Supplemental Privacy Notice - PIPL
1. Commitment to protecting privacy and transparency
Trade Technologies is committed to respecting and protecting the privacy rights of persons in the PRC consistent with the PRC’s Personal Information Protection Law (“PIPL”).
This Supplemental Notice - PIPL describes Trade Technologies’ commitment to the privacy of persons in the PRC.
2. Does this Supplemental Notice - PIPL apply to you?
This Supplemental Notice - PIPL applies to you (i.e., you are a “Data Subject”) if:
- You are a Person or Data Subject meaning a natural person, not a corporation, partnership, or other legal entity;
- Trade Technologies handles your Personal Information inside the borders of the PRC.
- You are physically located in the PRC, and
- Trade Technologies handles your Personal Information outside the borders of the PRC in order to 1) provide you goods or services, 2) analyze or assess your activities, or 3) comply with other circumstances as provided by laws or administrative regulations.
"Personal Information” means any information relating to an identified or identifiable natural person, not including information after anonymization handling. For the purposes of PIPL, "anonymization" refers to the process of personal information undergoing handling to make it impossible to distinguish specific natural persons and impossible to restore.
If you are located outside the PRC and you provide your Personal Information to Trade Technologies outside the PRC, this Supplemental Notice – PIPL does not apply to that information.
3. What are your rights as a Data Subject?
As a Data Subject pursuant to the PIPL, you have certain rights. This section of the Supplemental Notice - PIPL summarizes these rights and how you can exercise them. More detail about each right, including exceptions and limitations, can be found in Articles 15 and 44 through 50 of the PIPL.
Please note: Nothing in this Supplemental Notice - PIPL is intended by Trade Technologies to waive sovereign immunity or any other defenses or immunities afforded by any or all U.S. federal laws, U.S. state laws, PRC law, or international law.
Right to know and make decisions
You have the right to know and make decisions about the processing of your Personal Information, and the right to limit or refuse the handling of your Personal Information by others, unless otherwise provided for by law.
If the purpose or method of processing your Personal Information or the type of Personal Information or who has access to your Personal Information changes, you will be notified and asked to re-consent to the change(s).
Right to consult or copy
You have the right to consult or copy your Personal Information, except when it is necessary for Trade Technologies to maintain confidentiality or when otherwise provided for by applicable law. Trade Technologies will respond to your requests to consult or copy your Personal Information in a timely manner.
Right to request transfer
You may request that Trade Technologies transfer your Personal Information to another personal information handler. If Trade Technologies is permitted to make the transfer under applicable law, Trade Technologies will facilitate the transfer.
Right to have inaccurate Personal Information corrected or supplemented
You have the right to request that Trade Technologies correct any inaccurate Personal Information that it maintains about you. You also have the right to request that Trade Technologies complete any incomplete Personal Information that it maintains about you, which could be accomplished by incorporating a supplementary statement that you submit. If Trade Technologies concurs that the Personal Information is incorrect or incomplete, Trade Technologies will correct or complete it in a timely manner.
Right to request deletion
You have the right to request the deletion of Personal Information that Trade Technologies maintains about you in certain circumstances. These circumstances are identified in Article 47 of the PIPL and include that the Personal Information is no longer necessary in relation to the purpose(s) for which it was collected.
Subject to applicable U.S. federal and state law and Trade Technologies policies, including but not limited to Trade Technologies Privacy Statement, and provided that there are no overriding legitimate grounds for Trade Technologies to retain the Personal Information, Trade Technologies will comply with deletion requests meeting the requirements of applicable law. For the avoidance of doubt, where deletion has been requested but is technically hard to realize, Trade Technologies shall cease processing the Personal Information other than for storage and taking necessary security protective measures.
Right to have the rules of processing explained
You have the right to request that Trade Technologies explain to you the Personal Information handling rules.
Right to withdraw consent
If the basis for processing your Personal Information is consent, you may revoke your consent at any time. Upon receipt of your notice withdrawing consent, and if there are no other legal grounds for the processing, Trade Technologies will stop processing the Personal Information unless the processing is necessary for the establishment, exercise, or defense of legal claims or is otherwise permitted by applicable law. Revoking consent does not affect the lawfulness of processing that occurred before the revocation.
Your refusal to provide consent or your subsequent withdrawal of consent will not impact your ability to access Trade Technologies goods and/or services, to the extent such goods and/or services are applicable to you; provided however, it may prevent provision of Trade Technologies goods and services that are dependent on such a consent.
Right to file a lawsuit
If Trade Technologies rejects your request to exercise your rights, you may file a lawsuit in a court of competent jurisdiction according to the law.
4. How to exercise your rights
At that time, you will be asked to: 1) identify yourself; 2) provide information to support that the PIPL applies to you (see Section 2, above); 3) identify the specific information or data that you are concerned about; and 4) state what right(s) you wish to exercise.
To expedite processing your request, please identify the data collection location (e.g., the website where your Personal Information was collected), if known.
In the event of a death, the next of kin of a deceased natural person may exercise the rights of an individual provided in this PIPL Supplement, such as the right of consulting, copying, correcting, and or deleting Personal Information of the deceased as detailed above, except where the deceased natural person has arranged otherwise before his/her death.
If your request to exercise your rights under PIPL is rejected, Trade Technologies will explain the reason.
5. How does Trade Technologies respond to requests for Personal Information?
In addition to the rights provided by the PIPL, you may also have rights with respect to your Personal Information pursuant to U.S. federal law, state law, and Trade Technologies policy. When you submit a request to Trade Technologies to exercise your rights, Trade Technologies will respond in accordance with existing Trade Technologies policies and procedures that implement the relevant privacy law(s).
6. Existence of automated individual decision-making
Trade Technologies may use automated decision-making, including profiling, to help identify prospective customers of Trade Technologies. The logic takes an all-factor approach to assessing a possible customer’s propensity to purchase Trade Technologies Services and may result in a prospective customer being contacted to explore sales opportunities. For the purposes of the PIPL, “automated decision-making” refers to the activity of using computer programs to automatically analyze or assess personal behaviors, habits, interests, or hobbies, or financial, health, credit, or other status, and then to make decisions based on the analysis of such information.
You will not be subject to a decision having a major influence on your rights and interests based solely on automated processing, including profiling, unless you explicitly consent.
7. Transfer of Personal Information outside the PRC
Trade Technologies is based in the U.S. and is subject to U.S. and Texas law. Personal Information that you provide to Trade Technologies will generally be hosted on U.S. servers. To the extent that Trade Technologies needs to transfer your information either (a) from the PRC to the U.S. or another country or (b) from the U.S. to another country other than the PRC, Trade Technologies will do so consistent with applicable law governing such transfers. To support such transfers, Trade Technologies will generally enter into a contract containing certain standard terms to clearly establish the rights and responsibilities of the parties to the transfer.
In addition, to the extent the following information is not included in this Supplemental Notice – PIPL, Trade Technologies will notify you of the of the name and contact information of the overseas recipient, the purpose of the transfer and method of processing, the type of Personal Information involved, and how you can exercise your rights. Trade Technologies will also obtain your separate consent to the transfer unless such separate consent is not required by applicable law.
8. How do I contact the personal information handler?
9. Updates to Supplemental Notice - PIPL
Trade Technologies may update this Supplemental Notice - PIPL from time to time. Any changes will become effective upon posting of the revised Supplemental Notice - PIPL.
Posted: April 12, 2023
Effective: May 12, 2023
Last revised: May 12, 2023