Privacy Policy

TABLE OF CONTENTS

1.Information We Collect and How We Collect It

• A. Information You Provide
• B. Information We Collect Automatically
• C. Information We Receive From Third Parties
• D. No Information from Children

2.How We Use Personal Information

3.How We Share or Disclose Personal Information

4.How we Store your Personal Information

• A. Storage and Security
• B. Retention

5.Cookies Policy

• A. Types and Uses of Cookies
• B. Managing Cookie Preferences

6.International Use of the Services and Transfer of Information Outside the European Union

• A. Legal Basis for Processing Personal Information
• B. Transfers of Personal Information Outside the EU
• C. Data Controller
• D. Your Data Protection Rights
• E. Do Not Track Signals

7. How to Contact Us

TradeBeyond Limited (“TradeBeyond”, “we”, “us” and “our”) offers a platform, software and services to enable connections among business parties such as buyers (“Buyers”) and suppliers (“Suppliers”) for product development, sourcing and related business purposes (such platform, software and services, collectively, the “Services”) via websites, mobile sites and mobile applications, including: (a) the web and mobile-optimized versions of the websites identified by the uniform resource locator “www.tradebeyond.com” and (b) the mobile applications of TradeBeyond’s platforms (collectively, the “Sites”).

We are committed to respecting and protecting the privacy rights of our Users, and we created this Privacy Policy to give you notice of how your individual information we collect in connection with our provision of the Sites and Services will (and will not) be used by us. By accessing and/or using any of the Sites, Services, Site Content, and/or registering with TradeBeyond, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, store, process and share your information in the following ways.

Remember that use of the Services is at all times subject to TradeBeyond’s Terms of Use (https://tradebeyond.com/terms-of-use). Any terms used but not defined in this Privacy Policy have the definitions given to them in the Terms.

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on our Site. Once posted, the new Privacy Policy will be effective immediately. You can see when this Privacy Policy was last updated by checking the “last updated” or “effective” date displayed at the top of this Privacy Policy.

If you have any questions or concerns about the use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Policy.

1. Information We Collect and How We Collect It

The personal information that we may collect about you broadly falls into the following categories:

A. Information You Provide

• When you register with us as a Member, you will be asked to provide certain identification and contact information about you and your Company, such as your name, Company name, principal business address, job title, department, phone number, and email address.
• Depending on the Services you choose to use, you may be asked to provide some additional information, such as corporate registration, business license and certificate information.
• If you decide to subscribe to some of our Premium Services, we will need you to provide certain billing and payment information.

B. Information We Collect Automatically

• We collect details of User activities and interactions in the Services, including information related to the products and product requirements that Members may share and communicate between them.
• If you contact us (such as via our customer service department, by phone, email or online chat), we may keep a record of your contact information and correspondence, including your questions, comments, feedback, and any additional information we may ask you so we can verify your identity.
• We collect certain information from your devices. In some jurisdictions, including countries governed by the General Data Protection Regulation (“GDPR”) of the European Union (“EU”), some of this information may be considered personal information under applicable data protection laws. Specifically, this information may include IP addresses, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location), browsing patterns and details of how you have interacted with our Sites and Services. In addition, we gather statistical information about uses of the Sites and Services including, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique users. Collecting this information enables us to better understand how our Sites are accessed and our Services are used, and we use this information for our internal analytics purposes and to improve the quality and relevance of our Services.

C. Information We Receive From Third Parties

• We may receive information about you from Buyers who invite you to join their networks and sign up for our Services. This may include your name, Company, email address, and other contact information.

D. No Information from Children

• The Services are not intended for children under the age of thirteen (13) and we do not knowingly collect personal information from children. Per the Terms, Users must be at least eighteen (18) years old or of legal age of consent and fully able and competent to enter into and abide by and comply with the Terms. If we become aware that we have inadvertently received personal information from a User under the age of 13 through the Services, we will delete such information from our records.

2. How We Use Personal Information

We use the information we collect about you for the following purposes:

• Providing you with the Services for which you have registered, and entering into and performing under any contracts we may have with you;
• Checking your identity and eligibility to register as a Member in accordance with our Terms;
• Setting up / administering your account, including providing your login ID and creating your Member profile;
• Personalizing our communications with you;
• Facilitating communications between Members via the Services;
• Sending you business messages such as those related to payments or expiration of your subscription;
• Providing customer service support, including responding to questions and managing claims and/or disputes;
• Performing research and statistical analysis to better understand how our Sites are being accessed and how our Services are being used, to identify and develop Services and improve the quality and relevance of our Services;
• Diagnosing problems, reducing fraud and software piracy, and protecting you, other Users and Members, as well as TradeBeyond;
• Where required by law or where we believe it is necessary to protect our legal rights, interest, and the interests of others, to protect our legitimate business interests and legal rights in connection with legal claims, compliance, regulatory, and audit functions; and
• Sending you information about TradeBeyond, new releases and Services, special offers, and similar information, in accordance with applicable laws. Where we are required by applicable law, we will seek your consent prior to sending you communications for marketing purposes.

We may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as for reasons of scientific or historical research if appropriate technical and organizational measures such as anonymization or encryption are implemented, for protecting the vital interests of you or another party, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us) if and where this is required or permitted by applicable data protection laws.

3. How We Share or Disclose Personal Information

We may disclose (or provide access to) personal information to the following categories of recipients:

• Other Members of the Services in connection with the facilitation of communications made between you and the other Members. We expect you to respect the rights of the Members whose information you receive and that you will not use such information without the consent of that Member except as needed in connection with the Services and any resulting transactions.
• TradeBeyond’s affiliates and/or third-party service providers engaged by us or working with us to assist or support us in providing the Services to our Users (such as website or database hosting companies, authentication providers, credit card payment processors, e-mail service providers, customer support service companies, analytics companies, and other similar service providers that use such information on our behalf) (“Third Party Service Providers”). Unless otherwise stated in this Privacy Policy, these Third Party Service Providers do not have the right to use the personal information we provide to them other than to assist or support us in providing the Services.
• To our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations in response to subpoenas, court orders, warrants, or legal process or where we believe it is necessary to comply with applicable laws, to exercise, establish or defend our legal rights, or if we believe you will harm the property or rights of TradeBeyond or those of any other party, as required or permitted by applicable laws.
• To an actual or potential buyer or successor (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, or other business transition, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
• To any other party with your consent to the disclosure.
  We may provide aggregated or anonymized data to third parties, but when we do so, the information we share is in a de-identified format that does not personally identify you.

4. How we Store your Personal Information

A. Storage and Security

The security of your personal information is important to us. TradeBeyond operates or leases secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary. Notwithstanding such measures, remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Your Member account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and individual information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

B. Retention

We retain your personal information as long as we have an ongoing legitimate business need to do so, including providing the Services to you or as required or permitted by applicable laws, such as tax and accounting laws.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. Cookies Policy

The Sites employ “cookies” when a User visits the Sites. In general, cookies are small pieces of text that are saved on a website or app visitor’s device by the website server or app. They enable a website/app to remember small amounts of information between pages or visits.

A. Types and Uses of Cookies

The types we use are:

• Essential cookies strictly necessary to enable Users to use our Services as they expect and to ensure proper performance, security, and functionality, such as navigating through pages of the Sites, accessing secure portions of the Services, authenticating Users, and helping prevent unauthorized use of a Member’s account. Without these cookies, the Sites and Services cannot function properly;
• Personalization and preference cookies, such as those remembering login information or storing a User’s settings and browsing preferences. Loss of these cookies may restrict or make a User’s experience with the Sites/Services less convenient or operational;
• Statistical cookies. We use this information for analyzing data in aggregate form to help us better understand how Users access and interact with the Sites and Services and to improve the quality and relevance of our Services.

The cookies we use do not contain a User’s name, address, phone number, email address, or anything to personally identify a User. Where required by applicable law, we seek to obtain the User’s consent before using cookies. Where the installation of cookies is based on consent, such consent can be freely withdrawn at any time as described below.

We use Google Analytics (“GA”), a web analytics service provided by Google, Inc. that tracks and reports website traffic. GA allows us to analyze use of the Sites/Services by providing us information such as counts of pages viewed on the Sites, the number of unique visitors, number and length of sessions, certain attributes of the browser software, operating systems, and hardware used by visitors of the Sites, and by compiling reports on activities related to the Sites. For more information about Google Analytics cookies, visit: https://support.google.com/analytics/answer/6004245.

B. Managing Cookie Preferences

Users can manage preferences for cookies directly within the privacy settings of their browsers and devices, including preventing cookie files from being installed or erasing those previously installed. Because each browser and device system handles this differently, you should check the help function of your browser and device for more information. The domain we use to set cookies is tradebeyond.com.

6. International Use of the Services and Transfer of Information Outside the European Union

This section of the Privacy Policy may apply to you depending on the data protection laws in your jurisdiction, including if you use our Services in a jurisdiction covered by the GDPR, and in the event of and from the date of the United Kingdom’s departure from the European Union, the United Kingdom, and supplements the information in this Privacy Policy.

A. Legal Basis for Processing Personal Information

We process personal information for the purposes set out in this Privacy Policy. Our legal basis for processing personal information will depend on the personal information concerned and the specific context in which we collect it. We will normally collect and process personal information about you only where it is:

• necessary for entering into contracts with you and performing our obligations under those contracts, such as to open your Member account or to perform obligations regarding the Services;
• necessary for compliance with applicable legal obligations;
• to satisfy a legitimate interest (including uses listed in Section 2 above) that is not overridden by your data protection rights;
• necessary to protect your vital interests;
• necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us as the data controller; and/or
• based on your consent for specific purposes, such as for marketing outreach.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided in Section 7 How to Contact Us.

B. Transfers of Personal Information Outside the EU

In connection with our provision of the Services, we may host and operate the Services in and transfer your personal information to countries outside of the EU, including countries, such as the United States, that may provide different levels of data protection as your home country. You therefore consent to the transfer of information to and storage of information in countries outside of your domiciled country and the EU. We take steps to ensure that recipients of your personal information are bound to duties of confidentiality and we implement measures to protect your personal information in accordance with this Privacy Policy.

C. Data Controller

TradeBeyond Limited will be the data controller under the GDPR of your personal information provided to or collected by us in connection with the Sites and Services.

D. Your Data Protection Rights

You also may have certain data protection rights (including if you are a “data subject” under the GDPR), which rights you may exercise as described here or by contacting us using the contact details provided below in Section 7 How to Contact Us.

• The right to access, rectify, or request deletion of your personal information. You can access your personal information via the Services, and you can make most corrections and updates by logging in to your Member account and editing the information. Please contact us if you need assistance. If you request deletion of your personal information, we will take reasonable efforts to do so upon such request in accordance with applicable law and our retention policy set forth in Section 4.B. above.
• The right to object to certain processing of your personal information when it is based on our legitimate interests.
• The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.
• The right to opt-out at any time of marketing communications, if any, that we send you. You can exercise this right by clicking on “unsubscribe” or “opt-out” options or links we provide or by contacting us.
• If we have collected and processed your personal information on the basis of your consent, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• The right to complain to your local data protection authority about our collection and use of your personal information, but we ask that you please contact us first. We will endeavor to respond to all Users requesting to exercise their data protection rights in accordance with applicable data protection laws.

E. Do Not Track Signals

Some web browsers have incorporated “Do Not Track” (“DNT”) features, which, when turned on, send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret DNT signals, nor a common definition of “tracking,” we currently do not respond to DNT signals on the Sites.

7. How to Contact Us

If you have any requests, questions or concerns about our use of your personal information or this Privacy Policy, please contact us at privacyinfo@tradebeyond.com, or write to us at: Trade Beyond Limited, Unit 1601-04, 909 Cheung Sha Wan Road, Lai Chi Kok, Kowloon, Hong Kong, Attn: Privacy Officer.