HCC Mall Privacy Policy

HCC Mall (hereinafter referred to as the "Mall", operated by HCC Group Limited) respects and protects the personal information and privacy of all users of the Mall's services. This Privacy Policy sets out the terms regarding how we collect, store, use, share, and protect the personal information of users ("you"). We hope this Privacy Policy clearly explains how we provide you with access to, updates of, control over, and protection of your personal information. We therefore recommend that you read this HCC Mall Privacy Policy (hereinafter the "Privacy Policy") in full to understand how to protect your privacy rights. If you have any questions about this Privacy Policy, you may contact us through the Mall's customer service channels. If you do not agree with any part of this Privacy Policy, you should immediately stop using the Mall's services. By using the services provided by the Mall, you indicate that you agree to our lawful use and protection of your personal information in accordance with this Privacy Policy.

1. Definitions

HCC Mall: HCC Mall is an Internet service platform initiated by HCC Group Limited for resource integration and business innovation in the international cross-border e-commerce industry. It aims to build an open platform for win-win cooperation and mutual benefit in the cross-border e-commerce sector.

Affiliates: means HCC Group Limited, the operator of HCC Mall, and other companies that have an affiliated relationship with the Mall, whether referred to individually or collectively.

2. Scope of Application

This Privacy Policy applies to any services provided by the Mall. When you visit, log in to, and use the services provided by the Mall, this Privacy Policy applies.

In addition, for certain specific services in the future, we may formulate specific privacy terms to explain in more detail how we collect, process, store, use, share, and protect your information in connection with those specific services. Such specific privacy terms form part of this Privacy Policy. If there is any inconsistency between the privacy terms of a specific service and this Privacy Policy, the privacy terms of that specific service shall prevail.

This Privacy Policy does not apply to information collected by other third parties ("Other Third Parties", including but not limited to your counterparties in transactions, any third-party websites, and third-party service providers) in connection with services they provide to you through our services. We assume no responsibility for such third parties' use of your personal information or the consequences thereof. Please note that Other Third Parties may have their own privacy policies. When you view web pages created by Other Third Parties or use applications developed by Other Third Parties, you may find Cookies or pixel tags placed by those web pages or applications. Such Cookies or tags are not under our control, and their use is not governed by this Privacy Policy.

3. Information Collection

We collect information to comply with applicable laws and regulations, to provide you with better and more personalized services, and to improve your user experience. You may choose not to provide certain information; however, doing so may prevent you from becoming our user, from enjoying certain services we provide, or from achieving the intended effects of those services. Please understand that we use the information you provide to respond to your requests, to facilitate your use of our industry information sharing, cross-border e-commerce transactions, and other services, to improve our services, and to communicate with you. By providing the information described below or by using any of the Mall's services, you agree that we may collect information in accordance with this Privacy Policy. The types of information we collect are as follows:

Information You Provide to Us

To comply with applicable laws and regulations and to provide you with more personalized and convenient services, we need to identify you. When you register and log in to a Mall account through a third-party platform account, and when you use the Mall's services, you may be required to fill in, submit, and/or otherwise provide your personal information, including but not limited to your name, gender, date of birth, identification card number, phone number, and related additional information (such as the country/region, province, and city in your address). When you voluntarily cancel your account, we will anonymize or delete your personal information as soon as practicable in accordance with applicable laws and regulations. Any text, photos, videos, or other forms of information you submit when posting content on the Mall may also contain or be associated with your personal information.

Please note that when you log in to the Mall through a third-party platform account, we will obtain the account information you authorize to share (such as your avatar and nickname) and, after you agree to this Privacy Policy, bind your third-party platform account to your Mall account so that you can log in directly through the third-party platform account and use our products and/or services. After confirming the legality of the source of personal information pursuant to our arrangements with the third-party platform, and subject to applicable laws and regulations, we will use such personal information.

You may use the Mall to order services for others. In that case, you will need to provide the personal information of the actual order recipient as described above. Before providing such personal information to the Mall, you must ensure that you have obtained the recipient's authorization and consent.

Information We Obtain While You Use Our Services

To improve service quality and user experience, we retain information about your use of our services and related usage patterns. Such information includes:

(1) Log information from your browser and computer. When you use the Mall's services or visit the Mall's web pages, our systems automatically receive and record information from your browser and computer, including but not limited to your IP address, browser type, language used, date and time of access, hardware and software characteristics, and records of the web pages you request.

(2) Your location information. When you enable device location features, download or use applications we develop, or visit mobile web pages to use our services, we may access your location (most mobile devices allow you to disable location services; for specific methods, please contact your mobile device service provider or manufacturer).

(3) Your device information. If you download or use client software of the Mall or of affiliates of HCC Group Limited, or visit mobile web pages to use the Mall's services, we may access information about the terminal device you use to visit us or use our services, including but not limited to device model, device identifiers, operating system, screen resolution, and telecommunications carrier.

(4) Information about your behavior, style, and preferences. To meet your service needs and provide more personalized services, we may record searches and other operations you perform when visiting us or using our services, as well as information such as your favorites and preferences.

(5) In addition to the above, we may also collect other information as reasonably necessary to provide services and improve service quality, including information you provide when contacting our customer service team, questionnaire responses you send when participating in surveys, and information we obtain from your interactions with the Mall's Affiliates and partners. To improve the security of your use of the Mall's services and more accurately prevent phishing and Trojan virus risks, we may assess account risk by understanding aspects of your online habits and commonly used software information, and we may record links ("URLs") that we consider risky.

Please understand that device information, log information, and similar data alone cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it together with personal information, then during such combined use it will be treated as personal information. Except where we have obtained your authorization or where laws and regulations provide otherwise, we will anonymize and de-identify such personal information. Please understand and agree that in such circumstances we have the right to use de-identified information; and, without disclosing your personal information, we have the right to analyze the user database and make commercial use of it.

Personal Information We Obtain Indirectly

To ensure your service experience, including third-party platform services such as transactions and logistics, we may share your service-related personal information with third-party platforms that provide services to you.

Personal information obtained to provide you with security safeguards: Please note that to verify the authenticity of user identity and provide better security safeguards, you may provide us with identity information (such as an identity card, military officer's certificate, passport, driver's license, social security card, or residence permit), biometric information such as facial features, and sensitive personal information such as third-party personal credit information to complete real-name or credit authentication. If you refuse to provide the above information, you may be unable to use account management or continue certain transactions that may involve risk, but this will not affect your use of information browsing, search, and similar services.

To provide you with better, more optimized, more personalized, and more secure services; to protect you, other users, or the public from harm to person or property; to better prevent phishing websites, fraud, network vulnerabilities, computer viruses, cyberattacks, network intrusions, and other security risks; and to more accurately identify violations of laws, regulations, or the Mall's relevant agreements and rules, we may use or integrate your user information, transaction information, device information, related network logs, and, subject to legal requirements or your authorization and consent, personal information shared with the Mall by Affiliates, partners, and other independent third-party sources, to comprehensively assess your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and handling measures in accordance with law.

Exceptions to Obtaining Authorization and Consent

In accordance with relevant laws and regulations, we may collect your personal information without obtaining your authorization and consent in the following circumstances:

(1) Where related to national security or national defense security;

(2) Where related to public security, public health, or major public interests;

(3) Where related to criminal investigation, prosecution, trial, and enforcement of judgments;

(4) Where necessary to protect the major lawful rights and interests such as life or property of the personal information subject or other individuals, and it is difficult to obtain your consent;

(5) Where the personal information collected has been voluntarily made public by you;

(6) Where personal information is collected from lawfully publicly disclosed information, such as lawful news reports or government information disclosure channels;

(7) Where necessary for entering into a contract at your request;

(8) Where necessary to maintain the secure and stable operation of the products or services provided, such as discovering and handling product or service failures;

(9) Where necessary for lawful news reporting;

(10) Where necessary for academic research institutions to conduct statistics or academic research based on public interest, and where personal information contained in the results is de-identified when such academic research or descriptive results are provided externally;

(11) Other circumstances provided by laws and regulations.

Please note that all personal information you provide while using our products and/or services will continue to authorize our use during your use of our products and/or services, unless you delete it or refuse our collection through system settings. When you cancel your account, we will stop using and delete your personal information. If we cease operating the Mall's products or services, we will promptly stop collecting your personal information, notify you of the cessation of operations by individual notice or public announcement, and delete or anonymize the personal information we hold.

You acknowledge and agree that: the Mall may cooperate with third parties to provide related online services to users. In such cases, if the relevant entity under HCC Group Limited, the Mall's operating entity, has entered into appropriate confidentiality terms with such third party, the Mall has the right to share user registration information and other materials with that third party and to require the third party to process such information for us in accordance with our Privacy Policy and any other relevant confidentiality and security measures. In addition, without disclosing any individual user's private information, the Mall has the right to analyze the entire user database and make commercial use of it. The Mall may compile statistics on the use of network services and may share such statistical information with the public to show overall usage trends of our services. Such statistical information does not contain any personally identifying information about you.

4. Purposes and Methods of Information Use

To provide you with services, improve our service quality, and optimize your service experience, we will use your personal information in accordance with applicable law or based on your authorization, primarily for the following purposes:

To provide you with the various services you use, and to maintain and improve those services.

We may use the contact details in the personal information you provide to communicate with you, for example to notify you about your account, security updates, and product and service information. To better serve you, please promptly review relevant information sent by the Mall.

To recommend content that may interest you, including but not limited to sending you product and service information, displaying personalized third-party promotional information through our systems, or sharing information with the Mall's partners in accordance with this Privacy Policy so that they may send you information about their products and services. If you do not wish to receive such information, you may unsubscribe through the corresponding unsubscribe function.

We may use your personal information to verify identity and to prevent, detect, and investigate fraud, security threats, illegal conduct, or violations of agreements, policies, or rules with us or our Affiliates, in order to protect you, our other users, or HCC Group Limited and its Affiliates' lawful rights and interests.

We may combine personal information and transaction information from one service with information obtained from other services for comprehensive statistics, analysis, or processing, in order to provide you with more personalized services, including for use, sharing, or disclosure as needed to expand your social circle.

We may compile statistics on the use of our services and may share such statistical information with the public or third parties to show overall usage trends of our products or services. Such statistical information does not contain any personally identifying information about you.

To invite you to participate in surveys regarding our products and services.

Other purposes with your consent or authorization.

5. Information Sharing

Your personal information is an important part of the services we provide to you, and we will fulfill confidentiality obligations regarding your information in accordance with applicable law. Except in the following circumstances, we will not disclose your personal information to third parties:

Where we have obtained prior consent or authorization from you or your guardian;

Where necessary to protect you from imminent danger to life, body, or property;

Where required by laws and regulations or by administrative or judicial authorities;

Where we share your information with the Mall's Affiliates for the purposes described in the section on our use of your personal information, or to perform our obligations and exercise our rights under this Privacy Policy;

Where we provide your information to partners, provided that the relevant entity under HCC Group Limited has entered into appropriate confidentiality terms with such third party;

Where we conduct joint marketing activities with third parties, we may share personal information generated during the activity and necessary to complete the activity—such as the number of participants, winner lists, and winners' contact details—so that the third party can promptly deliver prizes to you;

Where for academic research or public interest purposes, and without harming your major interests;

Where you are complained against for intellectual property infringement, and disclosure is requested by the complainant so that both parties may handle potential rights disputes;

Where sharing your information is necessary to provide the services you need or to handle disputes or controversies between you and others. For example, in a transaction you create on the Mall, if either party has performed or partially performed its transaction obligations and requests information disclosure, the Mall may, as appropriate, provide that user with necessary information such as the counterpart's contact details to facilitate completion of the transaction or resolution of the dispute;

Where, in accordance with applicable law and reasonable commercial practice, HCC Group Limited plans to merge with or be acquired by another company, or engage in other capital market activities (including but not limited to an IPO or bond issuance), or where we otherwise need to undergo due diligence by other parties, we may provide your information to necessary parties, provided that we require them to take reasonable confidentiality measures regarding your personal information, including by entering into confidentiality agreements;

Where you agree to submit personal information to a third party by clicking the corresponding button for the relevant product;

Where disclosure to a third party is required because you have violated applicable Chinese laws or regulations, or have breached relevant agreements with us (including electronically signed online agreements) and related rules;

Where necessary to protect the lawful rights and interests of the Mall, HCC Group Limited and its Affiliates, or users.

Therefore, please carefully consider the content of information you upload, post, and communicate through our services. In some cases, you may use privacy settings in certain of our services to control who may view information you share. If you request deletion of your related information from our services, please follow the methods provided in the applicable special service terms.

6. Information Storage

Information and materials about you collected by the Mall will be stored on servers of the Mall and/or affiliates of HCC Group Limited. Such information and materials may be transmitted to your country or region, or to the place where the Mall collects the information and materials, and may be accessed, stored, and displayed there. We will retain your personal information for the period necessary to achieve the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

7. Access to and Changes of Your Personal Information

Whenever you use our services, we strive to make it easy for you to access your personal information. If such information is incorrect, we will endeavor to provide ways for you to quickly update or delete it (unless we must retain it for legitimate business or legal reasons). If you believe that the Mall or HCC Group Limited has collected or used your personal information in violation of laws, administrative regulations, or agreements with you, you may contact us through the Mall's customer service channels.

You may log in to your account to query and update your personal information. You may also change the scope of your authorization for us to continue collecting personal information, or withdraw your authorization, by deleting information, disabling device features, or similar methods; or you may withdraw all authorization for us to continue collecting your personal information by canceling your account. When you apply directly within our products to cancel your account, please refer to the "HCC Mall Account Cancellation Notice" for the methods and conditions for account cancellation. After you cancel your account, we will stop providing products and/or services to you and, at your request and except as otherwise required by laws and regulations, delete your personal information.

When you request the Mall's assistance to update/delete your personal information, we may first require you to verify your identity before processing your request. In principle, we do not charge fees for reasonable requests; however, for repeated requests or requests beyond a reasonable scope, we may charge a reasonable cost fee as appropriate. We may refuse requests that are unreasonably repetitive, that require excessive technical means (for example, developing a new system or fundamentally changing current practices), that pose risks to others' privacy rights, or that are highly impractical (for example, involving information stored on backup tapes). In the following circumstances, we will be unable to respond to your request as required by laws and regulations:

(1) Where related to national security or national defense security;

(2) Where related to public security, public health, or major public interests;

(3) Where related to criminal investigation, prosecution, trial, and enforcement of judgments;

(4) Where there is sufficient evidence that the personal information subject is acting in bad faith or abusing rights;

(5) Where responding to your request would seriously harm the lawful rights and interests of you or other individuals or organizations;

(6) Where trade secrets are involved.

8. Protection of Your Personal Information

We will take reasonable and feasible measures to avoid collecting irrelevant personal information as far as possible. We retain your personal information only for the period necessary for the purposes described in this Privacy Policy and for the periods required by laws and regulations. To safeguard your information security, we strive to take various reasonable physical, electronic, and managerial security measures to protect your information from leakage, damage, or loss, including but not limited to SSL, providing browsing services via HTTPS, encrypted storage of information, and access controls at data centers. We also apply strict management to employees or outsourced personnel who may have access to your information, including but not limited to different permission controls based on role, signing confidentiality agreements with them, and monitoring their operations. The Mall and HCC Group Limited will provide corresponding security measures based on current technology to protect your information and offer reasonable security safeguards. The Mall will endeavor to prevent your information from being leaked, damaged, or lost.

Your account has security protection features. Please properly safeguard your WeChat account, mobile phone number, and verification code information. The Mall will use security measures such as backing up to other servers to help ensure that your information is not lost, misused, or altered. Notwithstanding the foregoing security measures, please also understand that due to technical limitations and possible malicious means, even with every effort to strengthen security measures, there are no "perfect security measures" on information networks. We strongly recommend that you do not send personal information using communication methods not recommended by the Mall. You are solely responsible for any legal consequences arising from leakage of your account, mobile phone number, and verification code information due to your own reasons.

When using the Mall for online transactions, if you inevitably need to disclose your personal information (such as contacts and contact details) to a counterparty or potential counterparty, please carefully protect your personal information and provide it to others only when necessary. If you discover that your personal information has been leaked or may have been leaked, and that this may endanger the security of your Mall account obtained through registration and login, or cause you other losses, please notify Mall customer service immediately so that the Mall and HCC Group Limited can take corresponding measures to protect your Mall account security and prevent losses from occurring or expanding. For the avoidance of doubt, if you fail to notify Mall customer service promptly, you shall bear the resulting losses (and any expanded losses) yourself.

Please note that information you voluntarily share or even publicly disclose while using our services may involve your or others' personal information, including sensitive personal information—for example, if you choose to upload images containing personal information when posting reviews. Please carefully consider whether to share or publicly disclose such information when using our services.

If our physical, technical, or managerial safeguards are compromised, resulting in unauthorized access, public disclosure, alteration, or destruction of information and harm to your lawful rights and interests, HCC Group Limited will bear corresponding legal liability. After an unfortunate personal information security incident, we will inform you as required by laws and regulations of: the basic circumstances and possible impact of the security incident; the measures we have taken or will take; suggestions for how you can independently prevent and mitigate risks; and remedial measures available to you. We will notify you of incident-related information by email, letter, phone, push notification, or other means. Where it is difficult to notify each personal information subject individually, we will issue an announcement in a reasonable and effective manner. We will also report the handling of personal information security incidents to regulatory authorities as required.

9. Protection of Minors

Minors under the age of eighteen should use our services under the guidance of their parents or guardians. Without the consent of a parent or guardian, a minor may not create their own user account. If you are a minor, we recommend that your parents or guardians carefully read this Privacy Policy and that you seek their consent and guidance before submitting personal information. Once a minor uses this website, we will deem that the minor's parent or guardian has consented to or guided such use.

10. Miscellaneous

You understand that using the Mall in accordance with this agreement, using licensed software in accordance with applicable rules, and performing your obligations under this agreement are prerequisites for obtaining authorization from the Mall and HCC Group Limited to use the software and receive services in various sections of the Mall. If you seriously breach this agreement, the Mall will terminate the provision of services and this agreement will terminate. Upon termination of this license, you shall stop using the licensed software and destroy all copies of the licensed software. You shall fully and independently bear any liability arising from your conduct prior to termination of the agreement.

If you have any questions about this Privacy Policy, or if the personal information you provided has been compromised, you may contact us through the Mall's customer service center, and we will respond as soon as possible after receiving your complaint.

To provide you with better services, our business will change from time to time, and this Privacy Policy will be adjusted accordingly. We will remind you of updates by posting an updated version in our mobile applications or by other means. Please also visit us to stay informed of the latest Privacy Policy. In such circumstances, if you continue to use the services provided by the Mall, you indicate that you agree to be bound by the revised Privacy Policy. We encourage you to periodically review the latest information on this page regarding our privacy practices.

The Mall and HCC Group Limited are committed to safeguarding the confidentiality and security of your personal information and enabling you to maintain control over it.

You may contact us through the Mall's customer service channels or by email at 3804873168@qq.com, and we will reply within a reasonable time after receiving your request. If you are not satisfied with our reply, especially if you believe our personal information processing practices have harmed your lawful rights and interests, you may also seek a solution by filing a lawsuit with a court having jurisdiction over the defendant's domicile.