Privacy Policy

Effective as of June 30, 2021

Note: this Privacy Policy applies to the collection, use and disclosure of information in connection with the products and services offered by Thundercomm Technology Co.,Ltd. through https://www.thundercomm.com

We at Thundercomm Technology Co.,Ltd. (“we”, “us”,  “Thundercomm”) recognize the importance of privacy and confidentiality of personal information. 

https://www.thundercomm.com (“Website” or “Platform”) is not only our official website, but also our E-commerce platforms.

This Privacy Policy sets out the ways in which Website collect, use and disclose information in connection with its operation of the Platform including personal information about Platform visitors and client (“you”).  This Privacy Policy also applies to use of our Platform via a mobile device, either through mobile applications or mobile-optimized websites.

If you have any questions or concerns about the use of your personal information, then please contact us using the contact details provided at section J “HOW TO CONTACT US” the bottom of this Privacy Policy.

A. COLLECTION OF INFORMATION

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

Information you provide to us

  • When you register for an account on Platform, we will ask you to provide the required specific contact information, including your email address, country of residence, company name and telephone number.
  • When you place an order on the Platform, we will ask you to provide the necessary specific contact information, including the country of receipt, postal code, full address, recipient’s name, company name, telephone number, user email address.
  • If you need an invoice, we will ask you to provide the relevant invoice information, including invoice title, duty paragraph, unit address, bank of deposit, the bank account.

Information that we collect automatically

  • If you contact us (such as via our customer services department chat service, telephone or email), we may record a copy of your correspondence and may ask for additional information to verify your identity.
  • We will collect contact details and other information of users from publicly available sources for the purposes of verifying the users and performing due diligence on the users.
  • We will collect details of user activities, transactions and interactions on the Platform including information relating to the types and specifications of the products and services purchased, pricing and delivery information, dispute and complaint records.
  • From time to time, we may also collect information about the existing and prospective users, during or in connection with trade shows, industry events and/or other functions. Including representative contact names, addresses, phone numbers, fax numbers and email addresses.
  • If you visit our Platform, we will automatically collect certain information from your device. In some countries, including countries in the European Economic Area, this information may be considered as personal information under applicable data protection laws. Specifically this information may include IP addresses, device type, unique device identification numbers, browser type, geographic location, browsing patterns and details of how you have interacted with our Platform and the goods and services available on it. In addition, we gather statistical information about the Platform and visitors to the Platform including, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Collecting this information enables us to better understand the visitors who come to our Platform, where they come from, and what content is of interest to them.  We use this information for our internal analytics purposes and to improve the quality and relevance of our Platform. Some of this information may be collected using cookies and similar tracking technology, as explained further under the section E “COOKIES” below.

B. USE OF PERSONAL INFORMATION

We collect and use your personal information for the following purposes:

  • verifying your identity and conducting security, KYC (know-your-customer), export control and economic sanctions compliance and anti-money laundering due diligence and background checks in order to set up user accounts;
  • verifying your eligibility to register as a Platform user in accordance with our Terms of Use; 
  • setting up / administering user accounts, including providing log-in IDs and developing a Platform profile;  
  • providing users with customer service support; responding to queries, feedback, and managing claims and/or disputes;
  • providing logistics and warehousing services (including, without limitation, customs clearance declarations via the Platform);
  • facilitating customs clearance declarations / applications via the Platform;
  • assessing and monitoring account security and transaction risks of users of https://www.thundercomm.com , detecting and preventing fraud, money laundering and other security incidents; 
  • performing research or statistical analysis in order to improve the content and layout of the Platform, and to improve the product offerings and services on https://www.thundercomm.com, including, for example, using anonymized data for machine learning purposes;
  •  when you use services that require access to contents stored in and/or functions on your devices (including but not limited to contacts in address book, photos, videos, microphone and/or camera), we use your photos, videos, contact information in your address book, and other personal information to respond to your requests, provide the requested services to you, and improve our services.

We may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

C. DISCLOSURE OR SHARING OF PERSONAL INFORMATION

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

  • Third party business partners, service providers and/or affiliates of Thundercomm Technology Co.,Ltd. engaged by us or working with us to assist us to provide services to you or who otherwise process personal information for purposes described in this Privacy Policy or notified to you when we collect your personal information.  Categories of these partners or service providers include:
    • Affiliates of Thundercomm Technology Co.,Ltd. and/or their designated service providers that work with us to provide processing services such as software, tools, systems and messaging services for purposes described in this Privacy Policy; 
    • our business partners (for example, in order for them to provide you with discounts or offers that may interest you);
    • payment service providers who collect and process personal information to assist with settling the payments for transactions or process withdrawal requests for Sellers. The activities of payment service providers may be governed by their own privacy policies, not this Privacy Policy; 
    • credit risk assessment providers to conduct risk assessment on Sellers to determine whether a Seller can be permitted to make a fund withdrawal;
    • logistics partners for providing delivery services for Buyers, including return and exchange of products, and warehousing services for Sellers;
    • custom agents for customs clearances purposes;
    • cloud computing service providers to provide cloud storage services;
    • customer service providers to provide after-sale services; 
    • risk control service providers to assess the security of users’ accounts and transaction risks; and
    • To our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations where we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person, we may also disclose and transfer your personal information or as otherwise required or permitted by applicable laws.
    • To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
    • To any other person 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. 

D. RETENTION

We retain your personal information as long as we have an ongoing legitimate business need to do so for example to provide services or products 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. 

E. COOKIES

What Cookies are？

Cookies are tiny data files that some websites place on your computer or other device when you visit. They are used by many website owners, including us. Cookies are linked to the machine you use to visit Platform and not to you as an individual. Unless you login or provide personal data through your use of Website, no personal information is collected. Cookies are commonly used by websites to remember some aspect of your current or previous visit. This could include things like the choices you have made or preferences you have chosen during your visit. Websites commonly do this in order to improve or tailor your current and future visits to that site or other related sites.

The information stored in a cookie can only be read by the website that placed the cookie or other sites that it has agreed to share information with.

Our policy on Cookies

Our policy is to use cookies only to improve the way we do business with you or when they are essential to the way the site works.

The types of activities we may use cookies for are to:

  • store details that help you to manage accounts and policies online, such as user login details.
  • find out how people use our sites, such as how often they visit, which pages they go to, and which links they click on, so that we can improve our sites.
  • help us to provide relevant information, such as details of products, services and other information that you may be interested in.

How can you turn off Cookies?

You can turn off cookies in your browser settings. If you do turn them off, it is important to remember that you may not be able to use some of the services on our website.

 F. MINORS

The Sites and their contents are not targeted to minors (those under the age of 18) and we do not intend to sell any of our products or services to minors. If a minor has provided us with Personal Data without parental or guardian consent, the parent or guardian should contact service@thundercomm.com to remove the information.

G. SECURITY MEASURES

We employ commercially reasonable security methods to prevent unauthorized access to the Sites, to maintain data accuracy and to ensure the correct use of the information we hold.

For registered users of the Sites, some of your information can be viewed and edited through your account, which is protected by a password. We recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not choose to save your log-in information (e.g., user ID and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session.

No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect the information we hold for you, we cannot guarantee the security of any information you transmit to us and you do so at your own risk. 

H. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on the Platform. Once posted on the Platform, the new Privacy Policy will be effective immediately. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice. 

I. VISITORS FROM THE EUROPEAN UNION

This section of the Privacy Policy applies only if you use our Platform or services covered by this Privacy Policy from a country that is a Member State of the European Union and in the event of and from the date of the UK’s departure from the European Union, the United Kingdom (the “EEA“), and supplements the information in this Privacy Policy. 

If you are in the EEA the data controller of your personal information is Thundercomm Technology Co.,Ltd. . For contact details, please see section J. “HOW TO CONTACT US” below. 

Legal basis for data processing

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

  • Ensure that you can properly browse and purchase on the platform;
  • necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement);
  • necessary for our legitimate interests and not overridden by your rights; and/or；
  • where it is based on your consent.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Platform and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Platform and our services, undertaking marketing, or for the purposes of ensuring the security of our Platform and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time. We will advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). In some instances, you may be required to provide us with personal information for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Platform.

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 under section J. “HOW TO CONTACT US”  below.

International transfers of personal information

In connection with our provision of the Platform and its connected services, we may transfer your personal information to countries outside of the EEA, including to countries that may not provide the same level of data protection as your home country such as the United States and China. We take appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and we implement appropriate measures to ensure your personal information will remain protected in accordance with this Privacy Policy, such as standard contractual clauses. A copy of those clauses can be requested from service@thundercomm.com.

Your rights

If you are a resident of the EEA, you also have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided under section J. “HOW TO CONTACT US”   below:

  • The right to access, correct, update or request deletion of your personal information. 
  • The right to object to processing of your personal information when it is based on our legitimate interests, and separately the right to object to direct marketing.
  • The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.
  • If we have collected and process your personal information with your consent, then 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 a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected.

J. HOW TO CONTACT US

If you have any requests, questions or concerns about our use of your personal information and this Privacy Policy, please contact us at service@thundercomm.com.

K. LANGUAGE

If there is any conflict between the English version and another language version of this Privacy Policy, the English version shall prevail.