Sourcetrium attaches great importance to the protection of personal data. This policy explains what data we collect, why, how we protect it and what your rights are.
1. Data controller
Yiwu Ninglian Trading Co., Ltd. (义乌宁联贸易有限公司), a company established in China, 800 Chouzhou North Road, Choucheng Subdistrict, Yiwu, Jinhua, Zhejiang Province, China, registered under number 91330782MAK39MTE4D (Unified Social Credit Code). Contact for any data-related question: contact@sourcetrium.com.
[TO BE COMPLETED BASED ON YOUR LAWYER'S ADVICE: contact details of the representative in the European Union under Article 27 of the GDPR, if its appointment is required.]
2. Applicable laws
As Sourcetrium is a Chinese company offering its services to customers located, in particular, in the European Union, our processing takes into account the Personal Information Protection Law of China (PIPL) and the European Union's General Data Protection Regulation (GDPR), where it applies.
3. The data we collect
On the website (quote form and appointment booking)
- name, company or shop, e-mail address, delivery country;
- sector, estimated quantity, project description;
- if you book an appointment: the chosen time slot and your time zone.
As part of the customer relationship (customer file, in your TriumHub space)
- company name, registered office address, tax and registration identifiers;
- identity of the company's representatives;
- the company's legal documents;
- identity document of the managing director.
This information is necessary to verify the identity of our customers ("KYC" procedure), draw up contracts and invoices, prepare transport and customs documents, and prevent fraud.
Technical data
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4. Why we use your data
| Purpose | Legal basis |
|---|---|
| Responding to your quote request and arranging an appointment | Pre-contractual measures at your request |
| Verifying our customers' identity (KYC) and preventing fraud | Legal obligations and legitimate interest |
| Performing our services, drawing up contracts and invoices | Performance of the contract |
| Preparing transport and customs documents | Performance of the contract and legal obligations |
| Complying with our accounting and legal obligations | Legal obligations |
For the managing director's identity document, which is sensitive data under the PIPL, we obtain your specific consent.
5. Who has access to your data
- Sourcetrium's founders and authorised staff, only when necessary;
- our technical service providers: website hosting (Cloudflare), [TO BE COMPLETED: host and developer of the TriumHub portal];
- freight forwarders and customs authorities, for the data required for import formalities;
- the authorities, where required by law.
We never sell your data. Partner factories do not receive your identity documents.
6. Where your data is stored
- form and appointment data is hosted by Cloudflare, in a database located in Europe;
- customer file data is stored in the TriumHub portal: [TO BE COMPLETED: location of the portal's servers].
[TO BE COMPLETED WITH YOUR LAWYER: safeguards governing data transfers between the European Union and China.]
7. How long we keep it
- quote requests not followed up: [TO BE COMPLETED: period, e.g. 3 years after the last contact];
- customer data and contractual documents: for the duration of the business relationship, then [TO BE COMPLETED: legal retention period];
- managing director's identity document: [TO BE COMPLETED: minimum necessary period], then deletion.
8. How we protect your data
Access limited to authorised persons, secure connection (HTTPS), [TO BE COMPLETED: TriumHub portal measures, e.g. document encryption, two-factor authentication, access logs, backups].
9. Your rights
Depending on the applicable law, you may request access to your data, its rectification, erasure, the restriction of or objection to processing, its portability, and withdraw your consent at any time. Write to us at contact@sourcetrium.com. You may also lodge a complaint with the data protection authority of your country.
10. Changes
This policy may change. The version in force is the one published on this page.
Last updated: [TO BE COMPLETED: publication date].