TMHShanghai Tianminghai International Trade
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Privacy Policy

Last updated: 2026-05-24

This policy explains how Shanghai Tianminghai International Trade Co., Ltd. (“TMH”, “we”, “us”) collects, uses, stores, and protects personal data when you use www.tianminghai.com (the “Website”) and the customer portal at /portal/.

This policy is written to address the requirements of the EU General Data Protection Regulation (GDPR), the China Personal Information Protection Law (PIPL), and similar frameworks where applicable.

1. Data controller

Name: Shanghai Tianminghai International Trade Co., Ltd. (上海天明海国际贸易有限公司)
Address: No. 536 Laolu Road, Lin-gang Special Area, China (Shanghai) Pilot Free Trade Zone, Shanghai, China
Legal representative: Clemens Neuses

For data protection enquiries, please write to the email above with the subject line “Data privacy request”.

2. What we collect and why

2.1 Inquiry form submissions

When you submit the contact / RFQ form, we receive: your name, company, email address, message content, and metadata automatically attached by the platform (your IP address, country derived from the IP, browser user-agent, timestamp).

PurposeLegal basis (GDPR Art. 6)Retention
Answering your inquiry, preparing a quotation, ongoing commercial communication.6(1)(b) — pre-contractual measures at your request; 6(1)(f) — legitimate business interest.Up to 3 years from last contact, then deletion or anonymization.

2.2 Customer portal sign-in

The portal at /portal/ authenticates users against our internal ERP system. The data exchanged consists of: your registered email, encrypted session identifier (cookie), and the order / quotation / shipment records linked to your customer account.

PurposeLegal basisRetention
Providing the contractual portal service: order tracking, document access.6(1)(b) — performance of a contract.Session cookie: 8 hours. Account records: retained per applicable Chinese commercial-record retention rules (10 years).

2.3 Browser storage (no tracking cookies)

We do not use advertising cookies, analytics cookies, or cross-site tracking. The Website stores one preference in your browser's localStorage (tmh-lang) so it can remember your chosen language between visits. This is technically necessary and exempt from cookie-consent requirements under the EU ePrivacy Directive.

2.4 Server logs

Our hosting provider (see §3) automatically records connection metadata — IP address, requested URL, response code, user-agent, timestamp — for security, abuse prevention, and operational analysis. These logs are retained for 30 days.

3. Categories of recipients

Your data is processed on our behalf by a limited set of third-party service providers acting as data processors. We disclose them by category rather than vendor name, in line with GDPR Art. 13(1)(e):

CategoryPurposeData location / safeguards
Content delivery & web hostingServing the Website, DNS resolution, edge caching, security (DDoS protection, bot mitigation).Global edge network with EEA points of presence used for EEA visitors. EU Standard Contractual Clauses (SCCs) and a Data Processing Agreement (DPA) in force.
Transactional emailDelivery of automated emails generated by the inquiry form to sales@tianminghai.com.Sending infrastructure located in the European Union (Ireland). Encrypted in transit.
ERP / customer-portal backendBackend system that authenticates portal users and stores order, quotation, and shipment data.Hosted in Frankfurt, Germany. Personal data on this layer does not leave the European Economic Area.

Each provider is bound by a written data processing agreement (DPA) and, where applicable, the EU Standard Contractual Clauses for transfers outside the EEA. We do not sell or share your personal data with any third party for marketing purposes. If you require the identity of a specific processor for a verified data-subject request, we will disclose it on request to sales@tianminghai.com.

4. International data transfers

Although TMH is incorporated in the People's Republic of China, the primary infrastructure supporting this Website is located inside the European Economic Area (EEA):

  • Web hosting and content delivery — EEA points of presence used for EEA visitors.
  • Customer portal backend — Frankfurt, Germany.
  • Transactional email — Ireland (EU).

Personal data is only transferred outside the EEA when TMH personnel in China access the data to fulfil your inquiry, contract, or shipment. For this access we rely on the EU Standard Contractual Clauses (SCCs) and equivalent safeguards under PIPL Art. 38 to ensure an adequate level of protection.

5. Your rights

Depending on your jurisdiction, you may have the following rights:

  • Access — request a copy of the personal data we hold about you.
  • Rectification — request that we correct inaccurate or incomplete data.
  • Erasure — request deletion of your data, subject to legal retention obligations.
  • Restriction — request that we limit processing in certain circumstances.
  • Portability — receive your data in a structured, machine-readable format.
  • Objection — object to processing based on our legitimate interests.
  • Withdraw consent — where processing relies on consent, withdraw it at any time without effect on past lawful processing.
  • Complaint — lodge a complaint with your national data protection authority (EU residents) or the Cyberspace Administration of China (中国网信办) for China-related concerns.

To exercise any of these rights, email sales@tianminghai.com. We will respond within 30 days.

6. Security

The Website is served exclusively over HTTPS. Customer-portal credentials are transmitted via authenticated POST and never logged. Session cookies are flagged HttpOnly, Secure, and SameSite=Lax. Resource access is restricted by Content-Security-Policy and other HTTP response headers.

7. Children's data

The Website is a business-to-business platform and is not directed at children under 18. We do not knowingly collect data from children.

8. Changes to this policy

We may update this policy from time to time to reflect changes in our practices or regulatory environment. The “Last updated” date at the top of this page indicates when the most recent change was published. Material changes will be communicated by a notice on the Website.