Yanfeng Hainachuan Privacy Notice

Yanfeng Hainachuan Automotive Trim Systems Co. Ltd. (registered in China, 55 Shuntong Road, 101300 Beijing) and its subsidiaries and affiliated companies (collectively YFBHAP, we, us or our) care about your privacy and are committed to processing your personal information in accordance with fair information practices and applicable data privacy laws.

Scope of this Privacy Notice

This Privacy Notice explains how we handle individuals’ personal information in the different locations where we operate. Personal information is all information relating to an identified or identifiable individual.

How and where we collect personal information

We collect personal information in a variety of ways through our normal business activities, in both online and offline contexts. This includes, for example, when you place orders or purchase products or services, enter into agreements or communicate with us, or visit and use our websites. We also receive personal information from our customers and suppliers in order to enter into business relationships and to perform services. We may also receive personal information from third parties, including public databases, social media platforms, or third party partners such as analytics or marketing providers.

What personal information we may collect

Personal information that we collect from individuals may include:

·         Contact Information that allows us to communicate with you, such as your name, job title, age and prefix, username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages, company information and registration information you provide on our website.

·         Relationship Information that helps us do business with you, such as the types of products and services that may interest you, contact and product preferences, languages, creditworthiness, marketing preferences and demographic data.

·         Transaction Information about how you interact with us, including purchases, inquiries, customer account information, order and contract information, delivery details, billing and financial data, details for taxes, transaction and correspondence history, and information about how you use and interact with our websites.

·         Security and Compliance Information that helps us to secure our interests, including information for conflict checks, fraud prevention and internal verification, as well as information necessary for the security of our premises, such as visual recordings.

Purposes for which we use personal information

We use personal information in the context of our normal business activities, which includes the following purposes:

·         Fulfilling your orders for products or services and related activities, such as product and service delivery, customer service, account and billing management, support and training and to provide other services related to your purchase.

Managing our contractual obligations and your ongoing relationship with us, including interacting with you, informing you about our products or services, as well as special offers and promotions.

·         Ensuring the security of our websites, networks and systems, and premises, as well as protecting us against fraud.

·         Managing our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, fulfillment, corporate governance, audit, reporting and legal compliance.

·         Analyzing information that is provided by third parties (e.g. Goolge Analytics) to improve our websites.

Legal basis for our processing of personal information

These processing operations are based on one of the following legal bases, as applicable:

·         the need to process your personal information for contract performance or to take steps to enter into a contract with you,

·         YFBHAP’s legal obligations,

·         YFBHAP’s legitimate business interests, including operating our business properly, marketing and improving our services (including our websites), protecting against fraud and other liabilities, ensuring compliance and our ability to assert legal defenses, guaranteeing the security of our networks and systems, and protecting our assets, and

·         in some specific circumstances, your consent.

When you visit our websites or otherwise request us to provide a service, we will notify you when information is required to provide our services or as required by law. Where your personal information is required, we may be unable to provide you with our services unless you provide us with the relevant information.

How we protect personal information we process on behalf of our customers

In some instances, we process personal information on behalf of our customers as a service (in a data processor capacity). We collect and process this personal information only as instructed by our customer and will not use or disclose it for our own purposes.

We maintain information security controls to protect your information and will only disclose or transfer the personal information as instructed by the customer or to provide the requested service. Unless otherwise instructed by the customer, we treat the personal information we process on behalf of our customers in line with our commitments on disclosure and transfer as set forth in this notice.

How we manage privacy on our websites

Data provided voluntarily by you

You may provide certain information voluntarily on our websites for a determined purpose, e.g. any information entered when expressing an interest in being contacted, specifically as Candidate or Supplier. Such data may include personal contact information, such as name, company name, address, phone number, email address, job position, or demographic information (for example, zip code, employing industry, or country) and any other information provided by You. YFBHAP uses that data collected to contact the person who submitted such information. That data will be collected at first in the Drupal System and then send by email to internal email address saved in Drupal System.

Cookies, usage data and similar tools

When you visit our websites, we and/or our webspace provider collect certain information in the form of server log files and by other automated means, using technologies such as cookies, browser analysis tools and server logs. In many cases, the information we collect using cookies and other tools is used in a non-identifiable way, without any reference to personal information.

Why should I allow cookies?

The information contained in cookies is used to improve services for you, for example:

·         enabling a service to recognize your device so you don't have to give the same information several times for a task or during a session, e.g. filling out a web form or a web survey

·         allowing the video player to function properly

·         measuring how many people are using services, enabling those services to be made easier to use and ensuring there's enough capacity to keep them fast; analyzing anonymized data to help us understand how people interact with the different aspects of our online services so we can make them better

What if I do not accept or chose to opt-out?

If you decide not to accept cookies, certain features of this website may not be displayed or not work properly. This will restrict what you can do on our site and may have an impact on design and user experience. Examples of features that may be affected:

·         receiving a personalized experience of the website

·         watching videos

·         liking and sharing this page on social networks

·         viewing embedded content 

Cookie列表

Cookie是网站在用户访问时要求您的浏览器在您的设备上存储的一小段数据（文本文件），以便记住您的信息，如您的语言偏好或登录信息。这些cookies由我们设置，称为第一方cookies。我们还使用第三方cookie--这些cookie来自与您正在访问的网站域名不同的域，用于我们的广告和营销工作。更具体地说，我们将cookies和其他跟踪技术用于以下目的。

定向 Cookie

这些 Cookie 由广告合作伙伴通过我们的网站进行设置。这些公司可能利用 Cookie 构建您的兴趣分布图并向您展示其他网站上的相关广告。它们只需识别您的浏览器和设备便可发挥作用。如果您不允许使用这些 Cookie，您将不能体验不同网站上的定向广告。

功能 Cookie

这些 Cookie 允许提供增强功能和个性化内容，如视频和实时聊天。我们或我们已将其服务添加至我们页面上的第三方提供者可以进行设置。如果您不允许使用这些 Cookie，则可能无法实现部分或全部功能的正常工作。

绝对必要的 Cookie

网站运行离不开这些 Cookie 且您不能在系统中将其关闭。通常仅根据您所做出的操作（即服务请求）来设置这些 Cookie，如设置隐私偏好、登录或填充表格。您可以将您的浏览器设置为阻止或向您提示这些 Cookie，但可能会导致某些网站功能无法工作。

Data we collect via cookies is saved by us using the same strict security measures taken with all other information. We only use this data to the extent defined in this Privacy Notice.

Our server logs also collect information about how users utilize the websites (usage data). This data may include a user's domain name, language, type of browser and operating system, Internet service provider, Internet protocol (IP) address, the site or reference directing the user to the website, the website you were visiting before you came to our website and the website you visit after you leave our site, and the amount of time spent on the website. We may monitor and utilize usage data to measure the website's performance and activity, improve the website's design and functionality or for security purposes. Our employees and the service providers engaged by YFBHAP are obliged to maintain confidentiality and to comply with the provisions of applicable data protection rules

Some YFBHAP websites incorporate content and services from other providers (e.g. Facebook, YouTube, Twitter, LinkedIn and Xing) which may use cookies as well. YFBHAP has no control or influence on the processing of personal data by these providers. Your interactions with a particular feature are governed by the applicable privacy policy of the company providing such feature. Please refer to the respective provider‘s websites for information about how your data is processed.

You can change your browser settings to block or notify you when you receive a cookie, delete cookies or browse our website using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our websites may not function properly if you do not accept cookies or these technologies.

Where required by applicable law, you will be asked to consent to certain cookies and similar technologies before we use or install them on your computer or other device. You can view or change your consents and settings at any time using the preference center on the website.

Google Analytics

This website uses Google Analytics, a web analysis service provided by Google Inc. (?Google“). Google Analytics Data Processing Amendment with Google was signed. Google Analytics uses cookies which allow the analysis of your usage of our website. The information created by such cookie about your usage of this website are generally transferred to a server of Google in the USA and stored there.  We want to inform you, though, that Google Analytics on this website has been extended by the Code ?anonymizeIP“, to ensure an anonymized collection of IP-addresses (so called IP-Masking) which means that the IP-address will be cut by Google within the member states of the European Union or in other countries within the EEA. Only in single cases the full IP address will be transferred to a servicer of Google in the USA and cut there. As instructed by us, Google will use that information to analyze your usage of this website, to create reports on website activity and to render further services connected to the website and internet usage for us. The IP-address transferred by your browser in connection to Google Analytics will not be linked to other data of Google. In addition to the general possibility to prevent our website storing cookies on your computer (see above) you can also prevent the collection of information related to your usage of this website created by that cookie (including your IP-address) as well as the processing of such data by Google by downloading and installing the browser plug-in you can find here: https://tools.google.com/dlpage/gaoptout?hl=en. An opt-out cookie will be set which will prevent the future collection of your data when visiting this website: Click here to opt-out of Google Analytics. Further Information on the Terms of Use and Data Protection you can find at https://www.google.com/analytics/terms/gb.html or at https://policies.google.com/?hl=en.

Do Not Track Requests

Some browsers have incorporated features that can send a signal to websites you visit to notify those sites that you elect not to be tracked (a “Do Not Track” signal). We currently do not respond to web browser Do Not Track signals because a uniform technological standard has not yet been developed. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org/.

Linked sites

We may provide links to third parties' websites (“linked sites”) from our websites. Linked sites are not necessarily reviewed, controlled or examined by us. Each linked site may have its own terms of use and privacy notice, and users must be familiar and comply with all such terms when using linked sites. We are not responsible for the policies and practices of any linked site, or any additional links contained in them. These links do not imply our endorsement of the linked sites or any company or service and we encourage users to read these linked sites’ terms and notices prior to using them.

Children

Our websites are not directed at children and we do not use our websites to knowingly solicit personal information from or market to children. If we learn that a child has provided personal information through one of our websites, we will remove that information from our systems.

Security measures for protecting personal information

We apply appropriate technical, physical and organizational measures that are reasonably designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where personal information is transferred over a network, and against all other unlawful forms of processing. Access to personal information is restricted to authorized recipients on a need-to-know basis. We maintain a comprehensive information security program that is proportionate to the risks associated with the processing. The program is continuously adapted to mitigate operational risks and to ensure the protection of personal information taking into account industry-accepted practices. We will also use enhanced security measures when processing any sensitive personal information.

Sharing personal information with third parties

We may use third parties to provide or perform services and functions on our behalf. We may make personal information concerning individuals available to these third parties, as necessary, to perform these services and functions. Any access to that personal information will be limited to the purpose for which the information was provided.

We may also make personal information concerning individuals available to public or judicial authorities, law enforcement personnel and agencies as required by law, including to agencies and courts in China and the United States and other countries where we operate. Where permitted by law, we may also disclose such information to third parties (including legal counsel) when necessary for the establishment, exercise or defense of legal claims or to otherwise enforce our rights, protect our property or the rights, property or safety of others, or as needed to support external audit, compliance and corporate governance functions.

Personal information may be transferred to a party acquiring all or part of the equity or assets of YFBHAP or its business operation in the event of a sale, merger, liquidation, dissolution, or sale or transfer of the substantial assets of YFBHAP or any of its business operations. We may also transfer and share such information to our affiliates within the YFBHAP group, in compliance with applicable law.

International transfers of personal information

The third parties, subsidiaries and affiliates to whom your personal information can be disclosed may be located throughout the world; therefore information may be sent to countries having different privacy protection standards than your country of residence.

If you are a resident of the European Economic Area (“EEA”), we may transfer your personal information to countries that have not been found by the European Commission to provide adequate protection. In such cases, we take the measures necessary to ensure that your personal information receives an adequate level of protection. Please note, that the website is not hosted in the EEA. All data that you submit through the website will be stored in servers located in the People’s Republic of China (PRC).

Your Personal Information Rights

Access, Correction and Transmission. You may reasonably access the personal information pertaining to you. You also have the right to request to correct incomplete, inaccurate or outdated personal information. To the extent required by applicable law, you may request the transmission of the personal information you have provided to us to you or another company.

Objection. We respect your right to object to any uses or disclosures of your personal information that are not (i) required by law, (ii) necessary for the fulfillment of a contractual obligation, or (iii) required to meet a legitimate need of YFBHAP (such as general administration disclosures for auditing and reporting purposes or internal investigations, management of network and information systems security, and protection of YFBHAP’s assets). If you do object, we will work with you to find a reasonable accommodation. You may also withdraw your consent at any time in relation to our processing of personal information based on your consent.

Deletion. You may also request the deletion of your personal information, as permitted under applicable law. This applies, for instance, where your information is outdated or the processing is not necessary or is unlawful; where you withdraw your consent to our processing based on such consent; or where we determine we should accommodate an objection you have raised to our processing. In some situations, we may need to retain your personal information pursuant to our legal obligations or for the establishment, exercise or defense of legal claims.

Restriction of processing. You may request that we restrict processing of your personal information while we are processing your request or complaint pertaining to (i) the accuracy of your personal information, (ii) the lawfulness of the processing of your personal information, or (iii) our legitimate interests to process this information. You may also request that we restrict processing of your personal information if you wish to use the personal information for litigation purposes

You may exercise these rights free of charge. However, YFBHAP may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character. In some situations, YFBHAP may refuse to act or may impose limitations on your rights if, for instance, your request is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, interfere with pending or future litigation, or infringe applicable law. In all cases, you have a right to file a complaint with a Data Protection Authority.

Consent and opt-out choices

By providing personal information to us, you understand and agree to the collection, processing, international transfer and use of such information as set forth in this Privacy Notice. Where required by applicable law, we will ask your explicit consent.

Also, in case you have specific reasons that relate to your particular situation, you may object to YFBHAP’s processing of your personal information on the basis of our legitimate interests. In such cases we will investigate your request and notify you as to how we intend to resolve it. You may withdraw any consent previously granted for a specific purpose, free of charge by clicking on relevant website links, following the directions contained in an email or by contacting our Privacy Office as mentioned below.

Please note that if you choose to withdraw your consent, you may not be able to participate in or benefit from the programs, services and initiatives for which you provided consent.

Data retention

We will retain your personal information as long as necessary to achieve the purpose for which it was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect applicable local statute of limitation periods and legal requirements.

How to identify the responsible YFBHAP entity

To identify the YFBHAP entity responsible for the processing of your personal information, you can ask your YFBHAP business contact, consult the list of our locations on YFBHAP public websites or contact our Privacy Office as mentioned below.

How to contact us and exercise your rights

If you would like to communicate with us regarding privacy issues or have questions, comments or complaints, or for the exercise of your rights, please contact our Privacy Office at YFBHAP_INFO@YANFENG.COM .

Modifications to our Privacy Notice

YFBHAP may amend or update this Privacy Notice from time to time. The most current version of this Privacy Notice at any time will be posted online at www.yfbhap.com/en/privacy/. Use of information collected is subject to the Privacy Notice in effect at the time such information is used. If we make material changes in the way we use Personal Information, we will notify you by posting an announcement on the websites prior to the change becoming effective. Your continued use of the YFBHAP websites or YFBHAP’s services following any such change constitutes agreement to be bound by such changes to the Privacy Notice.

This Privacy statement is effective as of October, 2022.