This Policy describes:
1. Definition and Use of Personal Data
2. Personal Data Disclosure
3. Access & Control Your Personal Data
4. Personal Data Protection and Retention
5. International Transfers of Your Personal Data
6. Updates to This Policy
Personal data means any data that, either on its own or jointly with other data, can be used to identify a natural person. You directly provide us with such data when you use our websites, products, or services, or interact with us by. We may also obtain data by recording how you interact with our websites, products, or services. For example, we may use technologies like cookies or receive use data from software running on your device. As permitted by law, we may also obtain data from public and commercial third-party sources, for example, purchasing statistics from other companies to support our services. The personal data we collect includes name, gender, enterprise name, job position, postal and email addresses, phone number, login information (account and password), photos, and certificate information, etc. We also collect the information you provide to us and the content of messages you send us, such as the query information you provide, or the questions or information you provide for customer service support.
We may use your personal data for the following purposes:
• Creating an account.
• Contacting you with your consent; sending you information about products and services that may interest you; inviting you to participate in Esteel’s activities (including promotional activities), market surveys, or satisfaction surveys; or sending you marketing information. If you do not want to receive these types of information, you can opt out at any time.
• Qualifying and managing suppliers and business partners, and communicating or working with suppliers and business partners.
• Ensuring the security of our products, services and customers or users, executing and improving our loss prevention and anti-fraud programs.
• Complying with and enforcing applicable legal requirements, industry standards and our policies.
Esteel will process your personal data following the requirements of applicable laws on an appropriate legal basis, including:
• Processing your personal data with your consent;
• Processing based on the legitimate interests of Esteel or a third party when we use your personal data to contact you, conduct marketing or market surveys, improve our products and services, execute and improve our loss prevention and anti-fraud programs, and other purposes. Legitimate interests include enabling us to more effectively manage and operate our business and provide our products and services; protecting the security of our businesses, systems, products, services, and customers; internal management; complying with internal policies and processes; and other legitimate interests described in this policy;
• Processing your personal data as necessary to comply with and fulfill legal obligations.
Esteel shares your personal data with other partners, as described in this Policy, when services are provided by partners authorized by Esteel. In addition, as a global company, we may share personal data with Esteel affiliates and subsidiaries. To comply with applicable laws or respond to valid legal procedures, Esteel may also disclose your personal data to law enforcement or other government agencies. If Esteel is involved in a restructuring, merger & acquisition, or a bankruptcy or liquidation lawsuit in a given jurisdiction, your personal data may be disclosed in connection with the transaction. Esteel may also disclose your data when appropriate, for example, to execute Terms and Conditions, when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or when it is in connection with an investigation of suspected or actual illegal activity.
It is your responsibility to ensure that all personal data submitted to Esteel is correct. Esteel is dedicated to maintaining the accuracy and completeness of personal data and keeping the data up-to-date. To the extent required by applicable law, you may (i) have the right to access certain personal data we maintain about you, (ii) request that we update or correct inaccuracies in that data, (iii) object or restrict to our use of your personal data, and (iv) ask us to delete your personal data from our database, in writing to us. Your written request may be required for security. We may decline the request if we have reasonable grounds to believe that the request is a fraudulent, unfeasible or may jeopardize the privacy of others. If allowed by applicable laws, you have the right to withdraw your consent at any time when Esteel processes your personal data based on your consent. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another justification other than your consent.
The security of your personal data is important to us. We use appropriate physical, management, and technical measures to protect your personal data from unauthorized access, disclosure, use, modification, damage, or loss. For example, we use cryptographic technologies for data confidentiality, protection mechanisms to prevent attacks, and access control mechanisms to permit only authorized access to your personal data. We will retain your personal information for no longer than is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law. The data storage period may vary with scenario, product, and service. We will maintain your registration information as long as your account is necessary for service provision. You can choose to deregister your account. After you deregister your account, we will stop providing you with products and services through your account and delete your relevant personal data, provided that deletion is not otherwise stipulated by special legal requirements.
As a global company, your personal data collected by Esteel may be processed or accessed in the country/region where you use our products and services or in other countries/regions where Esteel or its affiliates, subsidiaries, service providers or business partners have a presence. These jurisdictions may have different data protection laws. In such circumstances, Esteel will take measures to ensure that data is processed as required by this Policy and applicable laws, we may use a variety of legal mechanisms where deemed required.