Qianhai Zhongxin Supply Chain Group Global Privacy Statement

**1. Introduction**

We are delighted that you have chosen us and are interested in our company, products, and services. Your trust is of paramount importance to us. We are committed to protecting your privacy and the security of information that can be used, directly or indirectly, to identify a natural person ("personal information") throughout our business process handling. Qianhai Zhongxin Supply Chain Group (SYR / MPM) has formulated this Privacy Statement to explain how we collect and use your personal information.

**Last Updated: July 3, 2025.**

When this Privacy Statement refers to "Qianhai Zhongxin Supply Chain Group (SYR / MPM)", "we", "us", or "our", it means the Qianhai Zhongxin Supply Chain Group companies that determine the purposes and means of processing your personal information under this Privacy Statement. When you use our services within Mainland China, your personal information is controlled by Shenzhen Qianhai Qianhai Zhongxin Supply Chain Management Co., Ltd. When you use our services in other countries or regions to arrange shipments from China to other parts of the world, your personal information is controlled by Rainbow Logistics (China) Ltd.

**Contact Information:**

*   **Shenzhen Qianhai Qianhai Zhongxin Supply Chain Management Co., Ltd**

*   Attn: Legal Department

*   Address: 101, Building 2, No. 7 Yongtai East Road, Baishixia Community, Fuyong Street, Bao'an District, Shenzhen, China

*   **Rainbow Logistics (China) Ltd**

*   Attn: Legal Department

*   Address: Room 4012-4018, 4/F, Tower A, Container Terminal No. 3, Kwai Chung District, New Territories, Hong Kong

If you have any questions regarding our use of your personal information during or after reading this Privacy Statement, you can of course contact us at any time via email at DPO@qhzx-express.com.

**2. Does this Privacy Statement Apply to You?**

This Privacy Statement applies to you if:

*   You are a customer of Qianhai Zhongxin Supply Chain Group,

*   You contact Qianhai Zhongxin Supply Chain Group by visiting www.qhzx-express.com or www.qhzx-express.com (including any pages and mobile applications, hereinafter referred to as the "Website"), or

*   You receive an email from Qianhai Zhongxin Supply Chain Group.

Our website, products, and services are intended for the general public and are not directed at children. In principle, we do not collect personal information from children under the age of 14. If you are under 14 and wish to use our services, please rely on your parents or guardians to assist you.

If a child under 14 may have disclosed personal information to us, parents or guardians can contact us, and we will delete the personal information if necessary.

**3. What Personal Information Do We Collect?**

In the course of conducting business activities and providing services, Qianhai Zhongxin Supply Chain Group needs to process personal information. Without your personal information, we would be unable to provide you with the requested services. Typically, the personal information provided directly or indirectly to Qianhai Zhongxin Supply Chain Group when you use our services and visit our website includes:

*   **Contact Information:** Including your name, address, email address, and phone number.

*   **Financial Information:** Including your bank account number, payment status, and invoices.

*   **Identification Information:** May include your ID card number, passport number, or driver's license number to ensure we can verify your identity.

*   **Account Information:** Including login details such as your username, email address, phone number, and other information provided through your account.

*   **Sender Information:** Including the sender's name, address, email address, and phone number.

*   **Recipient Information:** Including the recipient's name, address, email address, and phone number.

*   **User Data & Preferences:** Where applicable, including shipment volume, complaints, transaction history and related business activities, communication records, survey information, and your preferences.

*   **Automatically Generated Information:** Including IP address, unique device or user ID, system and browser type, date and time stamps, referring website address, content and pages you access on our website or mobile application, date, time, and location of actions.

In addition to the categories of personal information listed above, depending on your interaction with Qianhai Zhongxin Supply Chain Group, we may collect other types of information, which may or may not contain personal information. Such shipment and service-related information may include shipment tracking number, shipment routing information, location data, shipment status, delivery location, packaging type, number of pieces, weight, price, package images, proof of delivery, and customs information.

**4. How Do We Collect Personal Information?**

Qianhai Zhongxin Supply Chain Group collects personal information when it is provided by the sender or our contracting customer, or when provided by a website visitor. If you are the sender or our contracting customer, we receive your personal information directly from you. Examples of situations where Qianhai Zhongxin Supply Chain Group collects personal information directly include:

*   The name, address, and phone number of the shipper listed as the sender.

*   The name, address, identification information, payment card information, and account number of the person opening a Qianhai Zhongxin Supply Chain Group shipping account (i.e., our contracting customer).

If the sender or our contracting customer provides personal information of another person, we receive that personal information indirectly. Examples of situations where Qianhai Zhongxin Supply Chain Group collects personal information indirectly include:

*   The name, address, and phone number of the shipment recipient.

*   The name, address, phone number, email address, and identification information of directors, employees, workers, or representatives of the sender or account holder.

*   The name and address of the actual sender when a sender places an order on an online marketplace platform such as Amazon, eBay, SHEIN, Wish, etc., and Qianhai Zhongxin Supply Chain Group delivers the package to the address you provided.

When Qianhai Zhongxin Supply Chain Group receives personal information indirectly, we rely on the provider of the information to ensure its accuracy and to ensure that the provider is authorized to provide this information to Qianhai Zhongxin Supply Chain Group.

**5. For What Purposes and on What Legal Basis Do We Process Your Personal Information?**

Personal information shall be collected, used, stored, or otherwise processed where necessary within the framework of responsible, efficient, and effective business management of Qianhai Zhongxin Supply Chain Group. Qianhai Zhongxin Supply Chain Group processes personal information based on applicable legal grounds. The legal basis is often intrinsically linked to the business purpose. This means, for example, that fulfilling a contract can be both the legal basis for Qianhai Zhongxin Supply Chain Group to process personal information and the business purpose. Therefore, we will first clarify the legal basis on which Qianhai Zhongxin Supply Chain Group processes your personal information, and then explain the business purposes we aim to achieve by using your personal information:

**Legal Basis**

Typically, Qianhai Zhongxin Supply Chain Group processes your personal information based on one of the following legal grounds:

*   Processing is necessary for the performance of a contract between you and Qianhai Zhongxin Supply Chain Group;

*   Processing is necessary for compliance with our legal obligations;

*   Processing is necessary to protect the vital interests of you or another person;

*   Processing is necessary for the legitimate interests pursued by Qianhai Zhongxin Supply Chain Group, except where such interests are overridden by your interests or fundamental rights and freedoms; or

*   Where appropriate and necessary, we will obtain your consent.

**Business Purposes**

Qianhai Zhongxin Supply Chain Group collects, uses, or processes personal information only when the processing falls within one (or more) of the following legitimate business purposes:

*   **Fulfillment of Contract:** Including freight services, tracking Qianhai Zhongxin Supply Chain Group services, communicating with our contracting customers, senders, and other relevant parties regarding services, responding to requests for further information, dispute resolution, and preparing agreements.

*   **Product Development, Research, and Improvement of Qianhai Zhongxin Supply Chain Group Products and/or Services:** Qianhai Zhongxin Supply Chain Group processes personal information as necessary for developing and improving Qianhai Zhongxin Supply Chain Group products and/or services, research and development (e.g., analyzing shipment and service-related information to improve our services).

*   **Relationship Management and Marketing for Business Activities:** Generally, Qianhai Zhongxin Supply Chain Group processes personal information as necessary for developing and improving Qianhai Zhongxin Supply Chain Group products and/or services, account management, customer service, and executing targeted marketing campaigns to build customer relationships and/or maintain and expand customer or business partner relationships, and for performing statistical analysis on personal information (e.g., sending you advertisements, newsletters, and content that better match your interests).

*   **Business Process Execution, Internal Management, and Management Reporting:** Including processing for activities such as managing company assets, conducting internal audits and investigations, finance and accounting, implementing business controls, providing centralized processing facilities for efficiency, managing mergers and acquisitions and divestitures, and processing personal information for management reporting and analysis.

*   **Security and Protection:** Processing data for security, protecting Qianhai Zhongxin Supply Chain Group, its customers or business partners, and for processes such as verifying the status and access rights of customers or business partners.

*   **Protection of Vital Interests of Individuals:** Including processing data where necessary to protect the vital interests of you or another individual (e.g., for urgent safety reasons).

*   **Compliance with Legal Obligations:** Refers to processing personal information as necessary to comply with applicable laws and regulations applicable to Qianhai Zhongxin Supply Chain Group (e.g., checking customer and business partner names against blacklists to avoid conflicts of interest, complying with trade regulations, anti-money laundering and anti-corruption regulations, and other policies, procedures, and regulations).

**6. How Do We Use Cookies?**

Qianhai Zhongxin Supply Chain Group may use cookies and similar technologies on its websites. Through these cookies, Qianhai Zhongxin Supply Chain Group automatically obtains personal information as listed above when you visit our website. To learn more about cookies and similar technologies, please refer to our [Cookie Notice].

**7. How Do We Share Your Personal Information?**

Qianhai Zhongxin Supply Chain Group shares your personal information with third parties under the following circumstances:

*   Your personal information is shared internally within Qianhai Zhongxin Supply Chain Group's affiliated companies, operating groups, subsidiaries, and departments if necessary to achieve the purposes stated above.

*   Our employees are only authorized to access personal information to the extent necessary to serve the applicable purposes and perform their job duties.

*   Your personal information is shared with data processors (e.g., suppliers or service providers who process personal information on our behalf). In such cases, these third parties only use your personal information for the purposes stated above and only act on our instructions. When these third parties are granted access to your personal information, we take necessary contractual, technical, and organizational measures to ensure that your personal information is only processed to the extent that processing security is guaranteed. In relevant cases, the following third parties have access to your personal information to provide us with their products or services:

*   **Customs Brokers:** To perform customs clearance and declaration procedures for your goods.

*   **Last-Mile Delivery Service Providers:** To deliver goods to your desired destination.

*   **IT Service Providers:** To develop and maintain our website and certain software.

*   **Cloud Service Providers:** We may store data on servers operated by cloud service providers. Regardless of where you use our online services or provide us with data, the data may be transmitted to and stored on servers located outside the country where the data was collected.

*   **Law Enforcement, Regulatory Agencies, and Other Parties (For Legal Reasons):** We may also disclose your personal information to third parties as required by law, or if we reasonably believe such action is necessary: (a) to comply with a subpoena or other legal process, legal proceedings, or requests from government agencies; (b) when we believe in good faith that disclosure is necessary to comply with the law and reasonable requests from law enforcement; (c) to protect and enforce our legal claims, rights, and property; (d) to protect the rights, property, or personal safety of you, others, or the public; (e) to investigate fraud.

**8. How Is Your Personal Information Secured?**

We have implemented adequate security measures to ensure the confidentiality and security of your personal information. We have implemented appropriate technical, physical, and organizational measures to protect personal information against accidental or unlawful destruction, accidental loss, damage, alteration, unauthorized disclosure or access, and all other forms of unlawful processing (including but not limited to unnecessary collection) or further processing, including protecting your personal information from unauthorized access, maintaining the confidentiality, integrity, and availability of your personal information, and training personnel on information security requirements.

However, no security measure can guarantee absolute security. You also play an important role in protecting personal information. You should not share your username and password with anyone and should not reuse passwords across multiple websites. If you have reason to believe that your personal information has been compromised, please contact us.

**9. How Long Do We Retain Your Personal Information?**

Unless otherwise permitted or required by applicable laws or regulations, we will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, to satisfy any legal, accounting, or reporting obligations, or to resolve disputes. To determine the appropriate retention period for personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

In some cases, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymized and de-identified data for any legitimate business purpose without further notice to you or consent from you.

**10. Where Do We Store or Transfer Your Personal Information?**

Generally, your personal information collected lawfully by Qianhai Zhongxin Supply Chain Group within the People's Republic of China will be stored within the territory of the People's Republic of China.

Due to the nature of our business and the services we provide to you, Qianhai Zhongxin Supply Chain Group may need to transfer your personal information to affiliated companies or subsidiaries located outside the People's Republic of China to perform the contract with you or to achieve the purposes described in this Statement. In any case where we transfer personal information, we will ensure that such transfers are subject to appropriate safeguards affording a level of protection no less than that required by applicable Chinese laws. We will complete the relevant procedures as required by applicable personal information protection laws and regulations before conducting any cross-border transfer or remote access.

**11. What Rights Can You Exercise Regarding Your Personal Information?**

Depending on the laws applicable to the use of your personal information, you may have rights that you can exercise regarding your personal information. Please note that in some cases, we may not be required to fully comply with your request, as these rights may be conditional or because we must balance your rights against our rights and obligations to process your personal information and to protect the rights and freedoms of others. Some rights you may have regarding personal data (applicable in the European Economic Area, California, or other US or international geographies) are explained below:

*   **Right of Access:** You may have the right to obtain a copy of the personal information we hold about you and to understand the details of how we use that information. Your personal information will typically be provided to you digitally. Before providing the requested information, we may need to verify your identity.

*   **Right to Rectification:** We take reasonable steps to ensure the information we hold about you is accurate and complete. However, if you believe this is not the case, you may have the right to request the modification of any incomplete or inaccurate personal information about you that we process.

*   **Right to Erasure (Deletion):** You may have the right to request that we delete your personal information, for example, when the personal information we collected no longer serves the original purpose, the personal information is outdated, or you withdraw your consent (if we processed your personal information based on consent). However, this needs to be weighed against other factors. For instance, we may be unable to comply with your request due to certain legal or regulatory obligations.

*   **Right to Restriction of Processing:** You may have the right to request that we (temporarily) stop using your personal information, for example, when you believe the personal information we hold about you may be inaccurate, or when you believe we no longer need to use your personal information.

*   **Right to Data Portability:** You may have the right to request that we transfer the personal information you provided to us to a third party of your choice. This right is only exercisable when you provided us with the personal information and we are processing it by automated means based on your consent or for the performance of a contract with you.

*   **Right to Object:** You may have the right to object to processing based on our legitimate interests. For the processing of personal information for marketing purposes, you have the right to object at any time. When you ask us to stop using your personal information for marketing purposes, Qianhai Zhongxin Supply Chain Group will cease using your personal information for such purposes immediately. For other purposes based on our legitimate interests, when you object on grounds relating to your particular situation, we will cease processing the personal information for that reason unless we have compelling legitimate grounds for the processing. Please note, however, that we may be unable to provide certain services or benefits if we cannot process the necessary personal information for that purpose.

*   **Rights Related to Automated Decision-Making:** You may have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. If you believe you have been subjected to automated decision-making and disagree with the outcome, you can contact us using the contact details provided below and request that we review the decision.

*   **Right to Withdraw Consent:** We may seek your consent to process personal information in specific circumstances. When we do so, you have the right to withdraw your consent at any time. Qianhai Zhongxin Supply Chain Group will cease further processing as soon as possible after you withdraw consent. However, this will not affect the lawfulness of processing based on consent before its withdrawal.

**12. California Consumers**

If you are a California resident, you may make specific requests regarding your personal information. We will fulfill these requests as required by California law.

You may request a copy of the personal information we hold about you, including a list of categories of your personal information we have sold and a list of categories of your personal information we have disclosed for business purposes to other companies.

You may request that we delete your personal information.

You may request that we stop selling your personal information.

More information about these requests is below:

*   **Request Access to Personal Information:** If you make this request (which we may also refer to as an "Access to Information Request"), we will return to you (to the extent required by law):

*   The categories of personal information we collected about you.

*   The categories of sources from which we collected your personal information.

*   The business or commercial purpose for collecting or selling your personal information.

*   The categories of third parties with whom we share personal information.

*   The specific pieces of personal information we collected about you.

*   A list of categories of personal information we have sold about you, and the categories of any other companies we sold it to. Any category of personal information we collect may be sold to other companies, including companies within our corporate group. If we have not sold your personal information, we will inform you of that fact.

*   A list of categories of personal information we have disclosed for business purposes, and the categories of any other companies we shared it with. You may request this information up to twice within a continuous 12-month period. When you make this request, the information provided may be limited to personal information we collected about you in the past 12 months.

*   **Request Deletion of Personal Information:** You have the right to request that we delete your personal information. Once we receive the request, we will (to the extent required by law) delete the personal information about you that we held as of the date of your request from our records and instruct any service providers to do the same. In some cases, deletion may be achieved by de-identifying the information. Choosing to delete your personal information may impact your ability to use our website and online features, including closing your online account.

*   **Request to Stop Selling Personal Information:** In the twelve months prior to the effective date of this statement, we have not sold any consumer's personal information (as these terms are defined under the California Consumer Privacy Act).

*   **Non-Discrimination:** We will not discriminate against you for exercising your rights. This generally means we will not deny you goods or services or provide a different level or quality of goods or services. Please note that if you request deletion of your information, it may affect your experience with us, and you may be unable to participate in certain services that require your personal information to function.

*   **Shine the Light Law:** California Civil Code Section 1798.83 (also known as the "Shine the Light Law") allows our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal data (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and wish to make such a request, please submit your request in writing to us using the contact information provided at the top of this Privacy Statement.

**13. What If You Have Other Questions or Complaints?**

Questions or complaints regarding the processing of your personal information can be directed to Qianhai Zhongxin Supply Chain Group by using the contact information provided at the top of this Privacy Statement.

You also have the right to lodge a complaint with the relevant data protection authority in the jurisdiction where you work, reside, or where the alleged infringement occurred.

**14. How Will This Privacy Statement Be Updated?**

Qianhai Zhongxin Supply Chain Group may update this Privacy Statement from time to time. If the revisions would have a significant impact, Qianhai Zhongxin Supply Chain Group will endeavor to proactively notify you of such revisions. Qianhai Zhongxin Supply Chain Group will at all times publish the latest Privacy Statement on the website, indicating the latest revisions.

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