The Company Private Limited Policy
This Policy will help you understand the following:
- How we collect and use your personal data
- How we share, transfer and publicly disclose your personal data
- How we protect your personal data
- Your rights
- How we process the personal data of children
- How your personal data moves across borders
- How this Policy is updated
- How to contact us
Please read carefully and understand this Policy before you use our products (or services).
1. How we collect and use your personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We will collect and use your personal data for the following purposes herein only:
1.1 Required information with regard to use of Melanoid Exchange services
Our services contain certain core functions, including realizing your online shopping, improving your experience of our services, and ensuring secure transactions. In order to realize such functions, we may collect and use the following information relating to you:
1.1.1 Melanoid Exchange account information
You will need to use a Melanoid Exchange account or a third-party social network account supported by Melanoid Exchange platform to enable access to and use of Melanoid Exchange platform. When you register with or log in to Melanoid Exchange platform, you need to provide the following account information to complete registration or login: an email address or the account and password registered with a third-party social network supported by Melanoid Exchange platform.
1.1.2 Communication information
To ensure your communication with sellers in the course of transaction and your inquiry and evidence-taking of such communication history, the Melanoid Exchange platform system will automatically collect and store your in-box information at the Melanoid Exchange platform. Unless we have to use or disclose such information as explicitly required by you or according to relevant applicable laws, we will not use or disclose such information in any way.
Moreover, to better help you handle after-sale rights protection and services with regard to the goods traded, you may need to provide your personal phone number to us for timely feedback of handling results and relevant information.
1.1.3 Financial information
For use of payment services, you need to provide the following financial information to complete payments, ensure transaction security, and comply with relevant applicable laws: billing address and bank account.
1.1.4 Transaction information
To ensure the delivery of goods and services, you need to provide the following information for timely receipt of goods/services and inquiry and check of transaction status: name, personal phone number, delivery address, transaction record, and order information.
1.1.5 IP address, device information etc.
For your convenience in quickly searching out the products you are interested, we may collect common data of the device you use (hardware serial number, MAC address, unique device ID etc.), language settings, IP address and in-site browsing history of your every visit on the DHgate platform.
Further, such information may also be collected and used for data analysis and study, out of justified needs for offering personalized services and improving the quality of service, for improving system security of our services, for more accurate prevention of phishing site frauds, and for ensuring the security of your DHgate account.
1.1.6 The above information you provide is authorized for our use on a continued basis as long as you use our services. Upon your request to close an account or for justified deletion, we will cease to use and delete such information according to relevant laws.
1.2 Information you provide to us at your option
To better your experience of our services, you may opt to provide the following personal information in order to acquire the following additional services. If you opt not to provide such personal data, your use of core functions of Melanoid Exchange services will not be affected, but you may be unable to use such additional services or may be required to fill out certain information every time you use certain services:
1.2.1 Personalized recommendation and sending of promotional and marketing information
In the course of using our services, you may at any time provide or choose to delete the following additional information that helps us offer more relevant services and experiences: name, gender, country/jurisdiction, date of birth, DOBs of spouse/parents, important anniversaries, income bracket, tags, third-party social network accounts, etc. Such information will be used for analysis of your behaviors and preferences to tailor personalized services for you and send you special offers, marketing information, advertisements, or other information you may be interested in.
1.2.2 Other information
You may at your option comment on the products/services you purchase. Such comments will be used to shape testimonials of corresponding products for reference by other Melanoid Exchange users and optimize user experience of relevant services.
If you use an Android device, you may at your option provide location data to us for real-time access to information of merchants in your surrounding area and acquiring site language services matched with your location. You may also at your option provide us you SIM card data (including contacts list) according to your needs, so that you may add and/or communicate with other Melanoid Exchange users in a timely manner. You may at any time close relevant functions and immediately cease to provide location data or SIM card data in your Android system or our application. After you’ve closed such functions, we will cease to collect and use your personal data as mentioned above and cease to offer you relevant services.
1.3 We will seek your prior consent if we intend to use such information for other purposes not covered herein or use information for purposes other than the particular purposes for which it is collected.
2. How we use Cookie and similar technologies
In order to ensure the smooth operation of the website and meet your personalized demands, we will store a small file named Cookie in your computer or mobile devices. Generally, Cookie includes identifiers, site name and some numbers and characters. By virtue of Cookie, the website can store your preferences or goods in the cart and other data, so as to provide you with preference setting for shopping, help you optimize the advertisement selection and interaction, help you judge your logging status and account security etc.
We will not use Cookie for any purpose other than those in this Policy. You can manage or delete Cookie according to your preference. For details relevant, see AboutCookies.org. You can clear all Cookies stored in the computer as most part of web browsers have the function to prevent Cookie. If you do so, you have to change the user setting in person every time you visit our website. For details relevant to how to change browser setting, visit the following link. If your server is not among the list, contact us, we will provide technical guidance to you:
2.2 Do Not Track
Several web browsers have the function Do Not Track which can issue Do Not Track request to websites. At present, major internet organizations for standardization have not set policies relevant to how websites cope with such request. However, if your browser starts to use Do Not Track, all our websites will respect your choice.
3. Third-party data processor
We will according to our own business demands, entrust your personal data to a third-party data processor in a form meeting GDPR requirements, so as to provide better customer service, guarantee transaction security and improve user experience. For example, data processor can help us verify your identity and conduct background investigation, police investigation, fraud prevention and risk assessment, so as to guarantee your account security and transaction security, and help us provide logistics service to your, so that you can receive the corresponding goods/service among others in a timely manner. For the list of data processors and their category, and the scope, purpose and method of shared information among others. We entrust your personal data to data processor only for legal, proper, necessary, specific and clear purpose, and process personal data necessary to the rendering of service only. We will try our best to supervise data processor to fully perform the entrustment agreement for processing legally, so as to ensure that your rights can be guaranteed to the most extent.
4. Public disclosure
4.1 We will publicly disclose your personal data only under the following situations:
4.1.1 Obtaining your explicit consent;
4.1.2 Disclosure based on laws: we may publicly disclose your personal data if mandatorily required by laws, legal procedures, lawsuits or competent authorities of government.
5. How we protect your personal data
5.1 We have used safety protection measures meeting industrial standards to protect the personal data provided by you, and prevent data from unauthorized access, public disclosure, utilization, modification, damage or loss. We will adopt every reasonable and feasible measure to protect your personal data. For example, your browser is under SSL encipherment protection when exchanging data (such as credit card information) with “service”; meanwhile, we will provide https safe browsing methods to our website; we will use encryption technique to ensure the confidentiality of data and store personal data and non-personal data separately; we will use reliable protection mechanism to prevent data from hostile attack; we will deploy access control mechanism to ensure that only authorized personnel have access to personal data; and we will hold training courses for security and privacy protection, so as to strengthen our employees’ understanding about the importance of protecting personal data.
5.2 We will adopt every reasonable and feasible measure to ensure that no irrelevant personal data is collected. We will reserve your personal data only within the period necessary to reaching the goals stated in this Policy, except for otherwise extension of reserving period or allowed by laws.
5.3 We will regularly update and make public the relevant contents of security risk, impact assessment of personal data security and other reports.
5.4 As internet is not an absolutely safe environment in which emails, instant messaging and other methods of exchange Melanoid Exchange users. During this process of communication, the personal data that you provide or describe voluntarily may be disclosed to the others. we strongly advise you not to send personal data with this method. Please use complex password to help us protect your account to be safe.
5.5 We will try our best to ensure or guarantee the security of any information you send to us. We will assume the corresponding legal responsibilities if your legal rights and interests are compromised due to unauthorized access to, public disclosure, manipulation or damage of information as a result of our physical, technical or management safeguards damaged.
5.6 After the personal data leakage, we will, according to the laws and regulations, inform you our contact information, basic situation of the security event and possible impacts, actions we adopted or to be adopted, suggestions relevant to self-leading prevention and risk reduction, remedies to you among others in a timely manner. We will inform you the situation relevant to the event via email, letter, call, notice push and other ways in a timely manner, or in the case of being difficult in informing the subjects of personal data one by one, we will release announcement in a reasonable and effective manner.
5.7 In addition, we will initiatively report the disposal of the security event of personal data according to the requirements of supervision department.
6. Your rights
In accordance with applicable laws, regulations, standards and their established practices, we guarantee that you can exercise the following rights over your personal data:
6.1 Access right
You have the right to access your personal data described in Article 1 and Article 2 of this Policy through your personal account settings, except the exceptions provided by the laws and regulations. The information that you can access includes, but is not limited to, types of personal data that we collect and process, the purpose of processing such personal data (and the consequences for not providing such personal data), basis of legitimacy, facts of leaving the country, storage period, the right and channel to complain, and we will inform you of the specific data profiling logic if we use your personal data for data profiling.
If you are unable to access your personal data through the above-mentioned approaches, feel free to send us an email to [XXXX]. We will respond to your access request in a timely manner.
6.2 Correcting inaccurate or incomplete personal data
You can correct or supplement some of your personal data through your personal account settings by yourself. You have the obligation to update your personal data in a timely manner.
The correction of certain special information probably cannot be performed by yourself. You may contact us through various contact details released in this Policy or on the Melanoid Exchange platform. We will respond to your access request . To ensure security of your account, we may ask you to verify your identity.
6.3 Deleting your personal data
6.3.1 You can request us to delete your personal data in the following cases:
a) Relevant data are no longer necessary for the purpose of collection or processing, and we lack the legal basis to continue processing your personal data;
b) You no longer agree to or refuse to allow us to process your personal data, and we lack the legal basis to continue processing your personal data;
c) Our processing of personal data violates laws and regulations;
d) Your data involve with data of any child;
e) You no longer use our products or services, or you have closed your account;
f) We no longer provide products or services for you.
6.3.2 If we decide to respond to your request for deletion, we will inform the third party that we have commissioned to process your personal data as far as practicable and require such third parties to delete your personal data in a timely manner, unless otherwise provided by laws and regulations, or such third parties has obtained your independent authorization.
6.3.3 Notwithstanding the foregoing, to resolve disputes, enforce user agreements, and comply with technical requirements related to safe operation, we may still retain certain data for a reasonable time to the extent permitted by law.
6.4 Withdrawing consents and processing constraints
6.4.1 For personal data that you have allowed us to collect and process, you can withdraw your consent at any time through your account settings or send an email to [XXXXX], indicating which consent you want to revoke. When you have withdrawn your consent, we will no longer process the relevant personal data. However, your decision to withdraw your consent will not affect the legality of personal data processing previously done based on your authorization.
6.4.2 In addition, in some jurisdictions, applicable law may entitle you to limit our way of using your personal data, including:
a) You doubt the accuracy of your personal data;
b) Personal data processing is illegal, and you only request to restrict the use of your personal data and object to the deletion of your personal data;
c) We no longer need your personal data for processing, but you need such information for the purpose of filing a lawsuit or responding to a lawsuit;
d) You object to our processing of your personal data based on public interests or legitimate interests and oppose waiting for verification of whether the aforementioned public interests or the legitimate interests of DHgate will outweigh your own interests.
6.5 Right of refusal
6.5.1 In some jurisdictions, applicable law may empower you to require Melanoid Exchange not to process your personal data for a specific purpose (including identifying behavioral analysis, direct marketing purposes, etc.), though such processing are based on legitimate interests. If you object to such processing, we will no longer process your personal data for these purposes unless we can prove that such processing has a convincing and reasonable cause, or that such processing is necessary for the establishment, exercise or safeguard of legal rights.
6.5.2 If your personal data is processed for direct marketing purposes, you can refuse to let Melanoid Exchange process your data for direct marketing purposes at any time through the boot settings on the relevant advertising screen or by sending an email to [xxxx]
6.6 Canceling an account
6.6.1 You can cancel the Melanoid Exchange account that you have registered at any time.
6.6.2 After canceling your account, we will cease to provide services for you and delete your personal data within the time limit stipulated by applicable laws in accordance with your request, unless otherwise provided by laws and regulations or when you have reached an agreement with us.
6.7 Obtaining a copy of personal data
6.7.1 You have the right to send us a written request to obtain a copy of your personal data through the contact information released in this Policy.
6.7.2 We can also directly transmit your personal data copy to a third party designated by you according to your requirements and existing communication technology under the condition that it is technically feasible, such as data interfaces are matched. If such third party refuses to receive the copy of your personal data, which results in transmission failure, you should coordinate with such third party by your own and DHgate will not be liable for the transmission failure.
6.8 Constraining automatic decision-making of the information system (data image)
6.8.1 Based on personal data legally collected under authorization, automatic decisions (for example, commercial information push) made by labeling or image processing realized through inartificial automatic decision-making technologies such as the information system and algorithm will be subject to your legal constraints. In some business functions, we may only make decisions based on inartificial automatic decision-making mechanism, such as the information system and algorithm. Where these decisions significantly influence your legal rights and interests, you have the right to request us to explain or reject our continued provision of such labeling or image processing service, and we will provide appropriate remedies in accordance with the law.
6.9 Responding to your above request
6.9.1 In order to ensure security, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.
6.9.2 We will make a reply. If you are not satisfied, you can also lodge a complaint in the way provided in the Article 0 of this Agreement.
6.9.3 For your reasonable request, we do not charge any fee in principle, but we will charge a certain cost for repeated requests beyond the reasonable limit, as the case may be. We may reject those repeated requests without a cause, requests requiring too much technical means (for example, development of a new system or fundamental change of the existing practice is necessary) or posing risks to legal rights and interests of others, or extremely unrealistic requests (for example, involving information stored on the backup tape).
6.10 We will not be able to respond to your request as required by laws and regulations, in the following situations:
6.10.1 Directly related to national security and national defense security;
6.10.2 Directly related to public safety, public health and major public interests;
6.10.3 Directly related to criminal investigation, prosecution, trial, judgment execution, etc.;
6.10.4 There is sufficient evidence proving your subjective malice or abuse of rights;
6.10.5 Responding to your request will result in serious damage to your legitimate rights and interests or that of bother individuals or organizations.
6.10.6 Involving business secrets;
6.10.7 Other circumstances specified by applicable laws.
7. How we process the personal data of children
7.1 Our products, websites and services are for adults only. Children shall not create their own user accounts. We will not collect or use data on children, if informed.
7.2 We regard anyone under  years old as a child, despite different definitions of children by local laws and customs.
7.3 Once we find ourselves having collected personal data on children without their parents’ prior and verifiable consent, we will try to delete the relevant data as soon as possible.
8. How this Policy is updated
8.3 Major changes referred to in this Policy include, but are not limited to:
8.3.1 Major changes in our service model. For example, the purpose of processing personal data, the type of processed personal data, the use of personal data, etc.;
8.3.2 Major changes in our ownership structure, organizational structure, among others. Such as, change of the owner caused by business adjustment, bankruptcy and mergers and acquisitions, and others;
8.3.3 Changes in main objects of personal data delegated to be processed;
8.3.4 Changes in main objects of personal data publicly disclosed;
8.3.5 Major changes in your rights to participate in the processing of personal data and how it is exercised;
8.3.6 Upon changes in our department responsible for dealing with the security of personal data, contact information, and complaints channels;
8.3.7 Upon high risks indicated in the personal data security impact assessment report.
9.4 We will also archive the old version of this Policy for your reference.
10. How to contact us
10.2 Generally, we will reply within a good time frame . If you are dissatisfied with our response, especially if you believe that our acts of processing personal data have caused damage to your legal rights and interests, you can also contact the [relevant EU data protection authority or committee] for assistance.