1. Scope, Controller and Business Context
1.1 This Privacy Policy explains how we collect, use, store, share, transfer and otherwise process personal data when you visit the Site, submit an inquiry, communicate with us by email, telephone or messaging application, or enter into a supply relationship with us.
1.2 We are the controller of the personal data described in this policy, and the "personal information handler" for the purposes of the Personal Information Protection Law of the People's Republic of China ("PIPL").
1.3Business-to-business context.The Site is a wholesale and business-to-business platform. It is directed to importers, distributors, retail chains, hospitality operators, kitchen showrooms, gifting companies and other trade buyers. It is not directed to consumers purchasing for personal, family or household purposes, and we do not knowingly collect personal data from children.
If you contact us in a personal capacity, this policy still applies to that contact, but the commercial terms in Part II are drafted for business buyers.
1.4What this policy does not cover.This policy does not apply where we process personal data on behalf of a business customer under a separate data processing agreement, nor to third-party websites, marketplaces or applications that we do not control, even where the Site links to them.
2. Personal Data We Collect
2.1Information you provide to us directly.
|
Category |
Specific data elements |
How it reaches us |
|
Inquiry and contact data |
Name, email address, company name, telephone or WhatsApp number, message content, product of interest, target quantity and destination market where you choose to include them |
The "Product inquiry" form on the Contact Us page, or direct email and messaging |
|
Business contact and transaction data |
Contact person, company name, billing and delivery addresses, shipping marks, telephone and email, order and contract details |
Email, quotation, order confirmation and contract correspondence |
|
Compliance and customs data |
Company registration or tax identifier, VAT or EORI number, end-user and end-use information, destination and consignee details |
Documents you provide for export, customs clearance and sanctions screening |
|
Correspondence data |
The content of emails and messages exchanged with our sales and service teams |
Email, messaging applications, telephone notes |
2.2Information collected automatically.When you access the Site, our systems and those of our service providers record: IP address; device type and unique device identifiers; browser type and version; operating system and language settings; referring and exit pages; pages viewed, links clicked and time spent; date and time of access; and approximate location derived from your IP address.
This information is used in aggregated or statistical form wherever practicable.
2.3Cookies and similar technologies.We use cookies, pixels, local storage and comparable technologies. Section 8 describes the categories we use, the purposes, the third parties involved and how you can control them.
2.4Information received from third parties.We may receive business contact data from our website platform provider, from analytics providers, from publicly available business directories and trade registers, from referrals, and from trade fair and exhibition contact lists.
We do not purchase consumer marketing lists and we do not acquire personal data from data brokers for advertising purposes.
2.5Children's privacy.The Site is a business-to-business platform and is not directed to children. We do not knowingly collect personal data from children under 16 years of age, and we do not knowingly process the personal data of children for marketing purposes. Where we become aware that we have collected personal data from a child under 16 without the consent of a
holder of parental responsibility, we will delete that personal data without undue delay.
Where the law of your jurisdiction sets a lower age of digital consent, we will apply that lower age in respect of the data subjects concerned. A parent or guardian who believes that a child has provided personal data to us may contact support@aurumdine.com to request deletion.
2.6What we do not collect on the Site.We do not operate an online checkout and we do not collect payment card numbers, card security codes or bank account credentials through the Site. Bank details required for invoicing are exchanged through invoices and contracts, not through the Site. We do not seek to collect special categories of personal data, such as health
data, biometric data, genetic data, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or data concerning sexual orientation.
Please do not send such data to us through the inquiry form or by email. We do not carry out automated decision-making, including profiling, that produces legal effects or similarly significantly affects you.
3. Why We Process Personal Data and Our Legal Bases
3.1 Where the General Data Protection Regulation (EU) 2016/679 ("GDPR") or the UK GDPR applies, we rely on the legal bases set out below. Where PIPL applies, we rely on the corresponding bases under Article 13 PIPL, and where consent is the basis we will seek separate consent as required.
|
Purpose of processing |
Data used |
Legal basis |
|
Responding to inquiries, preparing quotations and arranging samples |
Inquiry and contact data, correspondence data |
Steps taken at your request before entering into a contract — Article 6(1)(b) GDPR; consent or contract necessity under PIPL |
|
Concluding and performing supply contracts, arranging production, shipping, insurance and customs clearance |
Business contact and transaction data, compliance and customs data |
Performance of a contract — Article 6(1)(b) GDPR; legal obligation — Article 6(1)(c) GDPR |
|
Handling after-sales service, warranty claims and spare parts supply |
Business contact and transaction data, correspondence data |
Performance of a contract — Article 6(1)(b) GDPR; our legitimate interests in maintaining commercial relationships |
|
Operating, securing and improving the Site, including fraud prevention, abuse detection and troubleshooting |
Information collected automatically, cookies |
Our legitimate interests in operating a secure and functional website — Article 6(1)(f) GDPR |
|
Measuring Site usage and understanding which products and pages are of interest |
Information collected automatically, analytics cookies |
Consent where required — Article 6(1)(a) GDPR; otherwise our legitimate interests in understanding demand |
|
Sending business-to-business product updates, price lists, catalogue releases and trade news |
Business contact data |
Our legitimate interests in direct marketing to business contacts — Article 6(1)(f) GDPR; consent where your jurisdiction requires it |
|
Delivering, measuring and improving advertising and remarketing campaigns, where such campaigns are active |
Cookies and identifiers described in Section 8 |
Consent — Article 6(1)(a) GDPR |
|
Accounting, tax, audit, record-keeping, export control screening, dispute resolution and defending legal claims |
Business contact and transaction data, compliance and customs data |
Legal obligation — Article 6(1)(c) GDPR; our legitimate interests in establishing, exercising or defending legal claims — Article 6(1)(f) GDPR |
3.2Marketing.You may object to or withdraw from marketing communications at any time by writing to support@aurumdine.com or by using the unsubscribe link in any marketing email. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal, and it does not affect processing carried out on another legal basis.
3.3Consent.Where we rely on consent, you may withhold or withdraw it at any time without detriment. Refusing consent for non-essential cookies does not prevent you from using the Site or from contacting us.
4. How We Share Personal Data
4.1Categories of recipients.We disclose personal data only to the extent necessary, and only to the following categories of recipients:
● our website platform, hosting, content delivery and email service providers, including the operator of the platform on which the Site runs;
● freight forwarders, carriers, couriers, customs brokers, inspection bodies and insurance providers, in connection with shipping and clearance;
● banks and financial institutions, in connection with invoicing and payment settlement;
● professional advisers, including lawyers, auditors, accountants, tax advisers and insurers, under duties of confidentiality;
● analytics, consent management and advertising providers, where the corresponding cookies are active;
● our group companies and affiliates, for internal administration and customer relationship management;
● competent authorities, courts, arbitral tribunals and regulators, where disclosure is required or permitted by law, or where necessary to establish, exercise or defend legal claims;
● an actual or prospective purchaser or successor, in connection with a merger, acquisition, restructuring, financing or sale of assets, subject to confidentiality.
4.2No sale of personal data.We do not sell personal data for monetary consideration. Where our use of advertising cookies amounts to a "sale" or "sharing" for cross-context behavioural advertising under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), you have the right to opt out, and Section 9 explains how to exercise it.
4.3Processors and contractual safeguards.Recipients acting on our behalf are bound by written agreements that require them to process personal data only on our documented instructions and to apply appropriate confidentiality and security measures.
4.4Aggregated and de-
