DRAFT, pending lawyer review. Not a binding legal text. Anything in square brackets is a placeholder.
1. Who we are
[COMPANY LEGAL NAME] (“we”) runs the Thorb Hub website. Contact: [PRIVACY CONTACT EMAIL]; address: [REGISTERED ADDRESS].
2. What we collect
- Account data: phone number (Mainland China customers) or email (overseas customers), region, display language.
- Order data: recipient, shipping address, phone number, order contents and amounts, payment status.
- Consent records: which documents you accepted, which version, and when.
- Technical data: the session cookie needed to keep you logged in, and access logs needed for security.
We do not collect your payment account or card details; payments are handled by payment providers such as WeChat Pay and Alipay.
3. How we use it
Only to verify your identity and log you in, to process and deliver orders, for support and after-sales, for bookkeeping and legal retention, and for security. Marketing messages are off by default and are sent only if you turn them on.
4. Sharing and processors
To provide the service we give the minimum necessary data to SMS, email, payment and courier providers. List of providers: [PROVIDER LIST]. We do not sell personal data.
5. Where data is stored, and transfers abroad
Data is stored in [STORAGE LOCATION AND PROVIDER]. [Statement on cross-border transfer and how separate consent is collected: to be confirmed by a lawyer.]
6. Retention
While your account exists. Order data is kept as required by law ([RETENTION PERIOD]). The shipping address in an order snapshot is anonymised 180 days after the order completes.
7. Your rights
You may view, correct or delete your personal data, or delete your account. Contact: [PRIVACY CONTACT EMAIL]. When an account is deleted, its balance is forfeited.
8. Minors
You must be 18 or older, or have a guardian’s consent.
9. Changes
When this policy changes its version number goes up, and we ask you to accept it again the next time you sign up or order.