Debenhang Privacy Policy

Last Updated: November 14 / 2016
Effective Date: November 13 / 2045
 
Chongqing Debenhang Trading Co., Ltd. (hereinafter referred to as “we”) is an enterprise specializing in the R&D, production, and sales of automotive front/rear lamps and auto parts. We fully recognize the importance of your personal information and have always regarded protecting your privacy and personal information security as one of our core business principles. This Privacy Policy is designed to clearly explain how we collect, use, store, share, transfer, and protect your personal information when you use our products and services (including but not limited to official website browsing, product consultation, order transactions, after-sales services, etc.), as well as the relevant rights you are entitled to.
 
Please carefully read and fully understand this Privacy Policy before using our products or services, with special attention to the clauses marked in bold. If you have any questions about the content of this Policy, please contact us through the contact information provided at the end of this Policy. Your use of our products/services, or continued use of our products/services after we update this Privacy Policy, indicates that you have fully understood and agreed to all the contents of this Policy (including updated versions). If you do not agree to any clause of this Policy, please immediately stop using our products and services.
If we have formulated a separate privacy policy for specific products or services (such as customized parts services, exclusive dealer services, etc.), the privacy policy for such products/services shall prevail.
 

1. Definitions

  • We/Company: Refers to Chongqing Debenhang Trading Co., Ltd. Registered Address: No.988-6, Lanmei Road, Jiulongpo Dist, Chongqing, China.
  • Personal Information: Refers to various information recorded electronically or by other means that relates to an identified or identifiable natural person, excluding information that has been anonymized, such as name, mobile phone number, email address, and address.
  • Sensitive Personal Information: Refers to personal information that may lead to discrimination against individuals or serious harm to their personal or property safety if disclosed or illegally used, including ID card number, bank account information, precise geolocation information, and personal biometric information. We will prominently mark sensitive personal information in this Policy with bold.
  • User: Refers to natural persons who use our products or services, including individual consumers, dealer contacts, and partner liaison personnel.
  • Anonymization: The process of processing personal information such that it can no longer identify a specific natural person and cannot be restored.

2. Purposes and Scope of Collecting and Using Personal Information

We adhere to the principles of “legality, legitimacy, and necessity” and only collect and use your personal information to fulfill the business functions stated in this Policy, without collecting information beyond the necessary scope. The specific scenarios and information scope are as follows:

2.1 Implementation of Basic Business Functions

  1. Use of Official Website and Online PlatformsTo provide you with stable browsing experience, product inquiry, and information display services, we may collect your device information (including device model, operating system version, browser type, and unique device identifier) and browsing log information (including access time, accessed pages, stay duration, and click records). Such information is only used to optimize platform performance, analyze user needs, and ensure service stability.
  2. Product Consultation and CommunicationWhen you consult about the model, price, applicable vehicle model, inventory, and other information of auto parts (such as LED lamps, wiring harnesses, lamp holders, etc.) through official website messages, online customer service, phone calls, emails, or other means, we may collect your name, mobile phone number, and email address. This information is only used to respond to your consultation needs in a timely manner, establish effective communication, and provide relevant product materials thereafter.
  3. Order Transaction and FulfillmentWhen you purchase our auto parts products, to complete order creation, payment settlement, logistics and distribution, and order confirmation, we need to collect your name, mobile phone number, delivery address, recipient information, bank account information/payment account information (only for the payment link) and order-related information (such as purchased product model, quantity, amount, and order number). This information is necessary to fulfill the transaction purpose; if you fail to provide it, we will be unable to complete order fulfillment.
  4. Liaison with Dealers and PartnersFor B-end partners such as dealers and maintenance workshops, we may collect the name, position, mobile phone number, email address, company name, and Unified Social Credit Identifier of the liaison personnel, as well as the business address and cooperation needs of the partners. This information is used to establish cooperative relationships, conduct business negotiations, sign cooperation agreements, and carry out subsequent business liaison.

2.2 Value-Added Services and Experience Optimization

  1. Query of Nearby Service OutletsIf you query nearby parts sales outlets or installation service points through our platform, we will obtain your geolocation information through an integrated map SDK (such as Baidu Maps SDK). We have set geolocation authorization to be disabled by default and will clearly ask for your authorization through a pop-up window; if you refuse authorization, you can manually enter the address to complete the query without affecting the use of other core services.
  2. Personalized RecommendationsBased on your browsing records, consultation history, and purchase preferences, we may recommend auto parts products suitable for the vehicle model you are interested in (such as recommending special LED headlights for the SUV model you consulted). If you do not wish to receive personalized recommendations, you can disable this service through the “Settings” function on the official website or by contacting customer service.
  3. After-Sales Services and Issue HandlingWhen you submit after-sales service requests such as product quality feedback, installation consultation, and return/exchange applications, to verify your identity, confirm product purchase records, and effectively resolve issues, we may collect your name, mobile phone number, order number, product fault description, and photos of relevant certificates. If necessary, we will record the communication content (phone/online chat) between you and customer service to ensure service quality and handle disputes.

2.3 Legal and Regulatory Requirements and Security Assurance

1. To comply with legal and regulatory requirements (such as tax declaration and product quality traceability), we need to retain your transaction information, identity information, and other necessary materials for a period in line with relevant legal requirements.
2. To ensure platform security, prevent fraud risks, and protect the legitimate rights and interests of you and other users, we may collect and analyze device information, login logs, transaction behaviors, and other information to identify abnormal operations and detect and prevent illegal activities.

2.4 Circumstances Not Requiring Authorization and Consent

In accordance with relevant laws and regulations, we may collect and use your personal information without obtaining your authorization and consent in the following circumstances:
  • Information related to our performance of obligations stipulated by laws and regulations;
  • Information directly related to national security and national defense security;
  • Information directly related to public security, public health, and major public interests;
  • Information necessary for concluding or performing a contract where you are one of the parties;
  • Information directly related to criminal investigation, prosecution, trial, and execution of judgments;
  • Information necessary to protect the life, property, and other major legitimate rights and interests of you or other individuals but it is difficult to obtain your authorization and consent;
  • Information collected from legally publicly disclosed information (such as public enterprise industrial and commercial information, and industry exhibition registration information);
  • Information necessary to maintain the safe and stable operation of the products or services we provide (such as detecting and handling system failures);
  • Other circumstances stipulated by laws, regulations, or national standards.

3. Methods of Collecting Personal Information

We collect your personal information through the following legal channels:
  1. Voluntarily Provided by You: Including information you fill in when registering, leaving messages, consulting, and placing orders on the official website, information you provide through phone calls, emails, and offline negotiations, as well as after-sales service application materials and cooperation intention documents you submit.
  2. Generated or Obtained in the Course of Service Provision: Including browsing logs and transaction records automatically generated when you use our platform, as well as product acceptance photos and service scenario records taken by us to provide services.
  3. Provided by Third Parties: (1) With your explicit authorization and consent, we may obtain your information from legally established third parties, such as obtaining your order information from cooperating e-commerce platforms and obtaining your delivery confirmation information from logistics service providers;(2) We may integrate third-party SDKs (such as map SDKs and payment SDKs) to implement specific functions, and some SDKs may directly collect your relevant information (such as geolocation information and payment information). We will strictly review the compliance of third-party SDKs and require them to use the information in accordance with the agreed purposes. The privacy policies of specific third-party SDKs can be viewed through relevant links (e.g., Baidu Maps SDK Privacy Policy: http://lbsyun.baidu.com/index.php?title=open/privacy).
  4. Obtained from Public Channels: Collecting your personal information from legally publicly disclosed information, such as contact information in the National Enterprise Credit Information Publicity System and public registration information from industry exhibitions.

4. How We Share, Transfer, and Publicly Disclose Personal Information

We attach great importance to the confidentiality of personal information and will not share or transfer your personal information to any third party other than our affiliated companies without your explicit consent.

4.1 Sharing

We may share your personal information only in the following specific circumstances and will strictly adhere to the principle of “minimum necessity”:
  1. Sharing with Affiliated Companies: To realize cross-regional service liaison, unified customer management, and cooperative business collaboration, we may share necessary personal information with our affiliated companies. Our affiliated companies will be bound by this Privacy Policy; if they need to change the purpose of information use, they will obtain your authorization and consent separately.
  2. Sharing with Authorized Partners: To complete order fulfillment (such as logistics and distribution), provide payment services, and carry out after-sales services, we will share necessary information with authorized partners such as logistics service providers, payment institutions, and maintenance service partners. For example, we provide your delivery address and contact information to logistics service providers to complete distribution, and provide necessary order information to payment institutions to complete payment settlement. We will sign strict confidentiality agreements with partners, clarify the scope of information use and protection obligations, and prohibit them from using the shared information for other purposes unrelated to the services.
  3. Sharing as Required by Laws and Regulations: We may share your personal information in accordance with legal and regulatory requirements, requests from administrative or judicial authorities, or to respond to dispute resolution needs such as litigation and arbitration.
  4. Sharing to Protect Legitimate Rights and Interests: Within the scope permitted by laws and regulations, to protect the life, property safety, or legitimate rights and interests of you, us, other users, and the public, such as preventing fraud and combating illegal and criminal activities, we may share necessary personal information.

4.2 Transfer

We will not transfer your personal information to any third party unless the following circumstances occur and comply with relevant legal and regulatory requirements:
  1. Obtaining your explicit written consent;
  2. In the event of corporate operational changes such as merger, division, acquisition, asset transfer, and bankruptcy liquidation, your personal information will be transferred along with the relevant business assets. We will require the transferee to continue to fulfill the information protection obligations stipulated in this Privacy Policy; if the transferee needs to change the purpose of information use, it will obtain your authorization and consent separately.

4.3 Public Disclosure

We may publicly disclose your personal information only in the following circumstances:
  1. Obtaining your explicit authorization and consent;
  2. Information that needs to be publicly disclosed in accordance with legal and regulatory requirements or mandatory requirements of administrative or judicial authorities;
  3. Publicly disclosing information that has been anonymized, which can no longer identify a specific natural person and does not fall under the category of personal information as referred to in this Policy.

5. How We Store Personal Information

5.1 Storage Location

The personal information we collect will be stored within the territory of the People’s Republic of China (for the purpose of this Policy, excluding the Hong Kong Special Administrative Region, the Macao Special Administrative Region, and Taiwan Region). If personal information needs to be stored or transmitted overseas due to business requirements, we will strictly comply with relevant legal and regulatory provisions, obtain your explicit consent, and ensure information security through methods such as signing data processing agreements and adopting encrypted transmission.

5.2 Storage Period

We will store your personal information for the “shortest period necessary to achieve the purpose”, and the specific storage periods are as follows:
  1. Personal information used for transaction fulfillment and after-sales services (such as order information and delivery information) will be retained for 5 years from the date of transaction completion, and will be anonymized after the retention period expires;
  2. Personal information used for business cooperation (such as dealer contact information) will be retained for 3 years from the date of termination of the cooperative relationship, and will be anonymized after the expiration;
  3. Log information used for platform operation and security assurance will be retained for 1 year and will be automatically deleted after the expiration;
  4. If laws and regulations stipulate special storage periods for personal information (such as tax and product quality traceability requirements), we will extend the storage period in accordance with the provisions.

5.3 Storage Security Assurance

We adopt dual guarantees of technology and management to protect your personal information from unauthorized access, use, disclosure, tampering, or damage:
  1. Technical Guarantee: Adopting technical means such as encrypted storage (such as encrypted processing of sensitive information), access control (such as setting hierarchical account permission management), security audit (such as regular log auditing), and intrusion detection to ensure the security of the information storage system;
  2. Management Guarantee: Establishing information security management systems, clarifying information processing procedures and employee responsibilities, conducting security training and confidentiality assessments for employees who have access to personal information, and signing confidentiality agreements to prevent internal information leakage risks;
  3. Emergency Response: Formulating emergency plans for personal information security incidents, conducting regular emergency drills, and in the event of an information security incident, promptly taking remedial measures and reporting to you and relevant regulatory authorities in accordance with legal and regulatory provisions.

6. Your Rights

In accordance with relevant legal and regulatory provisions, you are entitled to access, correct, supplement, delete, withdraw consent, cancel your account, and other rights regarding your personal information. We provide convenient channels for you to exercise these rights, which can be realized through the following methods:

6.1 Access and Inquiry

You can inquire about your personal information through the following methods:
  1. Individual Consumers: Log in to your account on our official website or online platform, and inquire about your basic information, order records, consultation history, etc., in the “Personal Center”;
  2. B-end Partners: Contact the business personnel you are liaising with to apply for inquiry about your cooperation-related information and enterprise-associated information.

6.2 Correction and Supplementation

If you find that the personal information we store about you is incorrect or incomplete (such as a changed mobile phone number or updated delivery address), you can apply for correction or supplementation through the following methods:
  1. Online: Modify your basic information independently through the “Personal Center” on the official website, or submit a correction application with relevant supporting materials;
  2. Offline: Submit a correction application through phone, email, or by contacting the liaison personnel. We will verify and process it within 3 working days after receiving the application.

6.3 Deletion

In the following circumstances, you can apply to us for the deletion of your personal information, and we will complete the processing within 15 working days after verification (unless otherwise stipulated by laws and regulations):
  1. We collect and use your personal information beyond the agreed scope of purposes;
  2. You withdraw your consent to the processing of personal information;
  3. We terminate the provision of relevant products or services;
  4. Other circumstances where personal information should be deleted as stipulated by laws and regulations.

6.4 Withdrawal of Consent

You can withdraw your consent to the processing of personal information at any time (such as withdrawing geolocation authorization and personalized recommendation authorization). After withdrawing consent, we will no longer process your relevant information based on that consent, but this will not affect the legality of the information processing activities completed based on your prior consent, nor will it affect your use of other core services that do not require such authorization. You can withdraw consent through the following methods:
  1. Withdrawal of Device Authorization: Withdraw relevant authorization through your device settings (such as “Settings – Privacy – Location Services” on a mobile phone);
  2. Withdrawal of Platform Authorization: Withdraw relevant authorization through the “Settings – Privacy Permissions” function on the official website, or contact customer service for assistance.

6.5 Account Cancellation

If you no longer use our products or services, you can apply to us for account cancellation. After account cancellation, we will anonymize your personal information (unless otherwise stipulated by laws and regulations), and you will no longer be able to log in and enjoy relevant services using that account. You can submit an account cancellation application by contacting customer service. We will complete the cancellation process within 10 working days after verifying your identity and notify you via SMS or email.

6.6 Feedback on Right Exercise

If you cannot smoothly exercise the relevant rights through the above methods, or have objections to our processing results, you can file a complaint with our privacy protection officer through the contact information at the end of this Policy. We will reply and handle it within 5 working days after receiving the complaint.

7. How We Process Minors’ Personal Information

Our products and services are mainly targeted at adults (18 years old and above). We do not actively collect personal information of minors (under 18 years old) unless with the explicit consent of the minor’s guardian. If a guardian discovers that a minor has provided personal information to us without their consent, they can contact us immediately, and we will verify and delete the relevant information in a timely manner. For the personal information of children under 14 years old that we collect, we will comply with the provisions of the “Provisions on the Protection of Children’s Personal Information Online” and other legal and regulatory requirements and take stricter protection measures.

8. Updates to This Policy

This Privacy Policy may be revised with the update of laws and regulations, adjustment of business models, or technological development. We will publish the updated Privacy Policy in a prominent position on the official website (such as the “Privacy Policy” column at the bottom of the homepage) and remind you to review it through pop-ups, SMS, emails, and other means. The updated Privacy Policy shall take effect from the date of publication. If you continue to use our products or services after the policy update, it indicates that you agree to all the contents of the updated version.
For major changes (including but not limited to significant changes in the scope and purpose of information collection, significant adjustments to the rules for sharing/transferring personal information, and significant changes in the way you exercise your rights), we will remind you through a more prominent method (such as sending a separate notice) and obtain your explicit consent in accordance with legal and regulatory requirements.

9. How to Contact Us

If you have any questions, suggestions, or need to exercise relevant rights or file complaints and reports regarding this Privacy Policy, you can contact us through the following methods:
  • Privacy Protection Officer Contact Number: +86 18883832018
  • Privacy Protection Dedicated Email: cqdebenhang@gmail.com
  • Company Contact Address: Chongqing Chongqing Jiulongpo No. 988-6 Lanmei Road
We will reply to and handle your contact request appropriately within 3-15 working days depending on the type of issue. If you are not satisfied with our processing results, you can file a complaint or report with the local Internet Information Office, Consumer Association, and other relevant regulatory authorities.

10. Miscellaneous

The establishment, effectiveness, performance, interpretation, and dispute resolution of this Privacy Policy shall be governed by the laws and regulations of the Chinese mainland (excluding conflict of laws rules). If any dispute arises between you and us regarding the content or implementation of this Privacy Policy, it shall first be resolved through friendly negotiation; if negotiation fails, either party shall have the right to file a lawsuit with the people’s court having jurisdiction over our registered place.
This Privacy Policy is the core agreement between you and us regarding personal information protection. The content related to personal information protection in supplementary agreements, service terms, and other relevant documents shall not conflict with this Policy.
 
Chongqing Debenhang Trading Co., Ltd.
November 14 / 2016