Chinese Privacy Policy

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Ocean Network Express Personal Information Protection Policy

Welcome to the Ocean Network Express Personal Information Protection Policy! This Personal Information Protection Policy is issued by the Ocean Network Express Pte. Ltd. and its affiliated companies (“we” or “ONE”). We respect your privacy and are committed to protecting your personal information. In this Personal Information Protection Policy, we will explain to you about the purpose, method and scope of the collection and use of your personal information by us, your rights to your personal information, and the security measures we take to protect your personal information, through your use of any ONE e-Commerce or ONE QUOTE platforms (“Platforms”) via our website or our mobile application. The ONE Platforms including all systems listed here: Ecommerce Applications. Personal information refers to various information which is recorded in electronic or any other form and used alone or in combination with other information to recognize the identity of a natural person.

Before using the Platforms, please read this Personal Information Protection Policy carefully to learn our practices to protect your personal information. If you do not agree with the terms herein, you can turn off the Platforms by clicking “Disagree” and we will not be able to provide you with our services. If you click “Agree”, it means that you fully and clearly understand the following terms regarding information collection and usage, your rights to your personal information, etc. It is important that you read this Personal Information Protection Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are fully aware of how and why we are using your personal information. This Personal Information Protection Policy supplements the other notices and is not intended to override them.

This Personal Information Protection Policy will help you understand the following:

How We Collect and Use Your Personal Information
How We Use Cookies and Similar Technologies
How We Retain Your Personal Information
How We Share, Transfer or Publicly Disclose Your Personal Information
How We Protect Your Personal Information
Your Rights to Your Personal Information
How We Process Children's Personal Information
Third-party Service Providers and Their Services
How Your Personal Information is Transferred Globally
How This Personal Information Protection Policy is Updated

How We Collect and Use Your Personal Information

We collect personal information for more efficient operation and to provide you with best usage experience. Our channels to collect personal information include: (1) Direct interactions. You may provide us with your identity and contact information by filling in columns in our user interface. (2) Automated technologies or interactions. As you interact with our Platforms, we may automatically collect technical data about your equipment, coupled with behavioral data including browsing actions and patterns. At current stage, we will only collect your personal information directly from you and will not receive any personal information from third-party partners. For more details, please refer to the subsection “How We Collect Your Personal Information”.

The information we collect depends on the service you actually use, the environment in which you interact with us, the choices you make, including your privacy settings and the features you enjoy. You are not necessarily required to provide us with your personal information. Notwithstanding that if you decline to provide the personal information which is necessary for our core features, we may be unable to provide you with relevant services regarding online booking, or respond to or solve any problems with which you are confronted. For other personal information, you may decide whether or not you permit us to collect. If you decline to do so, it may cause relevant customized functions to be unavailable, but will not compromise your use of our core features.
1. How We Collect Your Personal Information
1. Information collected from direct interactions.
  - To provide you with the rate search functions
    
    In addition to conducting rate search on our website, you may also choose to browse relevant information by registering in our mobile application. If you choose to do rate search on our mobile application, we may collect your contact name, company name, city, phone number, email address and password, in order to satisfy the real-name registration requirement and to identify which company you are working in. However, the services and features enjoyed by mobile application users is quite limited, therefore, it is suggested to register in our website as a user of e-Commerce, for the sake of placing orders, submitting shipping instructions and enjoying other diverse functions. At current stage, you can register as an e-Commerce user only via our website, rather than the mobile application; but you can log in your e-Commerce account via both our website and mobile application.
  - To create and maintain your account in e-Commerce
    
    To provide you with e-Commerce account registration functionality, we may collect certain personal information, including user ID, password, first name & last name, phone number, to register you for an account; your email address is also necessary for us to send you alerts and notifications; besides, we may also collect certain company information, including the company name, country/district, city, address and company type, in order to verify your identity, validate legitimacy of the company you are working for, and perform due diligence check on any legal sanction has been issued to your company. This information is necessary for us to create and activate your account and complete our KYC process. If you decline to provide the above information, neither could we create or activate your account, nor furtherly provide you with the services contained in our Platforms.
    
    We also provide you with service to complete your profile, you can choose whether to provide us with your fax number, company’s zip code, for us to serve you with more tailored services. You may choose whether to fill in the above information when registering or completing your profile. We will not compel you to provide such information. Declining to provide the above information will not comprise the basic services contained in our Platforms.
  - To provide you with the online booking services and shipping instructions submission services
    
    After you registered as an e-Commerce user, you can proceed with online booking services, upon acceptance of the offered rates. You are required to provide the customer information, i.e., customer details of the shipper, consignee, notify party, freight forwarder. But all the mandatory information are concerned with company, not related to personal information of any individual. If you decline to provide such information, neither could you book online, nor submit shipping instructions. The shipping instructions submission is currently not yet included in the beta launching of our Platforms, however this will be available later.
    
    Additionally, you may also provide email address or phone number relating to an individual as contact information of a customer. Please be noted that if you are providing personal information of other individuals, please make sure that the other individuals are aware of the purpose for collecting his/her personal information and all other relevant arrangement described herein, and that he/she has consented to such disclosure and information processing.
  - To provide the live chat services
    
    In order to enable you to send inquiries to local offices in ONE either to local Sales or local CSVC, you may use the live chat feature powered by LiveChat Software S.A.. You are required to provide us with the name and email address. Besides, you may also provide us with your country information for us to redirect to a local specialist. If you decline to provide this information, we will not be able to provide the live chat services to you.
2. Information collected via automated technologies or interactions
  - To ensure the normal operation of our Platforms and your account security
    
    In order to ensure the normal operation of our Platform and your account security (including troubleshooting, testing, system maintenance, support, reporting and hosting of data), and to optimize user experience, we may collect certain technical data, including internet protocol (IP) address, your user ID and password , browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our services.
  - To provide you with personalized service
    
    In order to provide you with personalized service, such as to display and push to you information more suitable for you, we may collect your browsing actions and patterns for user profiling and behavioral analysis, including how you use our services, your preferences in receiving news or newsletters from us, reports and emails related to your shipments. You have the right to withdraw consent to marketing at any time by contacting our data privacy team using the details set out at the bottom of the Personal Information Protection Policy. After you turn it off, we will no longer use your information to personalize the marketing information you view.
  - To detect Platforms’ performance and optimize your experience
    
    In order to detect Platforms’ performance and optimize our services, we also collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal information but is not considered as personal data in law as this data does not directly or indirectly reveal your identity (for example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature or our mobile application). If we combine or connect aggregated data with other data so that it can directly or indirectly identify you, we treat it as personal data, which will be used in strict accordance with this Personal Information Protection Policy.
1. How We Use Your Personal Information
  
  When we need to fulfill our obligations to you under the Terms & Conditions and/or the Service Contract, or legal obligations bound to us, or we consider it necessary to protect the legitimate interests of us or third parties upon evaluation, we will process your personal data for the purposes described herein subject to your consent. We will use your personal data in strict accordance with this Personal Information Protection Policy and its updated versions. Your personal data is only used for the purposes explicitly stated upon collection and to the extent you agreed. Your personal data is only used for the purposes that are explicitly agreed by you at the time of collection. For any purposes other than that, we will acquire your prior consent.
  - Your personal information will be used in the application scenarios and purposes set out in “How We Collect Your Personal Information” section.
  - Any use of your personal information to the extent beyond the purposes disclosed herein is subject to our further notice to you and your explicit consent.
2. Exceptions to Acquire Authorization and Consent for Collection and Use of Personal Information
  
  You fully understand that, under applicable law, we do not need to obtain your authorization and consent for collection and use of your personal information in the following situations:
  - where it is related to our performance of obligations provided by laws or regulations;
  - where there is a direct relation to national security or national defense;
  - where there is direct relation to public safety, public health, or major public interests;
  - where there is a direct relation to criminal investigations, prosecutions, trials, or enforcement of judgments and the like;
  - where it is done to preserve the life, property, or major lawful rights and interests of you or another person, and it is very difficult to obtain your consent;
  - where the personal information involved was voluntarily disclosed to the public by you;
  - where it is done to enter into and perform a contract between you and us;
  - personal information that is collected from lawfully disclosed information, such as lawful news reports, open government information, and other such channels;
  - where used to preserve the stable operations of this Program, such as discovering or handling problems with the product or service;
  - where it is necessary for a news agency to carrying out lawful news reporting activities;
  - where it is needed to carry out statistics or academic research in the public interest for academic research institution, and when providing outcomes of academic research or descriptions, de-identification of personal information contained in the outcome has been conducted.
How We Use Cookies and Similar Technologies
1. How We Collect Your Personal Information
  
  A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the site or browse from one page to another. The main function of cookies is to facilitate your use of our Platforms, and to help us calculate the number of unique visitors. Application of cookie technology enables us to provide you with more thoughtful and personalized services and allow you to select specific service options.
2. How do we use cookies?
  
  A number of our pages use cookies to remember:
  - your display preferences, such as contrast color settings or font size
  - if you have already replied to a survey pop-up that asks you if the content was helpful or not (so you won't be asked again)
  - the technical data about you if you visit other websites employing our cookies
  - if you have agreed (or not) to our use of cookies on this site
  Also, some videos embedded in our pages use a cookie to anonymously gather statistics on how you got there and what videos you visited.
  
  Enabling these cookies is not strictly necessary for the Platforms to work but it will provide you with a better browsing experience. You can delete or block these cookies, but if you do that some features of this site may not work as intended.
  
  The cookie-related information is not used to identify you personally and the pattern data is fully under our control. These cookies are not used for any purpose other than those described here.
3. Do we use other cookies?
  
  Some of our pages or subsites may use additional or different cookies to the ones described above. If so, the details of these will be provided in their specific cookies notice page. You may be asked for your agreement to store these cookies.
4. Clear/disable cookies
  
  In principle, we will only enable cookies or similar technologies after obtaining your explicit consent, and collect your information through cookie. You can turn on the cookie related functions or perform corresponding operations through methods to manage cookies or set cookie preferences in commonly used browser software disclosed below. We will strictly follow your decision to use cookies and similar technologies.
  
  Certain functions of our products and/or services depend on cookies, and if you reject or delete cookies, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work. The guidance on how to disable, delete or manage cookies in commonly used browser software is detailed as follows:
How We Retain Your Personal Information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, unless a longer retention period is provided by laws and regulations. Upon expiration of such retention period, we will delete or anonymize your personal information.

If we cease to operate some or all of our services for special reasons, we will promptly inform you and quit the collection and processing of personal information accordingly, and we will delete or anonymize the personal information we hold that is related to the said services, unless otherwise is required by laws and regulations.
How We Share, Transfer and Publicly Disclose Your Personal Information

We may, from time to time, share and transfer some personal information with the parties set out below for the prescribed purposes:
- Other companies in the ONE Group acting as joint controllers or processors and who are based in Japan and Singapore and who provide IT and system administration services and undertake leadership reporting. In order to provide you with services based on your account and to ensure your experience is optimum, we may share your personal information with the companies aforementioned. We will only share personal information that is necessary.
- Service providers. Some of our services will be provided by our authorized third-party partners solely for the purposes stated in this Personal Information Protection Policy. We may share some of your personal information with our partners to provide services and to improve user experience. We will only share personal information that is necessary.
- Professional advisers. We may share your company name and address to third-party professional advisers including external auditors and consulting company for improve your using experience.
- Regulators and governmental authorities. In certain circumstances, we need to report some of your personal information to regulators and governmental authorities in order to fulfill lawful obligations. We will share the personal information only when it is required by laws and regulations to the necessary extent.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, we will cause the new owners taking possession of your personal information to be bound by this Personal Information Protection Policy, or otherwise obtain your authorization or consent.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. Where we disclose your personal information to third-party information processors, we will not allow third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions. Where we disclose your personal information to third parties that are joint information controllers, such third parties will be under direct obligations to you.

We will enter into proper confidentiality agreements with any companies, organizations or individuals to whom personal information is shared, requiring them to use personal information solely for the purposes set out in this Personal Information Protection Policy and take relevant confidentiality and security measures to process personal information.

We will keep your personal information confidential in accordance with applicable laws and regulations, and not disclose your personal information unless your explicit consent or authorization is obtained, or as required by law. We may only disclose your personal information as demanded by law, subpoena or other legal procedures, litigation or mandatory requirements of government authorities. If we sincerely believe that disclosure is necessary to protect our rights, the safety of you or others, investigate fraud or respond to government requirements, we may disclose your personal information publicly.
How We Protect Your Personal Information
1. We have put in place appropriate security measures, including internal security policies, regular security audit and penetration testing, to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
2. To protect the security of your information, we have developed relevant systems, processes and organizations to protect information security. In particular, we put a strict limit on persons with the right to access information. Specifically, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and are subject to a duty of confidentiality.
3. When you use our services, please properly keep your account number and password, which will be used by us to identify you. Your disclosure of your account number and password to others may result in loss of your information or cause adverse legal consequences to you. If your account number and password have been or are to be disclosed for any reason, you should contact us immediately after you become aware of such disclosure, so that we can take prompt and proper measures to prevent or reduce losses arising therefrom.
4. We have put in place emergency response procedures to deal with any suspected personal information breach. Upon occurrence of divulgence of personal information or any other security incidents, we will initiate the procedures to prevent the case from getting worse, and promptly inform you of the following: the basic situation and possible impact of the security incident, disposal measures we have taken or will take, suggestions for your self-protection and risk mitigation, remedies for you, etc. We will timely inform you of the relevant situation of the event by email, letter, telephone, or push notification. When it is difficult to inform the personal information subjects individually, we will issue an announcement in a reasonable and effective manner. Besides, we will also notify any applicable regulator of a breach where we are legally required to do so and actively report the handling of the personal information security incident in accordance with the requirements.
5. The Internet environment is not 100% secure. We will use our best efforts to ensure or guarantee the security of any information you sent to us. We will be liable for any damage to your legal rights and benefits resulting from unauthorized access, public disclosure, alteration or destruction of information due to any damage to our physical, technological or administrative protection facilities.
Your Rights to Your Personal Information

We respect your rights to your personal information. Under certain circumstances, you have the following rights under information protection laws and regulations in relation to your personal information.
1. Right to be informed: By publishing this Personal Information Protection Policy, we inform you how we collect and process your personal information. We are committed to ensuring the transparency in the use of your information.
2. Right to access: You can query or access your personal information in our Platforms’ user interfaces. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You can request a copy by contacting our data privacy team using the details set out at the bottom of the Personal Information Protection Policy, and we will process and give feedback in time according to laws and regulations.
3. Right to correction: When you find that your personal information that we are processing is incorrect or incomplete, you have the right to require us to make rectifications or supplements, though we may need to verify the accuracy of the new information you provide to us. You can request correction or supplementation by contacting our data privacy team using the details set out at the bottom of the Personal Information Protection Policy, and we will process and give feedback in time according to laws and regulations.
4. Right to erasure: You may ask us to delete or remove personal information: (a) where there is no good reason for us continuing to process it; (b) where you have successfully exercised your right to object to processing (see below); (c) where we may have processed your information unlawfully; or (d) where we are required to erase your personal information to comply with applicable laws and regulations. You can request erasure by contacting our data privacy team using the details set out at the bottom of the Personal Information Protection Policy, and we will process and make feedback in time according to laws and regulations.
5. Right to cancel account: You are provided with account cancellation service by contacting our data privacy team using the details set out at the bottom of the Personal Information Protection Policy, which allows you to cancel your account. After you choose to cancel your account, we will delete or anonymize all your relevant personal information according to laws and regulations, unless otherwise provided by laws and regulations. After the cancellation, we will not be able to continue to provide you with products or services that require you to log in your account.
6. Right to object to processing: You can object to the processing of your personal information in the case of anything makes you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. You can exercise your right to objection of processing by contacting our data privacy team using the details set out at the bottom of the Personal Information Protection Policy, and we will process and make feedback in time according to laws and regulations.
7. Right to restriction of processing: This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it. You can exercise your right to restriction of processing by contacting our data privacy team using the details set out at the bottom of the Personal Information Protection Policy, and we will process and make feedback in time according to laws and regulations.
8. Right to withdraw consent: Certain basic personal information is required for realizing each business function (please refer to the section “How We Collect and Use Your personal information”). You can change the scope of your consent for us to continue collecting personal information or withdraw your consent by deleting information, changing the relevant function setting page, or cancelling your account, etc. However, this will not affect any lawful processing based on your authorization consent carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can exercise your right to withdraw your consent by contacting our data privacy team using the details set out at the bottom of the Personal Information Protection Policy, and we will process and make feedback in time according to laws and regulations.
  
  You have the right to withdraw consent to marketing at any time by contacting our data privacy team using the details set out at the bottom of the Personal Information Protection Policy. After you withdraw your consent, we will no longer use your information to personalize the marketing information you view.
9. Right to complain: You have the right to contact us and file service complaints by contacting our data privacy team using the details set out at the bottom of the Personal Information Protection Policy. We will respond within 15 days from the date of receipt of your complaint. If you are dissatisfied with our response, especially if our handling of personal information damages your legal rights, you can also file a complaint or report to the regulatory authorities such as cyberspace administration departments, public security organ, administration for market regulation, or file a lawsuit in a court with jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authorities so please contact us in the first instance.
Please note that, due to security reasons, we may verify your identity before processing your request. In principle, we do not charge any fees if your request is reasonable. However, based on the actual situation, we may impose a certain fee to cover our costs for repeated requests or requests that extend beyond reasonable limits. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), may be detrimental to the legal rights and interests of others, or are very impractical. In addition, we may not be able to respond to your request if your request is directly related to matters involving national security, national defense, public health, criminal investigation and other public interests, or if the request may severely impair the legitimate rights and interests of yours or those of other individuals and organizations.
How We Process Children’s Personal Information

Pursuant to the relevant laws and regulations, if you are a child under the age of 14, before using our Platforms, you shall obtain consent from your parents or legal guardians. Our Platforms are not intended for children under the age of 14 and we do not knowingly collect information relating to children. If we collect the personal information of children on an occasional basis, we will delete the relevant information as soon as possible after verification. If you find that we have collected the personal information of children during your usage of the Platforms, please contact us by contacting our data privacy team using the details set out at the bottom of the Personal Information Protection Policy. Upon receipt of your notice, we will verify it in a timely manner and delete relevant information after verification.
Third Party Service Providers and Their Services

Our Platforms may include links to third-party websites, plug-ins and applications (such as the live chat function powered by LiveChat Software S.A.). Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party platforms and are not responsible for their privacy statements. When you leave our Platforms, we encourage you to read the privacy notice of every platforms you visit. Please check and understand the privacy protection policies of these third parties before submitting personal information to third parties.
How Your Personal Information Is Transferred Globally

As a globally operating company, we provide our products or services through resources and servers around the world. Under the premise of not violating local data protection laws and regulations, we will share your personal information within the ONE Group and will store your personal information outside China in order to ensure the service quality and to benefit customers. For example, the “Shipper” and “Consignee” information used in the past shipment information is stored in Singapore to ensure the customer experience is optimum during booking creation process; customer information is also centralized in our operational system located in Singapore to ensure we conduct de-duplication process to eliminate any requirement for registered customer to duplicate registration.

You understand that different data protection laws involve different risks. In such cases, we will take measures to ensure that the information we collect is processed in accordance with this Personal Information Protection Policy and applicable laws and regulations. For example, we will acquire your consent to transfer your personal information overseas, and we will implement security measures such as encryption, de-identification, and signing necessary data transfer/sharing agreements with data recipients prior to cross-border data transfer.
How this Personal Information Protection Policy is Updated

This Personal Information Protection Policy is subject to updates or revisions from time to time. However, without your express consent, we will not diminish your rights herein. We will send you change notice through different channels. If you provide us with an email address, we will notify you by email before the change becomes effective, otherwise we will post notices on our Platforms or push notifications to you through our devices.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

This Personal Information Protection Policy shall come into force as of the date of update.

We have appointed a data privacy team who are responsible for overseeing questions in relation to this Personal Information Protection Policy. If you have any questions herein, including any requests to exercise your legal rights, please contact the data privacy team by using the details set out below.

Our full details are:
- Full name of legal entity: Ocean Network Express Pte. Ltd.
- Title: Data Privacy Team
- Email address: [email protected]
- Postal address: 7 Straits View, #16-01 Marina One East Tower, Singapore, 018936

Last updated: February 22, 2021

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