This Privacy Policy (hereinafter referred to as the “Policy”) introduces the types, collection methods, usage, scope, disclosure, cross-border transfer, and protective measures related to your personal data collected by Kerry Logistics Network Limited (Shenzhen) (hereinafter referred to as “We” or “KEC International Transhipment”).

Additionally, through this Privacy Policy, you can understand how to request KEC International Transhipment to:

1. Inquire, modify, or delete personal data related to you held by KEC International Transhipment;
2. Handle complaints or appeals related to KEC International Transhipment’s privacy matters.

Before using KEC International Transhipment’s services, please carefully read this Policy so that you can better understand our products and services and make appropriate choices. When you use our services within the territory of the People’s Republic of China, your personal data will be handled by Kerry Logistics Network Limited (Shenzhen).

Unless otherwise provided by law, administrative regulations or policies, you have the right to be informed and decide on how we handle your personal data, including rights to restrict or refuse our or other parties’ processing of your personal data; for provisions related to your rights (potentially) that are significantly connected to you and sensitive personal data (as defined in Section 2.1), the handling thereof will be clearly emphasized in this Policy to help you understand more clearly. At the same time, you have the right to request clarification of our personal data processing rules. Based on this, we strongly recommend that you carefully read the relevant explanations and fully understand the Policy content before giving consent. KEC International Transhipment will collect, store, use, share, and protect your personal data in accordance with this Policy.

1. Applicability of This Policy to You

1.1 If you are a customer of KEC International Transhipment or access KEC International Transhipment’s website https://vip.kec-tranship.com/ and APP (collectively referred to as “Website”), then this Policy applies to you.

1.2 KEC International Transhipment places great importance on protecting children’s personal data. If you are a child under 14 years old, you must first obtain consent from your guardian before using our products or services. KEC International Transhipment protects children’s personal data based on the laws and regulations of the People’s Republic of China (hereinafter referred to as “China”).

We will never directly collect personal data from children. Regarding the collection of children’s personal data with guardian consent, we will only use, share, transfer, or disclose such data within the conditions permitted by Chinese law, guardians’ consent, or where necessary to protect children. If there is evidence that children use our products or services without guardian consent, we will negotiate with the guardian and strive to delete the related personal data as soon as possible.

2. Basic Principles for Handling Your Personal Data

The important definitions in this Policy are based on the Personal Information Protection Law of the People’s Republic of China (hereinafter referred to as “Personal Information Protection Law”) and Information Security Technology – Personal Information Security Specification (GB/T35273-2020, hereinafter “Personal Information Security Specification”), and adapted to our actual circumstances to supplement these definitions. In case of inconsistencies, adherence to the regulations in the Personal Information Protection Law and Personal Information Security Specification shall prevail.

Please note that the core purpose of this section is to guide you to fully understand the methods, scope, and consequences of our processing of your personal data so that you can give informed consent accordingly. KEC International Transhipment will collect, store, use, share, and protect your personal data in accordance with this Policy.

2.1 Definitions

• Personal Data: Refers to various types of information recorded electronically or by other means related to identified or identifiable natural persons, such as phone numbers, personal account information, IP addresses, etc.
• Sensitive Personal Data: Refers to personal data that, once disclosed, illegally provided, or misused, can potentially threaten personal physical and financial security, easily leading to personal defamation, physical harm, or discriminatory treatment. This includes biometric identification, religious beliefs, specific identities, medical health, financial account information, behavioral trajectory data, and personal data of minors under 14 years old. In this Policy, sensitive personal data will be indicated in bold font to draw your attention and obtain your specific consent, and you should pay additional attention to this category of information.
• Personal Data Processor: Refers to an organization or individual who autonomously determines the purpose and methods of personal data processing activities.
• Processing: Includes collecting, storing, using, modifying, transmitting, providing, disclosing, and deleting personal data. For details on how we collect and use your personal data, please refer to Section 3, How We Collect and Use Your Personal Data.
• Providing to Third Parties: Refers to personal data processors providing personal data to other personal data processors and processing personal data according to the type, purpose, and method notified to the personal data subject.
• Commissioned Processing: Refers to a personal data processor entrusting another party to process personal data on their behalf and supervising the other party’s data processing activities. The entrusted party may only process personal data within the scope of authorization provided and may not delegate the processing to others without approval by the personal data processor.

Furthermore, personal data collected by us based on products should be retained on servers located within the territory of the People’s Republic of China according to the latest legal requirements. If cross-border transmission of your personal data is necessary, we will strictly abide by relevant laws and regulations, conduct necessary evaluation procedures, and if the legal, regulatory, and supervisory requirements are unmet, we will not provide your personal data to overseas entities. When transferring your personal data overseas, we will ensure compliance with internationally accepted data protection standards such as the General Data Protection Regulation (GDPR) by the European Union to protect the security of your personal data. For cross-border personal data transmission, we must clarify and ensure compliance with the applicable international data transmission agreements and protective measures.

3. Purposes and Scope of Our Collection and Use of Personal Data

To comply with national laws and regulations and fulfill the service functions described in this Policy, we will lawfully, properly, necessarily, and in good faith collect and use the personal data described below, which arises from your active provision or caused by using our services.

3.1 Registration and/or Login

To complete account registration and/or login, you will be required to provide your WeChat nickname (if you choose WeChat login), mobile phone number and verification code (if using mobile login), and/or Apple ID (if using Apple login). These pieces of information are necessary; if you do not provide them, you will not be able to complete registration and/or login.

3.2 Package Delivery

To help you complete sending, receiving, and express mail services, you need to provide us with package tracking number, sender’s name, sender’s contact details, sender’s address, recipient’s name, recipient’s contact details (phone, email), recipient’s address, recipient’s local postal code, front desk collection phone, expected pickup time, goods information (estimated weight, whether the goods contain sensitive items, goods value, remarks), international channels. This information is necessary; refusal to provide it will prevent us from providing package delivery services to you.

If you send special goods requiring a controlled logistics route, you also need to provide us with product name, category, external packaging weight, transportation mode, time requirements, needs description, WeChat number, product photos. This information is necessary; refusal will prevent us from providing specialized logistics services.

If the recipient is not you personally, you guarantee that the recipient has clearly agreed that your submitted information will be provided to us by the recipient. Otherwise, you will bear the corresponding legal consequences.

3.3 Recharge Management

To conduct recharge services, we may collect your transaction flow number, payment order number, third-party transaction number, recharge method, transaction type, recharge amount, account balance, and details.

3.4 Coupon Management

To provide you with coupon redemption and usage services, we may collect your coupon name, redemption code, redemption time, usage period, coupon value.

3.5 Order Management

For your convenience in order management, we may collect your order information during purchase, redemption, or use of products or services, including order number/ID, suborder number, order time, package pictures, express quantity, package number, international logistics order number, KEC International Transhipment logistics order number, transportation fee, insurance fee, remarks, payment status, payment amount, payment time, payment method, listing time, and whether it is a proxy order. In case of returns, insufficient payment, or refund scenarios, we may also collect return date, return type, refund appeal date, refund/exchange order number, refund/exchange type, refund/exchange reason, refund amount, shipment time, transaction flow number, third-party transaction number.

3.6 User Management

When you purchase, redeem, or use products or services through our platform, for user management convenience, we may collect your user information, including user avatar, mobile phone number and verification code, member code, user nickname, mailing address.

3.7 Product Evaluation

When you review products or services you transacted, we may collect and display your evaluation content on the corresponding product’s public page (including text, pictures, videos), as well as your avatar and username.

3.8 Points Accumulation and Redemption Information

To enable points accumulation and redemption for products, we may collect types of points gained/redeemed, points amount gained/paid, product name, weight, quantity, payment amount, order number.

4. How We Collect and Use Your Personal Data

We collect your personal data through the following channels:

4.1 Information You Provide Directly

We may collect information you provide during registration, application, or use of our services, including information provided to us when you contact us by phone or other methods, as well as information generated during your use of our services related to you.

4.2 Information We Collect Automatically

We will collect device information and log data related to our services automatically through tools such as Cookies.

4.3 Use of Third-Party Plugins or SDKs to Collect Your Information

To implement specific business functions, we may use third-party plugins or SDKs and may collect information necessary for particular functions by such third parties, including but not limited to:

• 1. WeChat Pay SDK
  
  • Personal Data Involved: Device information, network information, WeChat account information
  • Usage Scenario: Used each time the user selects third-party payment
  • Purpose of Use: To help users complete payment
  • Privacy Policy: https://www.tenpay.com/v3/helpcenter/low/privacy.shtml
• 2. Alipay Client SDK
  
  • Personal Data Involved: Device information, network information, Alipay account information
  • Usage Scenario: Used each time the user selects third-party payment
  • Purpose of Use: To help users complete payment
  • Privacy Policy: https://opendocs.alipay.com/open/54/01g6qm?pathHash=01459d85

4.4 Device Permission Adjustments

During the services provided to you, to implement specific product functions, we will request permissions from your device system according to the device permissions needed below (there may be slight differences depending on different operating systems or versions). Before requesting, we will seek your consent. You may choose to “Allow,” “Allow while using the app,” or “Deny” the permission request. After consenting, you can enter the device system permissions management page to close the corresponding permissions at any time, but note that closing permissions may cause related product functions to fail to operate properly. Please understand:

• Permission Name: Clipboard
  
  • Function: Conveniently fill in addresses, nicknames
  • Can Be Closed: Yes
• Permission Name: Camera
  
  • Function: Capture photos, pictures, videos
  • Can Be Closed: Yes
• Permission Name: Photo Album
  
  • Function: Upload/store/download photos and videos
  • Can Be Closed: Yes
• Permission Name: Microphone
  
  • Function: Online customer service voice
  • Can Be Closed: Yes

4.5 Situations Where We May Collect and Use Your Personal Data Without Obtaining Your Consent

1. When required to fulfill legal obligations;
2. When directly related to national security and defense security;
3. When directly related to public security, public health, or significant public interests;
4. When necessary to establish or perform a contract for you as a party;
5. When directly related to criminal investigation, prosecution, trial, or execution;
6. When necessary to protect your or another individual’s life, health, or important legal interests but obtaining consent is difficult;
7. When collecting personal data from public information lawfully disclosed;
8. When necessary for the secure and stable operation of products or services provided, or to address discovered defects or issues;
9. Other circumstances prescribed by laws or national standards.

5. How We Share, Transfer, or Disclose Your Personal Data

5.1 Sharing

We will not share your personal data with any company, organization, or individual outside Kerry Logistics Network Limited (Shenzhen) except in the following situations:

5.1.1 After obtaining your clear consent or authorization, we will share your personal data with other parties;

5.1.2 To protect your account and transaction security in connection with related products or services provided by KEC International Transhipment, we may share your personal data with our affiliates. We will share only the necessary personal data with our affiliates according to this Policy’s terms. If our affiliates need to change the purpose of processing your personal data, they will seek your authorization and consent again;

5.1.3 We may share your order information with cooperative partners to ensure smooth completion of services you purchase. We will, however, only share your personal data for lawful, proper, necessary, and clear purposes and share only the data necessary to provide the service. Our partners have no right to use your data for any other purposes.

1. In cross-border shipping logistics scenarios, we may send the recipient’s name, address, and contact information to third-party freight forwarders to complete various requirements of the cross-border transport stages and ensure accurate and secure delivery;
2. In remote area logistics scenarios, we may send recipient name, address, and contact details to third-party freight agents to ensure fast and efficient delivery;
3. Other third parties: When necessary, we will share your order and transaction-related necessary data with third-party merchants to realize your needs for products or services and assist in after-sales service.

5.1.4 We will enter into strict confidentiality agreements with companies, organizations, or individuals with whom we share personal data, requiring those parties to manage personal data per our explanations, this Policy, and other security measures.

5.2 Transfer

We will not transfer your personal data to any company, organization, or individual except under the following circumstances:

5.2.1 Transfer with your explicit consent after obtaining your clear authorization;

5.2.2 In case of mergers, acquisitions, or bankruptcy settlements involving transfer of personal data, we will require the new company or organization to continue to be bound by this privacy policy; otherwise, we will seek a new authorization consent from you.

5.3 Disclosure

We will only disclose your personal data under the following conditions: (1) when you have given individual consent; (2) when required by laws, legal procedures, litigation, or government competent authority’s compulsory requests.

6. How We Protect and Store Your Personal Data

6.1 Technical and Procedural Measures to Protect Your Personal Data

We attach great importance to personal data security and adopt all feasible measures to protect your personal data.

6.1.1 Data Security Technology Measures

We will adopt internationally recognized security protection measures, including establishing reasonable system specifications, security technologies to prevent unauthorized access or use, modification, and alteration, to avoid data corruption or loss. KEC International Transhipment adopts strict data access control and multi-factor identity authentication technologies to protect personal data and prevent illegal use.

6.1.2 Additional Security Measures Taken by KEC International Transhipment in Data Acquisition

We will manage personal data storage and usage through data classification and level control systems, data security management regulations, and security development specifications, including confidentiality agreements, supervision, and audit mechanisms for data access personnel to comprehensively secure the data.

6.1.3 Data Access Control and Monitoring Mechanism

We only allow necessary KEC International Transhipment personnel and affiliated employees who need to know your personal data to access it under strict access control and monitoring mechanisms, ensuring data access only when needed for business purposes. We also request full staff confidentiality obligations regarding your personal data. Failure to comply may result in legal liability or blocked cooperation with KEC International Transhipment.

6.1.4 We will adopt all reasonable and feasible measures to ensure no unnecessary personal data is collected.

6.1.5 Internet is not absolutely secure, and communication methods like email, instant messaging, or social media cannot guarantee full encryption. We recommend that when using such tools, you apply complex passwords and be attentive to protecting your personal data security. During online product or service transactions with KEC International Transhipment or third parties, you cannot avoid disclosing your personal data such as contact information or postal address to counterparties. Please prudently protect your personal data and only provide it to others as necessary.

6.1.6 Security Incident Handling

To address risks such as personal data breach, damage, and loss, KEC International Transhipment has established multiple regulations clarifying classification levels and corresponding handling flows of security incidents and vulnerabilities. We have also formed a professional emergency response team that acts per incident response rules to initiate security contingencies, stop losses, analyze, locate, formulate remediation measures, and coordinate relevant departments for traceability and enforcement.

Once a personal data security incident occurs, we will comply with legal requirements and promptly notify you of the basic situation, possible impact, measures taken or to be taken, recommendations to prevent or mitigate risks, and remedial actions. We will notify you by email, SMS, phone calls, push notifications, or other appropriate methods. As it is difficult to notify every personal data subject one by one, we will choose reasonable and effective ways to publish announcements.

6.2 Storage of Your Personal Data

6.2.1 Your personal data will be stored within the territory of the People’s Republic of China.

6.2.2 During the period you use our products or services, your personal data will be retained for the applicable period described in this Policy in compliance with mandatory legal retention requirements. After exceeding the retention period, we will delete or anonymize your personal data as required by law.

6.2.3 Please be aware, after successful registration of a KEC International Transhipment app account, we will complete the account registration approval for you within 48 hours of your application. After approval, we will delete or anonymize personal data no longer needed. Due to the limitations of applicable laws and security technology, we may be unable to immediately delete corresponding information from backup systems, but we will securely store your personal data and limit any further processing until backups can be deleted or anonymized. If we terminate service or operations, we will notify you at least 30 days in advance and delete or anonymize your personal data after termination.

6.2.4 If we terminate service or operations, we will notify you at least 30 days in advance and delete or anonymize your personal data after termination.

7. How You Manage Your Personal Data

KEC International Transhipment attaches great importance to your attention to your personal data and strives to protect your rights to access, correct, delete, and withdraw consent to your personal data so that you have sufficient ability to protect your privacy and security. Your rights include:

7.1 Deletion of Your Personal Data

You may directly clear or delete information including orders and delivery address information on our product or service pages. You may request deletion of personal data in the following circumstances:

1. If our handling of your personal data violates laws or regulations;
2. If we have not obtained your consent to collect and use your personal data;
3. If the purpose of processing is realized, impossible to realize, or no longer needed for the purposes for which it was collected;
4. If you no longer use our products or services or have canceled your KEC International Transhipment account;
5. If we terminate service and operations.

If we decide to respond to your deletion request, we will notify you and request actual deletion including the timing, unless otherwise provided by law or regulation or authorized by other legally obtained independent rights. Meanwhile, we cannot guarantee immediate deletion from backup systems, but we will secure your personal data in backups and limit further processing until backup contents can be deleted or anonymized. We will update or delete such information during backup updates.

7.2 Scope of Changes or Withdrawal of Your Consent

You can change the scope of our collection or withdraw consent via clearing information, disabling device functions, or privacy settings in the KEC International Transhipment app or withdraw consent entirely through account cancellation. Please understand that each business function requires some basic personal data to operate properly. After withdrawing consent or authorization, we will not be able to continue providing related services or process your personal data.

7.3 Account Registration

You can register an account through the “Artificial Customer Service” within the KEC International Transhipment app. After account registration, we will stop services to you and, upon your request and except as provided otherwise by law, delete your personal data.

Regarding your registration method and fulfillment of requirements: when you place an order, we will provide registration features and require you to provide phone number, verification code, or account and password. After registration, you will no longer be able to query your basic information, all orders, shipment, and address information.

7.4 Your Requests

7.4.1 If you cannot access, correct, or delete your personal data, or need to access, correct, or remove other personal data or obtain copies during use of products or services, or if you believe that KEC International Transhipment violates any laws or contracts about collecting or using personal data concerning you, you can contact us through means described in this Policy.

7.4.2 To protect security, we may request a written request or identity proof document and will respond to your request within 15 days of receipt and verification.

Per legal requirements, in the following situations, we will not be able to respond to your requests:

1. Requests related to legal obligations of personal data controllers;
2. Requests related to national security and defense;
3. Requests related to public security, health, or significant public interests;
4. Requests necessary for investigating crimes, prosecuting, trying, and executing judgments;
5. Requests where you are subjectively malicious or malicious misuse of rights;
6. Requests affecting personal life, property, and other significant legitimate rights of the data subjects or others without their consent;
7. Requests that would cause severe damage to legal rights of you or other individuals or organizations;
8. Requests involving business secrets.

8. Notification and Updates

8.1 To provide you with better services and respond to the development of KEC International Transhipment, this Policy will be updated accordingly. However, without your explicit consent, we will not limit your rights under this Policy. We will publish updates via the KEC International Transhipment website, app, or appropriate channels before implementation, using website announcements or other appropriate methods to notify you of relevant updates. We recommend you check KEC International Transhipment regularly to understand the latest Privacy Policy.

8.2 For major changes, we will notify you via emails, SMS, or special notices on the browsing page explaining specific changes to this Privacy Policy. Major changes include but are not limited to:

1. Major changes to the service model, purpose of processing, categories of personal data processed, or usage methods;
2. Significant changes in control rights structure, organizational structure, such as business reorganization, acquisition, bankruptcy;
3. Major changes to subjects of personal data sharing, transfer, or disclosure;
4. Significant changes in your rights or ways to exercise rights regarding personal data processing;
5. Responsibilities, contact methods, and complaint channels related to personal data security;
6. Personal data security impact assessment disclosures during high-risk events.

8.3 To enable you to receive notifications timely, please update your contact information with us promptly.

8.4 Continued use of our services after this Policy update takes effect means you have fully read, understood, and accepted the updated provisions and agree to be bound by them.

9. How to Contact Us

If you have any questions, opinions, or suggestions regarding this Policy, including exercising your legal rights, please contact the KEC International Transhipment team as follows:

• Legal entity name: Kerry Logistics Network Limited (Shenzhen)
• Contact address: 403, Block A, Lianhe Finance Building, No. 1 Shihua Road, Futian District, Shenzhen, Guangdong Province
• Phone number: +86 155 2119 0865
• Email: [email protected]

We will handle and respond promptly to your complaints, opinions, or suggestions. Generally, we will reply to your feedback or results within 15 days.