voluntarily disclosed by an individual or other Personal Data that have been lawfully disclosed are processed within a reasonable scope in accordance with this Law;
Where there are any other circumstances stipulated by laws or administrative regulations.
Where your consent is required for us to collect and process your Personal Data, we will rely on your consent, as may be directly or indirectly provided to us in the manner and form to the maximum extent permitted by Chinese law. Your consent provides us with a legal basis to collect and process your Personal Data, and you have the right to withdraw your consent at any time. Zongteng will stop the further processing of your Personal Data as soon as possible after you notify to us the withdrawal of your consent. However, this does not affect the lawfulness of the processing before consent was withdrawn.
3. How does Zongteng share, transfer and publicly disclose your Personal Data?
We will not share your Personal Data with third parties except with your explicit consent or under the circumstances of "share, transfer, and disclose your Personal Data without your prior consent". We may share your Personal Data with affiliated companies, partners and other third parties to ensure the smooth completion of the services provided to you; but we will only share your Personal Data for legal, legitimate, necessary, specific and explicit purposes , and only share the personal data necessary to provide the service. These third parties are not authorized to use the shared personal data for any other purpose. For companies, organizations and individuals with whom we share personal data, we will sign strict confidentiality agreements with them, requiring them to process personal data in accordance with our agreements and this Policy and to take appropriate confidentiality and security measures to protect the personal data. Zongteng will share your Personal Data with third parties under the following circumstances:
Share your Personal Data with affiliates of Zongteng. In order to facilitate Zongteng to provide you with services based on your service needs, your Personal Data will be shared within Zongteng’s affiliates, who will provide you with the actual services you need. In particular, when you inquire about our overseas warehousing and distribution services, we will share your contact information with the subsidiaries operating the warehousing business; when you inquire about our dedicated cross-border logistics services, we will share your contact information with subsidiaries operating dedicated cross-border logistics services.
Zongteng will not transfer your Personal Data to any company, organization or individual, except in the following cases:
After obtaining your explicit consent, Zongteng may transfer your Personal Data to other parties;
Transferred as necessary in accordance with applicable laws and regulations, legal process requirements, mandatory administrative or judicial requirements;
In the event of merger, acquisition or bankruptcy liquidation of Zongteng, or other situations involving merger, acquisition or bankruptcy liquidation, the transfer of personal information may be emerged. Zongteng will require new company or organization that holds your Personal Data to continue to comply with this Policy. If the new company or organization changes the processing purpose and processing method under this Policy, it shall obtain your consent and authorization again.
Zongteng will only disclose your Personal Data in the following circumstances:
After obtaining your explicit consent or based on your active choice, Zongteng may disclose your Personal Data;
We may publicly disclose your personal information when required by law, legal process, litigation or government authorities.
In the following situations, Zongteng is permitted to share, transfer and disclose your Personal Data without obtaining your prior consent:
Necessary to perform legal duties or legal obligations, such as legal duties or legal obligations directly related to national security, national defense security, criminal investigation, prosecution, trial and enforcement of judgments, etc.
Necessary to respond to public health emergencies, or to protect the life, health and property safety of natural persons in emergencies;
In order to protect your or other personal life, property and other important legitimate rights and interests, but it is difficult to obtain my consent;
Process your self-disclosed personal data, or other personal data that has been legally disclosed reasonably and appropriately.
Other situations stipulated by laws and regulations.
4. What measures does Zongteng take to protect your Personal Data?
Zongteng has taken reasonable and appropriate security protection measures in line with industry standards to protect your Personal Data and prevent your Personal Data from unauthorized access, public disclosure, use, modification, damage or loss. The security measures include but not limited to:
Data was encrypted by the SSL protocol when exchanging between your browser and the serve;
HTTPS protocol is used for secure browsing of websites;
Encryption technology is used to improve the security of sensitive personal information;
Trusted protection mechanisms against malicious attacks on personal data is used;
Access control mechanism is deployed to ensure that only authorized personnel can access personal data;
Security and privacy protection training courses are held to enhance our employees' awareness of the importance of protecting personal data.
The important information system of Zongteng has passed the evaluation of China's national information security level protection, and has implemented information security management system and privacy management system based on ISO/IEC 27001 and ISO27701 international standards.
Your account has security protection functions. You are expected to keep your account and password properly. Zongteng will take appropriate security measures such as back up your information and encrypt your password to prevent your information from being lost, abused and tampered. Despite the aforementioned security measures,you understand that there are no "perfect security measures" on the information network. Zongteng strongly suggests that you take active measures, including but not limited to using complex passwords, changing passwords regularly, not sending your own personal information such as account passwords to others. If you find that your personal information is leaked, especially your account number and password, please contact Zongteng immediately so that Zongteng can take corresponding measures.
After being aware of a security incident, Zongteng will inform you the basic situation and possible impact of the security incident, the countermeasures that Zongteng has taken or will take, what you can do to reduce risk, and the remedies for recovery. Zongteng will inform you of the relevant information by email, letter, telephone,notification, etc. When it is impossible for us to inform the subjects involved one by one, Zongteng will take a reasonable and effective way to publish an announcement. At the same time, Zongteng will report the security incident to the regulatory authorities if needed.
5. Where does Zongteng store and how long will Zongteng retain your Personal Data?
Under normal circumstances, the personal data about you collected by Zongteng within the territory of the People's Republic of China will be stored in the territory of the People's Republic of China.
Due to the nature of our business and the services we provide to you, we may need to transfer your Personal Data to its affiliates, subsidiaries and divisions located outside of the People's Republic of China to perform the agreement with you or for the purposes specified in this Policy. In any case where we transfer Personal Data, we shall ensure that such a transfer is subject to appropriate safeguards not lower than the protection level required under applicable laws in China. Prior to cross-border transfer or remote access, we will complete the appropriate procedures in accordance with the requirements of the relevant data protection laws and regulations.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Data, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes we process your Personal Data for, and whether we can achieve those purposes through other means.
Under some circumstances we may anonymize your Personal Data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or obtaining your consent.
If you have questions about the retention period, please contact us.
6. What rights can you exercise in relation to your Personal Data?
Based on the law applicable to the use of your Personal Data, you may have rights that you can exercise in relation to your Personal Data. Please be noted that in some cases we are not required to completely comply with your request, as such rights may be conditional or because we have to balance your rights against our rights and obligations to process your Personal Data and to protect the rights and freedoms of others. A number of the rights you have in relation to your Personal Data, as applicable in China are explained below:
Right of access
You have the right to access your Personal Data at any time, subject to exceptions provided by laws and regulations. If you wish to exercise your right of access, you may contact us at any time through the contact details set out in this Policy. You may be entitled to a copy of the Personal Data we hold about you and to learn details about how we use it. Your Personal Data will usually be provided to you digitally. We may require you to prove your identity before providing the requested information.
Right to modification
We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you believe this is not the case, you may have the right to request that any incomplete or inaccurate Personal Data that we process about you is amended.
Right to deletion
You may have the right to ask us to delete your Personal Data, for example where the Personal Data we collected is no longer necessary for the original purpose, where Personal Data has become obsolete or where you withdraw your consent (if we process your Personal Data based on consent). However, this will need to be balanced against other factors. For example, we may not be able comply with your request due to certain legal or regulatory obligations.
Right to object
You may have the right to object to processing which is based on our legitimate interests. In case of the processing of Personal Data for marketing purposes, you have the right to object at any time. When you notify us to stop using your Personal Data for marketing purposes, we will immediately cease to use your Personal Data.
For other purposes based on our legitimate interests, we will no longer process the Personal Data on that basis when you file an objection based on your grounds relating to your particular situation, unless we have a compelling legitimate ground for the processing. However, we may not be able to provide certain services if we are unable to process the necessary Personal Data for that purpose.
Right to withdraw consent
We may ask for your consent to process your Personal Data in specific cases. When we do this, you have the right to withdraw your consent at any time. We will stop the further processing as soon as possible after the withdrawal of your consent. However, this does not affect the lawfulness of the processing before consent was withdrawn.
You can use the contact details set out in this Policy to make requests regarding these rights. 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 thirty days.
We would not be able to respond to your request in the following circumstances:
If the information requested is related to our performance of legal obligations;
If the information requested is directly related to national interest, national defense;
If the information requested is directly related to public interest, public health and safety;
If the information requested is directly related to criminal investigation, prosecution, trial and execution of judgment;
If we have reasonable evidence to prove that you have malicious intent or intends to abuse your rights;
Response to your request will lead to the infringement of lawful right and interest of the data subject or other individuals, organizations.
If the information requested is related to trade secret.
7. Will there be updates to this Policy?
Zongteng may make changes or revisions to this Policy from time to time. We will not reduce your rights under laws and regulations without your express consent. When Zongteng needs to make changes or modifications to this Policy, Zongteng will take appropriate measures to inform you, consistent with the significance of the changes we make.
We will also archive older versions of this Policy on Websites for your review.
8. How to contact Zongteng?
We have set up a dedicated department for personal data protection. If you have any questions, comments or suggestions about this Policy, you can contact us at DPO@ztn.com.
Generally, we will reply within thirty days. If you are not satisfied with our reply, especially if you deem our processing has harmed your legitimate rights and interests, you can also seek help from relevant regulatory authorities.
