Effective Date: April 21, 2025

1. Data Controller Information

UltraPallet (Qingdao) Industrial Co., Ltd.
Qingdao, China
Email: privacy@ultrapallet.com
Factory Hotline: +86 17685506632

2. B2B Exemption Notice

UltraPallet operates exclusively as a Business-to-Business (B2B) manufacturer and supplier. Under GDPR Article 6(1)(f) (legitimate interests) and recitals related to corporate contact information, our processing of business contact data does not fall under the full scope of GDPR requirements intended for consumer (B2C) data protection. However, we remain committed to protecting all business information with high standards.

3. Information We Collect

We may collect the following business-related information:

• Company name, position, and business contact details (email, phone, WhatsApp)
• Inquiry history, order specifications, and shipping information
• Communication records related to business negotiations
• Website usage data via cookies (see Section 7)

4. Legal Basis for Processing

We process your data based on:

• Legitimate interests (Art. 6(1)(f)): Responding to inquiries, fulfilling orders, and maintaining business relationships.
• Contractual necessity (Art. 6(1)(b)): When processing is required for pre-contractual steps or contract performance.
• Legal obligations (Art. 6(1)(c)): For tax, customs, or regulatory compliance.

5. How We Use Your Information

• Respond to your quotes and technical inquiries
• Process and fulfill orders, including production and shipping
• Send order updates, invoices, and after-sales support
• Improve our products and website experience
• Comply with legal and regulatory requirements

6. Data Retention

We retain business contact and transaction data for as long as necessary to fulfill the purposes outlined in this policy, typically 5 years after the last interaction, unless a longer retention period is required by law (e.g., tax records: 7 years).

7. Cookies & Tracking

Our website uses essential cookies for functionality. We do NOT use marketing or analytics cookies without consent. You may disable cookies via browser settings, but some site features may be affected.

8. Data Sharing & International Transfers

As a China-based manufacturer, your data may be transferred to and processed in China. For business operations, we may share data with:

• Logistics partners (for shipping)
• Payment processors (for transactions)
• Legal/regulatory authorities (when required)

We ensure appropriate safeguards (e.g., Standard Contractual Clauses) for any international transfers.

9. Your Rights Under GDPR

Even under B2B exemption, we respect your rights. You may request:

• Access: Obtain a copy of data we hold about your company
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to legal retention obligations)
• Restriction: Limit how we process your data
• Objection: Object to processing based on legitimate interests
• Portability: Receive your data in a structured format

To exercise any right, contact us at privacy@ultrapallet.com. We will respond within 30 days.

10. Right to Lodge a Complaint

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with your local supervisory authority or with the Chinese data protection authorities.

11. Updates to This Policy

We may update this policy periodically. The "Effective Date" at the top indicates when changes are made. Continued use of our services constitutes acceptance of updates.

12. Contact Us

For any privacy-related questions or to exercise your rights:
📧 privacy@ultrapallet.com
📞 +86 17685506632
📍 Qingdao, China (HQ)