The security of user's personal information (also referred to as “you” in this Policy) is extremely important to the FreeXBuy platform (referred to as "we/FreeXBuy" below). We value your trust and will protect the security and privacy of any personal information you provide to us, and only use it in the scenarios described here. If you have any questions, suggestions, or opinions regarding the Privacy Policy, you can contact us anytime through the FreeXBuy online customer service system or the official FreeXBuyservice account.

Before using the FreeXBuy service, please read and fully understand this Policy carefully, and only use the relevant services if you fully understand and agree to it. By using the FreeXBuy service, you indicate your agreement with this Privacy Policy.

This Privacy Policy will help you understand the following:

1. What is the scope of this Policy?
2. What personal information do we collect from you?
3. What are the purposes of collecting your personal information?
4. How do we share, transfer, and disclose your personal information?
5. How do we use cookies and other similar technologies?
6. What rights do you have regarding your personal information?
7. How do we store your personal information?
8. How do we protect your personal information?
9. How do we protect minors?
10. Policy updates and Others
11. Contact us

Appendix: Definitions

1. What is the scope of this Policy?

This Policy applies to the FreeXBuy platform, as well as to the platform operator offering various internet commodity purchasing agency information and intermediary services related products and services to you through websites, clients, mini-programs, and new forms that emerge with technological development. Apart from the relevant information collection and use activities explained in this Policy, this Policy does not apply to separate scenarios where purchasing service providers or logistics service providers in the FreeXBuy platform independently collect and use your personal information for their own services. In such cases, you should comply with the personal information rules agreed upon by the purchasing service provider or logistics service provider and yourself.

1. What personal information does FreeXBuy collect from you?

We collect your personal information in order to provide and continuously improve our products and services. The following are the types of personal information we collect. You can choose not to provide certain information, but you may not be able to use many FreeXBuy services:

• Information you voluntarily provide: We receive and store any information related to FreeXBuy services that you provide, such as your name, gender, mobile number, email address, address, date of birth, PayPal account, Google account information, bank cards, device ID, device type, photos, etc.
• Automatically collected information: We automatically collect and store certain types of information related to your use of FreeXBuy services, such as your IP address, location, website login time, service order information, payment information, etc.

1. What are the purposes of collecting your personal information?

We use your personal information to operate, provide, develop and improve our products and services offered to customers. These purposes include:

• User qualification and account maintenance. You need to provide us with your name, email address, phone number, date of birth, profile picture, country, language, and gender information. If you wish to use third-party channels for quick login, you need to provide additional third-party account information, such as Apple account information, Google account information. You also allow us to collect and verify the above information so that we can identify your identity according to legal requirements in your location, grant you FreeXBuy user qualifications and membership status. Collecting the above information helps us provide services to you and give you necessary account security protection.
• Third-party platform account binding. If you need to bind your FreeXBuy platform account with a third-party platform account, you need to authorize us to disclose your FreeXBuy platform account information (including name, email address, account ID) to the third-party platform and the owner of the third-party platform account being requested to bind. If the third-party platform account being requested to bind does not belong to you personally, you need to provide the account owner's consent information for your binding application. You are responsible for the results of the binding behavior mentioned above.
• Referral relationship binding. If platform users establish a referral relationship due to using the "invitation code" function of FreeXBuy users, both parties of the referral relationship should allow us to disclose the identity information of users (account ID, email address) to each other, and the referred party should allow us to discloseits service order information on the FreeXBuy platform (order date, amount) to the referrer in order to verify the referrer's rights and interests.
• Obtaining information intermediary services. You need to provide us with your account information, password, bank account information, email address, phone number, and device information so that we can identify your account identity, match purchasing service orders for you, and prompt the purchase order status. If you need to search for third-party e-commerce platform product sales information through functions such as product images and photography, you should provide product images, and you should allow us to call your terminal device's camera and photo permissions.
• Help you complete purchasing agency service orders. You need to provide us with your mobile phone number, email address, tax number, order information, bank account, identity information, and addressso that we can confirm your order status and executability. If you need to entrust a purchasing service provider to communicate with the seller about the purchasing specifications or characteristics of specific products, you need to provide necessary personal information (such as when using the "Help Me Select" function to purchase clothing products, you need to disclose your personal physiological information such as height, weight, chest circumference, etc. to us, as prompted by the FreeXBuy platform). All of the above information is necessary for purchasing service providers and logistics service providers to provide services. Otherwise, your order may be deemed not to have been achieved, ineffective, or unenforceable.
• Customer service and dispute resolution. When you contact us or file a dispute application for participation in purchasing service orders, in order to ensure the security of your account and system, we need you to provide necessary personal information to verify your membership identity. In order to facilitate contact with you, help you solve problems as soon as possible, or record the processing plan and results of related issues, we may save your communication with us, communication/call records, and relevant content (including account information, order information, other information you provide to prove relevant facts, or contact information you leave behind), and you should allow us to use your terminal device's Camera and Photo permissions. If you consult, complain or provide suggestions regarding specific orders, we will use your account information and order information. In order to provide services and improve service quality reasonably, we may also use your other information, including relevant information you provide when contacting customer service.
• Help you use promotion functions. If you use the promotional function of the FreeXBuy platform and need to extract promotional income, you need to provide us with your name, bank account, and bank information. If you accept the promotional services of FreeXBuy platform users, you should allow us to provide your name and purchase order amount information to that user.
• Fault diagnosis and service improvement. We may collect your service log information such as search, browse, and view records on the FreeXBuy platform, product information under your purchasing service orders, your payment time, amount, and channel information, so that we can analyze, evaluate, and repair the reliability, security, and stability of the system service.
• Recommendation and personalization. We may collectyour service log information such as search and browsing records on the FreeXBuy platform, purchasing service order information, and your evaluation information, so that we can evaluate your preferences and improve your personalized experience.
• Compliance with legal obligations. In certain cases, we will collect and use your personal information to comply with the law. For example, to comply with legal requirements regarding transaction security, intellectual property protection, anti-money laundering, and anti-commercial bribery, we will obtainyour purchase order achievement and execution information from purchasing service providers and verify your account information with payment institutions.
• Sending information to you. You should provide us with, or authorize us to use, the address, email, and phone number informationyou provide independently, so that the FreeXBuy platform can send you information or legal documents (such as user agreements, platform rules, platform activities, etc.) regarding information services, platform operations, and the execution of orders with purchasing service providers.
• We may need to collect and useyour address, contact phone number, and email address for FreeXBuy platform advertising to you and promote services that you may be interested in.
• Risk control. You agree that we have the right to require you to provide us with the following personal information to ensure the security of your transaction or payment behavior:product information (product name, category), shipping information (recipient name, recipient phone number, recipient email, shipping address), device information (model, device fingerprint ID), the bank card information you bound for payment (credit card holder name, bank card number, bank card expiration date, bank card CVV code, bank card bills receiving address). The above personal information will be provided to payment institutions or third-party organizations upon their request.. We may also use your personal information to prevent and detect fraud and abuse behavior to protect your and our customers' and FreeXBuy's security.

1. How do we share, transfer, and disclose your personal information?

Your information is an important part of our business. Unless otherwise stated in this Policy, we will not transfer or sell your personal information to any third party.

• We may share your personal information with others according to the following rules:

Sharing with our affiliates: We may provide your personal identity information, order information, browsing and search records, and evaluation information to the affiliates of FreeXBuy's operator for analysis and processing of personal information, in order to optimize our service content and improve our service efficiency.

Submission to third-party service providers: You agree that in order to facilitate the realization of your transactions and ensure transaction security and risk prevention, we may provide your order information, payment information, and commodity logistics information to purchasing service providers, logistics service providers, payment institutions, and others who provide services to you.

Entrusting others to collect and process: You agree that we may entrust others to collect, store, and process your personal identity information, platform account information, and bank account information in order to ensure the security of your account and comply with regulatory requirements. At that time, we will sign a contract with the entrusted party and require them to fulfill their obligations of data security and protection. We will also not violate the laws of your location by requesting the entrusted party to transfer the personal information stored locally to us.

SDK cooperation: In order to ensure the stable operation and functional implementation of the FreeXBuy platform and to enable you to use and enjoy more services and features, our application may embed SDKs or similar applications authorized by cooperation partners. We will conduct strict security tests on the application program interface (API) and SDKs that the authorized partners obtain relevant information from, and we will agree with the authorized partners on strict data protection measures to ensure that they handle personal information in accordance with this Policy and any other relevant confidentiality and security measures, except when the authorized partners obtain your separate consent.

For the sharing of your personal information and the explanation of SDKs, please refer to the explanation at the end of this Policy.

• We will transfer your personal information to others according to the following rules:

If we need to transfer personal information due to merger, division, dissolution, bankruptcy declaration, or business transfer, we will inform you of the name or name and contact information of the receiving party. The receiving party will continue to fulfill the obligations of this Policy and other legal obligations. If the receiving party changes the original processing purpose or processing method, we will obtain your consent again.

• We will only disclose your personal information under the following circumstances:
• Based on your active choice and separate consent, we may publicly disclose your personal information.
• If we confirm that you have violated laws, regulations, or relevant agreements and rules of the FreeXBuy platform, or in order to protect the personal and property safety of platform users or the public from infringement, we may disclose information about you, including related violations and measures taken by the platform.
• In the event of our cessation of operation, we will follow the following rules:

If we stop operating the FreeXBuy platform or its products/services, we will promptly cease collecting your personal information. We will notify you individually or send a notice in the form of an announcement to inform you of the cessation of operation, and we will delete or anonymize the personal information we hold that is related to the platform or closed products/services.

1. How do we use cookies and other similar technologies?

We use cookies, pixels, and other technologies (collectively referred to as "cookies") to identify your browser or device. Cookies and similar device identification technologies are commonly used in the internet. When you use our services, we may use these technologies to send one or more cookies or anonymous identifiers to your device to collect, identify, and store information about your access and use of our product. We promise not to use cookies for any purposes other than those described in this Privacy Policy. We primarily use cookies to ensure the security and efficient operation of our products and services. They allow us to verify the security status of your account and transactions, and troubleshoot any related anomalies such as crashes or delays. Additionally, we may use cookies to show you information or features that you may be interested in and to optimize your advertisement preferences. You can manage cookies through your browser settings.

The "Help" function on most browsers will tell you how to prevent the browser from accepting new cookies, how to have the browser notify you when you receive new cookies, or how to block cookies altogether. If you block all cookies on your browser, neither we nor third parties will transmit cookies to your browser. However, if you do this, you may need to manually adjust certain preferences each time you visit the site, and some features and services may not work properly.

1. What rights do you have regarding your personal information?

(1) You can access and correct your information by using the following methods or contacting customer service:

Log in to the FreeXBuy website: https://www.freexbuy.com/person/info/udetail

Log in to the FreeXBuy mobile app: Go to Settings, next to your profile picture.

(2) You can obtain a copy of your information by using the following methods or contacting customer service:

Log in to the FreeXBuy website: https://www.FreeXBuy.com/person/info/udetail

Log in to the FreeXBuy mobile app: Go to Settings, next to your profile picture.

(3) You can request the deletion of your information by taking the following actions:

If any of the following circumstances apply, you can request the deletion of your personal information by either closing your account or contacting customer service:

1. If our handling of personal information violates laws and regulations.
2. If we collect and use your personal information without obtaining your explicit consent.
3. If our handling of personal information seriously violates the agreement with you.
4. If the purpose of our handling has been achieved, cannot be achieved, or is no longer necessary.
5. If we cease to provide products or services, or if the retention period has expired.

If we decide to respond to your deletion request, we will also notify the entities that obtained your personal information from us or the entities that obtained your personal information through our delegation, and request them to delete it promptly (unless otherwise stipulated by laws and regulations or unless these entities have independently obtained your authorization).

After you or we assist you in deleting relevant information, due to applicable laws and security technology limitations, we may not be able to immediately delete the corresponding information from the backup system. We will securely store your personal information and restrict any further processing until the backup can be deleted or anonymized.

(4) Changing the scope of authorization:

You can contact our customer service to change or withdraw your authorization for us to collect and process your personal information. However, please note that for certain types of personal information, such as information necessary for the basic functions of FreeXBuy or information required for us to fulfill legal obligations, we may not be able to respond to your request to change the scope of authorization. After you withdraw your authorization, we will no longer process the corresponding personal information. However, your withdrawal decision will not affect the processing of personal information based on your previous authorization.

(5) Account cancellation:

You can apply to cancel your account by using the following methods:

Log in to the FreeXBuy website: https://www.FreeXBuy.com/person/info/security/secenter

Log in to the FreeXBuy mobile app: Go to Settings.

You can also apply to cancel your account by contacting customer service.

To protect the rights of platform users and the security of orders, the cancellation of your account may require certain conditions, and FreeXBuy will notify you separately. After you voluntarily cancel your account, we will stop providing products or services to you and delete, anonymize, or de-identify your personal information in accordance with applicable laws.

(6) Responding to your requests:

If you need to assert your rights regarding personal information or request FreeXBuy to protect your rights regarding personal information, you can contact customer service or directly contact our dedicated department for personal information protection. We will respond within 15 days.

To ensure the security of your account and personal information, when you make the above requests to us, we may first verify your identity (such as increasing account verification, requesting written requests from you, or other reasonable methods), and then process your request.

We may refuse information that is not directly related to your identity, information requested without reasonable grounds, or requests that require excessive technical means (such as the need to develop new systems or fundamentally change current practices) and may pose risks to the legitimate rights of others or are impractical.

(7) Cases where your authorization is not required:

You understand and agree that in the following circumstances, we may transfer or disclose your personal information without obtaining your authorization:

1. It is necessary for the establishment or performance of a contract at your request: You enter into an agreement with purchasing agents or logistics service providers through FreeXBuy to facilitate transactions, logistics, or other service requirements.
2. It is necessary to fulfill legal duties or obligations: We may share your personal information in accordance with applicable laws and regulations, litigation, necessary dispute resolution, mandatory requirements from administrative and judicial departments, and other legal obligations.
3. It is necessary to protect the public interest, property safety, to prevent harm to you or other FreeXBuy users, FreeXBuy, FreeXBuy's affiliates, or partners within the reasonable scope permitted by laws and regulations.
4. It is necessary for the implementation of news reporting, public opinion supervision, and other behavior for the public interest within a reasonable scope while processing personal information.
5. It is necessary to process personal information that you have voluntarily made public or other personal information that has already been lawfully made public (such as personal information lawfully disclosed through channels such as news reporting or government information disclosure).
6. Other circumstances stipulated by laws and regulations.

1. How do we store your personal information?

You agree that we will store your personal information in secure locations in accordance with applicable legal requirements. We will only transfer your personal information overseas for the purpose of fulfilling our contractual obligations to you or for other legitimate processing reasons. For example, if it is necessary to transfer your information overseas to facilitate services with overseas purchasing agents, logistics service providers, or other third-party partners. In such cases, we will assess and make our best efforts, as required by the laws of your jurisdiction, to ensure that your personal information receives an adequate level of protection comparable to that in your jurisdiction.

You acknowledge and agree that if you cancel your account with FreeXBuy, the maximum storage period for the personal information under your account is three years. You may make copies or download your information within the storage period as explained in this Policy. If the storage period is exceeded, FreeXBuy may delete, anonymize, or de-identify the information.

1. How do we protect your personal information?

To ensure the security of your personal information, we have established a comprehensive data security management system based on the lifecycle of data, including organizational management, security policies, and operational procedures, to strengthen the protection of data security. We have dedicated departments responsible for the protection of personal information to handle security matters professionally.

We have implemented security measures that comply with industry standards and are reasonably feasible. These measures include email verification codes, two-factor authentication (2FA), and encrypted storage of passwords, among others, to protect your information and prevent unauthorized access, disclosure, use, modification, damage, or loss of personal information. In the event that our physical, technical, or managerial protective measures are compromised, resulting in unauthorized access, disclosure, tampering, or destruction of information, we will promptly initiate emergency response plans and take reasonable and necessary measures to minimize any impact on your personal information.

1. How do we protect minors?

FreeXBuy only provides services to individuals with full capacity for civil conduct. If you are a minor, you should ensure that your account registration and service usage have obtained the consent of your guardian.

You acknowledge and agree that FreeXBuy can only identify whether you are a minor based on the information you provide. FreeXBuy is not obliged or able to verify the authenticity of the information you provide. If you provide false information that leads to incorrect identification by FreeXBuy, you shall bear the adverse consequences yourself.

For guardians of minor users, you agree to abide by the following rules and jointly protect the personal information of minors:

(1) We will strictly fulfill the obligations and responsibilities for protecting the personal information of minors as stipulated by applicable laws and regulations, and collect and use the personal information of minors after obtaining the consent of the guardian. We will not collect personal information of minors unrelated to FreeXBuy services, nor will we violate our agreement with you to collect and use the personal information of minors.

During the process of minors registering and using FreeXBuy services, we will collect and use the personal information of minors in accordance with the "How we collect and use personal information" section of this Policy. This information is necessary to ensure the normal operation of FreeXBuy services, and you must authorize us to collect and use it. If you refuse to provide it, the user will not be able to use FreeXBuy services normally. For business needs, if it is necessary to collect and use the personal information of minors beyond the agreed purposes and scope mentioned above, we will seek your explicit consent again.

Please note to the guardians of minors: The following personal information may include personal sensitive information of both you and the minors under your guardianship, such as names, ID numbers, communication records and content, and all personal information of minors. Please carefully consider whether to provide sensitive personal information of yourself and the minors under your guardianship and use FreeXBuy services; once agreed, the personal sensitive information of you and the minors under your guardianship will be handled in accordance with the purposes and methods described in this Policy.

(2) We will store the collected personal information of minors as necessary and take security measures in accordance with other provisions of this Policy.

(3) Without your consent, we will not transfer the personal information of minors out of the country or engage in commercial use.

(4) When asserting the rights to the personal information of minor users, we have the right to verify your guardian identity. If FreeXBuy suspects the identity, we have the right to refuse your request.

(5) We will strictly protect any personal information that belongs to children as sensitive personal information.

1. Policy updates and Others

FreeXBuy will continuously adjust this Privacy Policy based on changes in applicable laws and regulations, adjustments to business operations, and the need to protect your rights and interests. The updated Privacy Policy will be announced through platform notifications or sent to you via email, and you should regularly check the FreeXBuy platform for recent changes. Unless otherwise specified, our current Privacy Policy applies to all information we have about you and your account.

This Privacy Policy is interpreted in accordance with the laws of the People's Republic of China mainland. You have the right to file a lawsuit with the court having jurisdiction over the defendant's domicile to seek a solution to any dispute regarding this Privacy Policy.

1. Contact Us

You can contact us through the following methods, and we will respond to your requests within 15 days:

(1) If you have any questions, opinions, or suggestions regarding the content of this Policy, you can contact us at [email protected].

Appendix: Definitions

FreeXBuy Platform: Refers to the FreeXBuy website (domain name: www.FreeXBuy.com), and other internet-based manifestations of the FreeXBuy business.

Personal Information: Various information recorded in electronic or other forms that is related to identified or identifiable natural persons, excluding anonymized information.

Sensitive Personal Information: Personal information that, once leaked or unlawfully used, may easily result in infringement upon the personal dignity, or harm to the person's physical or property safety. This includes biometric data, religious beliefs, specific identities, medical and health information, financial accounts, location tracking information, and personal information of individuals under the age of fourteen.

Children: Refers to individuals under the age of fourteen.

Device Information: Includes device identifiers (Android ID, IMEI), advertising identifiers (IDFA, OAID, GAID), application information, device parameters and system information (device type, model, operating system, device sensors, hardware serial number, and other hardware-related information), device network environment information (IP address, WLAN/Wi-Fi information, Bluetooth information, base station information, and other network-related information; WLAN-MAC is only collected after obtaining location permission), carrier information, and broadcast component communication information.

Service Log Information: Includes browsing history, search queries, favorites, items added to the shopping cart, transactions, after-sales service, follow/share information, and published information, as well as IP address, browser type, telecommunications operator, language preference, and access date and time.

De-identification: Refers to the process of processing personal information so that it cannot be identified as relating to specific natural persons without the use of additional information.

Anonymize/anonymization: Refers to the process of processing personal information in a manner that it cannot be identified as relating to specific natural persons and cannot be restored.

Attachment: Information on the sharing and receiving of your personal information by other parties, as well as an explanation of the SDK.

FreeXBuy Applicable Law
We are committed to protecting your personal information and the rights set out in this Policy reflect your rights under applicable laws.

Applicable laws for the purpose of this Policy means: (a) the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2013; (b) General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) until such time as it might cease to apply in the UK; and (c) to the extent applicable, any legislation ratifying or otherwise adopting the GDPR in the UK, and any applicable associated or supplementary data protection laws or regulations.

We recognize that as an international business, some of our customers are resident in jurisdictions other than England and Wales. In certain circumstances, local laws of these jurisdictions, may by way of their application, afford rights to a customer in respect of the personal data that they provide to us. We anticipate that the rights set out in this Policy also provide you with such protection in relation to your personal information. Please do e-mail our Data Protection Officer at [email protected] to discuss any additional questions you may have.