Privacy Policy

Sinorbis is committed to protecting your privacy. This Privacy Policy applies to the information and data collected by Sinorbis when you use our website (accessible at https://www.sinorbis.com/), interact with us through our other channels (for example, by communicating with us or attending one of our events) and when you use our Subscription Services (as defined below).

By using our website or our Subscription Services, you acknowledge that you have reviewed the terms of this Privacy Policy and agree that we may collect, use, store, provide, transfer, process, disclose and delete your personal data in accordance with this Privacy Policy. If you do not agree to these terms, you may choose not to provide any personal data and not to use our website or Subscription Services.

In this Privacy Policy:

• references to "we", "our" or "us" are to Sinorbis Australia Pty Limited ACN 605 350 123; .
• references to "you", "your" and "yours" are to our customers and third parties;.
• “Personal Data” means any information or an opinion about an identified or identifiable natural person ("data subject"); and.
• "Subscription Services" means the suite of services and tools for website design and creation, search engine optimization and digital marketing, CRM, content management, web analytics and conversion, landing page creation and management, automated web optimisation, and such other services and tools that you have subscribed to by a subscription services order. .

We may make changes to this Privacy Policy from time to time in accordance with legislative changes and business requirements. If a revision meaningfully reduces your rights, we will notify you by email. The most current version of the Privacy Policy will be posted on the Sinorbis website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

1. Who are we?

Sinorbis is an Australian based software company. Sinorbis' head office is located in Sydney, Australia, and we have offices in Shanghai, China.

Sinorbis is committed to protecting the privacy of its customers’ personal data and to the responsible use of personal data in accordance with the relevant laws which govern our use and handling of such information. We have developed this Privacy Policy to explain how we collect, store, use, process, disclose, transmit, provide and delete your personal data.

This Privacy Policy sets out information on:

• the general categories of personal data we collect;.
• why we collect an individual's personal data;.
• how it will be used and who it will be disclosed to; .
• the legal basis of our processing of personal data; .
• your rights in relation to the personal data we collect; and.
• your rights and interests that will be affected if you elect not to provide your personal data..

2. What type of personal data do we collect?

Sinorbis will collect, store, use, process and disclose personal data only in a manner permitted by law. The personal data that we may collect and hold in connection with your use of our website and Subscription Services may include your:

• name;.
• identification number;.
• date of birth;.
• gender;.
• postal and email address;.
• phone number;.
• contact preferences;.
• payment data, including credit and debit information;.
• demographic information;.
• the location from which you have come to the website and the pages you have visited; and.
• technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system. When you apply for and we facilitate the provision of a specific product or service, we may also collect information from you related to that product or service..

3. Job Applicants

If you are applying for employment with Sinorbis, we may collect and process information about you such as your employment history, qualifications, residency status, background check and other information required as part of the recruitment process. Where reasonably necessary for the position for which you apply, we may also collect sensitive information about you such as your health or medical information, racial or ethnic origin and criminal convictions (if any). You acknowledge and consent to Sinorbis' collection, storage, use, processing and disclosure of any such information for the purpose of assessing your employment application.

Sinorbis generally collects personal data as part of its recruitment process for the purpose of facilitating safe recruitment and determining suitability for the role. If you fail to provide certain information when requested, we may not be able to enter into an employment contract with you (for example if incorrect references are provided), or we may be prevented from complying with our legal obligations (such as evidence of right to work).

Throughout your job application process, Sinorbis will only use your personal information for the purposes for which it was collected, unless we reasonably consider that we need to use it for a secondary purpose, and that purpose is related, or in the case of sensitive information - directly related, to the original purpose. If we need to use your personal information for an unrelated secondary purpose, we will notify you and seek your consent.

The period for which we retain your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned, and the purposes for which it is processed. The personal information of unsuccessful job applicants will be deleted or destroyed within 15 business days after the application is rejected.

If the information is no longer required by us for any purpose for which it was collected, and is no longer required by law to be retained by us, we will destroy or de-identify the information.

4. How does Sinorbis collect your personal data?

Sinorbis may collect personal data from the individual concerned and from third parties.

Sinorbis may collect your personal data in various ways, such as when you interact with us via our website or use the Subscription Services, as further described below.

(a) When you visit our website

We collect personal information from you when you submit web forms or interact with our website, for example when you subscribe to a Sinorbis blog, sign up for a webinar, or request customer support. We may ask for your email address, first and last name, job title, and other similar information. You are free to explore our website without providing any personal data about yourself.

(b) Event information

When you register for a Sinorbis event, we collect personal data such as your name, address, phone number and email address. We use this information to communicate with you and facilitate your registration. We may also share your registration data with service providers of the Sinorbis event in order to provide event information and improve your experience at the current or future Sinorbis events.

(c) Account and user information

We collect personal information when you sign-up for a Sinorbis account, create or modify user information, set preferences, or provide other related information to access or use our Subscription Service.

(d) Payment information

We collect payment and billing information when you register for and/or purchase products or services, such as credit card and bank account information, a billing address and a billing contact for your Sinorbis account. If you give us payment information, we will use it solely as authorised by you and in accordance with this Privacy Policy. We use secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.

(e) Customer testimonials and surveys

We post customer testimonials, surveys and comments on our websites, which may contain personal information. We obtain each customer’s consent via email or through other agreements, prior to posting the customer’s name, testimonial or survey response.

(f) Log data

When you visit our website or use the Subscription Services, we collect information about your computer hardware and software including your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information.

(g) Usage data

We collect usage data when you, or users of your Sinorbis account, interact with the Subscription Services. Usage data includes metrics and information regarding your use and interaction with the Subscription Services, such as the product features you use the most and how often certain features are triggered in your account. We engage third-party providers to collect usage data, and we only share such data with these providers in an unidentified manner.

(h) Third party integrations

You may connect third party integrations to your Sinorbis account which may ask for certain permissions to access data or send information to your Sinorbis account or to your websites or mobile sites. It is your responsibility to review any third party integrations you authorise. Any permission(s) granted by you, grants these third parties access to your data, which may include (but is not limited to) granting third-party applications access to view, store, and modify your Sinorbis account data. We are not responsible for the practices of third party integrations, so please carefully review the permissions you grant to third-party applications.

(i) Information we collect from other sources

We may receive information about you or other users of your Sinorbis account from our global network of partners, third party service providers, related companies and from our business and solution partners.

We have processes in place to ensure that our records remain accurate, complete and up to date, including by verifying information with you each time you use our services or from other sources.

If you provide another person's personal data to Sinorbis, you are responsible for telling the other person that you have provided their personal data to Sinorbis. You must also refer them to this Privacy Policy. By providing another person's personal data to Sinorbis, you represent and guarantee that you are legally authorised to provide such personal data, and Sinorbis will not be responsible for verifying any such authorisation.

Can I choose to remain anonymous?

You can always choose to deal with us anonymously or by using a pseudonym. You may also choose not to give us your personal data. However, please note that if you choose not to provide us with your personal data or to deal with us anonymously, this may affect your ability to access or use certain functions of our website, software, products or services, and we may not be able to respond to your queries.

If you wish to remain anonymous when dealing with us via a telephone call, please advise the call operator assisting you. Providing your personal details enables us to provide you with a contact record reference number which allows you, and other authorised persons, to retrieve information about that call at a later date.

5. How your personal data may be used by Sinorbis

We only collect personal data from you with your consent, where we need the personal information to perform a contract with you, or where the collection, use or processing is in our legitimate business interests and is not overridden by your data protection rights.

Sinorbis has a legitimate business interest in operating and improving its business and the services it offers. Sinorbis may only collect, store, use, process and disclose your personal data, and you consent to us doing so, for the following purposes:

• to enable you to access and use our website and Subscription Services;.
• to provide you with the information, products and services that you request from us and carry out the transaction(s) you have authorised (or we may disclose this information to authorised Sinorbis partners to undertake this activity on our behalf); .
• to communicate with you and respond to queries via live chat, email or phone;.
• to operate, protect, improve and optimise the Sinorbis website and Subscription Services to better serve you and other users;.
• to perform analytics, measure the performance and reach of advertising and marketing campaigns, obtain insights about the people and businesses who use our products and services, and conduct research;.
• to enable Sinorbis to respond promptly to your customer service requests;.
• to verify user accounts and sign-ons, and to detect and prevent abuse of our products and services;.
• to send support and administrative messages, reminders, technical notices, updates, security alerts, and related information to you;.
• to provide general statistics regarding use of the website; .
• to trouble-shoot, investigate and help prevent security incidents;.
• for research and development in order to provide Sinorbis' products and services; .
• to send marketing and promotional messages to you and other information that has been requested or which may be of interest to you;.
• to administer rewards, surveys, contests and or other promotional activities or events sponsored or managed by us or our business partners;.
• to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;.
• to investigate, prevent, or take action regarding illegal activities or suspected fraud;.
• to facilitate payment transactions; and.
• to facilitate recruitment by Sinorbis..

6. How we may share your personal data

We may disclose your personal data to third parties for the purposes described in this Privacy Policy and so that they may perform services for us or on our behalf.

Sinorbis may need to disclose your personal data to third parties including:

• related bodies corporate;.
• Sinorbis' suppliers, subcontractors, agents, business partners, professional advisers, debt collection agents, insurers and to their respective related entities and partners;.
• third parties engaged by Sinorbis (who will be bound by confidentiality obligations), in connection with the provision of our products and services, including customer support, to you;.
• payment services providers in relation to financial transactions relating to our services, including processing payments;.
• our sponsors or promoters of any competition that we conduct via our services;.
• anyone to whom our assets or businesses (or any part of them) are acquired or transferred whether by merger, acquisition, bankruptcy or otherwise;.
• specific third parties authorised by you to receive information held by us; and/or.
• other persons, including government agencies, regulatory bodies and law enforcement agencies if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or comply with a law, court order or legal process.We may ask one of these third parties to contact you directly for a specific purpose, and provide us with information collected from you for the purpose of providing the relevant products or services. Such third parties are prohibited from using your personal information except for the relevant purpose, and are required to maintain the confidentiality of your information.Except as provided in this Privacy Policy, Sinorbis will not disclose your personal data to a third party unless you have consented to the disclosure, the disclosure is required or authorised by law, in an emergency or in the event of an investigation of suspected criminal activity such as fraud.When we disclose personal information to third parties, we make all reasonable efforts to ensure that we disclose only relevant information and that it is accurate, complete and up to date and that the third party will comply with relevant privacy laws in relation to that information. .

7. How we transfer personal data

In certain circumstances we may need to transfer your personal data to countries outside the country in which the data was collected (or, in the case of personal data collected within the European Economic Area (“EEA”) or United Kingdom, to countries outside the EEA/United Kingdom) including our offices around the world which are currently located in Australia, and China and to our affiliates for the purposes described in this Privacy Policy. Please see Annexure 1 of this Privacy Policy for a list of Sinorbis' affiliates and their locations.

International transfers of your personal data are protected by appropriate safeguards, such as the standard data protection model clauses adopted by the European Commission or any other supervisory authority, which we will incorporate into our agreements with such transferees of personal data. We also make use of additional safeguards where appropriate, such as commercial industry standard encryption methods, TLS, web application firewall protection and other appropriate contractual and organisational measures.

8. Cloud storage of Personal Data

We may store data on remote servers operated by a cloud service provider, rather than storing it on our own servers. Regardless of the location from which you use our online services or provide information to us, your data may be transferred to and maintained on servers located outside the country in which the data was collected (or, in the case of personal data collected within the EEA, to countries outside the EEA). By providing any data through our online services, you hereby expressly consent to the transferring and processing of your data in such other countries.

Transfers of personal data to servers operated by cloud service providers outside the EEA will be protected by appropriate safeguards, namely the standard data protection clauses adopted by the European Commission or other supervisory authority, which we will incorporate into our agreements with such cloud service providers.

9. How Sinorbis stores and secures your Personal Data

We may hold your personal data in either electronic or hard copy form. Sinorbis has implemented security measures to protect your personal data from misuse, interference and loss, and unauthorised access, modification or disclosure.

The following organisational and technical measures are currently in place:

• Sinorbis uses cloud monitoring services. The Sinorbis website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to the Sinorbis website as safe as possible..
• Your personal data is contained behind secured networks and is only accessible to a limited number of persons duly authorised by Sinorbis who are required to keep the information confidential..
• If you make an online application or undertake a payment transaction using the Sinorbis website, Sinorbis takes additional steps to protect the security of your personal data. Your personal data is encrypted via a Secure Socket Layer (SSL) technology (in your web browser, you can confirm that your session is encrypted by the appearance of a locked padlock symbol at the foot of the browser)..
• All payment transactions are processed through a gateway provider and are not stored or processed on our servers..
• We store your electronic records in secure systems..
• We use trusted contracted service providers (including cloud storage providers)..
• To help protect your privacy and maintain security, we may take steps to verify your identity before we can action your request.Notwithstanding the security measures implemented by Sinorbis, we advise that there are inherent risks in transmitting information across the internet, including the risk that information sent to or from a website may be intercepted, corrupted or modified by third parties. While Sinorbis takes reasonable measures to protect your personal data, we cannot warrant the security of any information transmitted to Sinorbis online and users of our website do so at their own risk.If you have security concerns or wish to provide personal information by other means (e.g. by telephone or paper), you may contact us using the contact details set out at the bottom of this Privacy Policy. .

10. Retention of personal data

We will retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy. In most cases, it is generally not possible for us to specify in advance the exact periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the period required by applicable law.

If your personal data is no longer required by us for the purpose for which it was collected and is no longer required by law to be retained by us, we will destroy or de-identify the information in accordance with applicable law.

11. Use of Cookies and similar technologies

Cookies are small files that a site or its service provider transfers to your computer, TV, mobile phone or other device through your web browser (if you allow) that enables the site's or service provider's system to recognise your browser and remember certain information. We may use cookies or other similar tracking technologies to understand and save user preferences for future visits to our website, for statistical purposes, for marketing purposes and to compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. Cookies help us improve the Sinorbis website and products, optimise your experience, store information about your preferences, speed up your searches and to recognise you when you return to the Sinorbis site.

Data collected through the use of cookies may include personal data (and will therefore be regulated by applicable privacy laws) if the data subject is an identified or identifiable natural person. We will handle any personal data collected by cookies in the same way we handle all other personal data under this Privacy Policy.

You can choose to have your device warn you each time a cookie is being sent, or you can choose to disable cookies by selecting the appropriate setting on your internet browser. If you disable cookies, this may prevent you from using the full functionality of our website. However, you can still place orders.

12. Links to third party sites

The Sinorbis website may contain links to other websites operated by third parties for your convenience and information. Sinorbis is not responsible for those sites or any consequence of a person's use of those sites. In particular, unless expressly stated otherwise, we are not responsible for the privacy policies or practices of the operators of other websites. We encourage individuals to read the privacy policies of those external websites before using them.

13. Your rights

United Kingdom and the EU

If you are a “data subject” under applicable data protection law in the EU or United Kingdom, you will have the following rights in relation to your personal data held by Sinorbis:

Right to Access: you may request confirmation from Sinorbis as to whether we process your personal data, and if so, you may request a copy of that personal data. However, it may not be possible to give you a copy of the information if it was provided anonymously or if it may lead to harm being done to another person.

Right to Rectification: you have the right to request that we rectify or update any personal data that is inaccurate, incomplete or outdated without undue delay.

Right to Erasure: you have the right to request that we erase your personal data without undue delay in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent.

Right to Restriction of Processing: you have the right request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data.

Right to Withdraw Consent: where you have given us consent to process your personal data, you have the right to withdraw your consent.

Right to Data Portability: you have the right to request that we provide a you with a copy of your personal data in a structured, commonly used and machine readable format in certain circumstances.

Australia

If you reside in Australia, you have the 'Right of Access' and the 'Right of Rectification' set out above. If we refuse to provide you with access to your personal data or to update your data in the way you request, we will provide you with written reasons. If we refuse to correct or update your information, you may request that we make a note on your record that you are of the opinion that the information is inaccurate, incomplete, out of date, irrelevant or misleading, as the case may be.

China

If you reside in the PRC, you have the 'Right to Access', 'Right to Restriction of Processing', 'Right to Rectification' and 'Right to Erasure' set out above. You also have a right to request that we explain how we process your personal data.

There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material). You will be notified of any likely costs before your request is processed.

To exercise your rights as set out above, please contact our Privacy Officer using the contact details set out at the bottom of this Privacy Policy.

14. Direct marketing

With your consent and subject to all applicable laws, we may send you direct marketing communications and information about our products and services, including via email, SMS, mail or other forms of communication. You may withdraw your consent or unsubscribe from our marketing communications at any time by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by contacting us via the following link https://www.sinorbis.com/sinorbis-contact.

Your decision to provide your data for marketing purposes is optional and will have no impact on your ability to use our products or benefit from our services.

We do not sell, trade, or otherwise transfer to third parties (other than as set out in this Privacy Policy) your personal data for the purposes of direct marketing. However, we may provide non-personally identifiable user data to third parties for marketing, advertising, or other uses.

Third party services

Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google Inc. (Google). Google Analytics uses cookies to help analyse how users use the website. Google Analytics anonymously tracks how users interact with the website, including where they came from, what they did on the website and whether they completed any transactions on the website.

The information generated by the cookie about your use of the website (including their IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of compiling reports on the website activity and providing other services relating to the website and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate a person's IP address with any other data held by Google.

You can opt out of the collection of information via Google Analytics by downloading the Google Analytics Opt-out browser add on here. Google’s privacy policy can be found here.

Google AdWords

Our website uses Google Analytics and Google AdWords cookies to advertise our products and services through Google AdWords and/or other third-party vendors to persons who have previously accessed our website.

We use Google Ads to improve our presence online, and help measure the effectiveness of our advertising. Google Ads helps Sinorbis to make sure our ads are shown to the right people. It collects data that helps you track conversions from Google ads, optimize ads, build targeted audiences for future ads and remarket to people who have already taken some kind of action on your website.

You can opt out of Google’s use of cookies by visiting the Google Ad Settings here. Alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page here.

15. Specific local requirements - China

If we process personal data within the People' Republic of China ("PRC"), or we process the personal data of a person who is located in the PRC, we will comply with the privacy obligations under the Personal Information Protection Law of the PRC, including:

(a) seeking the voluntary, explicit and informed consent of an individual residing in the PRC to the:

(i) collection and use of the individual’s personal information;

(ii) transfer of the personal information outside the PRC, including to sub-processors located outside the PRC;

(b) notifying the individual about this Privacy Policy;

(c) adopting remedial measures and notifying the relevant departments in the event of a data breach or loss; and

(d) assisting individuals to exercise their data protection rights.

16. Other important information

Sinorbis does not:

• collect any details of the data you are working with when you use our Subscription Services. This data is stored only in the projects or files into which you direct the software to save the data;.
• sell your personal data to third parties; or.
• collect sensitive information from you. Sensitive information includes information that reveals an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation or practices, health information, criminal convictions and genetic or certain biometric information. .

17. Children

Sinorbis considers a child to be anyone under the age of 18. Our website and the Subscription Services are not intended for or targeted at children under 18, and we do not knowingly or intentionally sell products or services for purchase by children or collect personal data from or about children under 18, without the consent of a parent or guardian. If you believe that we have collected personal data about a child, please contact our Privacy Officer on the below contact details. If Sinorbis becomes aware that personal data that has been collected relates to a child without the consent of a parent or guardian, Sinorbis will use reasonable efforts to delete that personal data from its files as soon as possible. If deletion is not possible, Sinorbis will ensure that the personal data is not used further for any purpose.

18. How to contact us

If you have any questions, complaints or concerns about how we handle your personal data, or think that your privacy has been affected, please contact our Privacy Officer using the details below. Please include your name, email address and/or telephone number and clearly describe your question, complaint or concern.

Privacy Officer

Sinorbis Australia Pty Ltd

PO Box A974

Sydney South, NSW, 1235, Australia

Email: privacy@sinorbis.com

Phone: 1300 966 157

Sinorbis China

Suite 2006

Sunny Days City No.425

Yishan Road. Xuhui Dist..

Shanghai, China, 201103

Email: privacy@sinorbis.com

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the relevant data privacy regulator:

For Australian residents, this is the Office of the Australian Information Commissioner;

For UK residents, this is the Information Commissioner’s Office;

For residents of the European Economic Area, this is the data protection authority in your country of residence. A list of EU national data protection authorities can be found on the European Commission website at: https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection_en;

For China resident 20s, this is the Cyberspace Administration of China.