This Privacy Policy explains how Tongshan Gongfanfeng Trading Co., Ltd. collects, uses, stores and protects personal information when retailers, village workshops, suppliers and visitors interact with our trading house and this website. The policy is written and maintained by the developer GongFanPeak on behalf of the Company. We ask every reader to study it carefully, because it describes rights and duties that apply to everyday trading correspondence, orders and deliveries.
1. Who We Are
Tongshan Gongfanfeng Trading Co., Ltd. is a mountain trading house registered in China and operating from Group 225, Banqiao Village, Dafan Town, Tongshan County, Xianning, 437000, China (CN). The Company buys seasonal produce and homeware lines from village workshops and distributes those goods to county retailers. In the course of that trade the Company receives personal information from retailers, workshop makers, suppliers and visitors to this website.
For the purposes of applicable data protection law, the Company is the controller of the personal information described in this policy. The developer GongFanPeak builds and maintains this website and assists the Company in keeping this policy accurate and current. Where this policy refers to we, us or our, it means Tongshan Gongfanfeng Trading Co., Ltd. acting through its trading desk and its website operations.
The Company takes its responsibilities seriously because trust is the foundation of trade in a mountain community. A retailer shares a shop address, a phone number and ordering habits, and a workshop shares the details of a small family business. We treat that information as something entrusted to us rather than something extracted from a visitor, and this policy explains how that trust is honored in practice.
2. Scope of This Policy
This policy applies to personal information collected through this website and through the ordinary commercial correspondence of the Company, including telephone calls, email messages, written orders, delivery notes and account records. It covers information about retailers, prospective retailers, workshop makers, suppliers, delivery contacts and general visitors to this website.
This policy does not apply to third party websites that may be reached from links on our pages. If a visitor follows a link to another organization, that organization applies its own privacy practices and the Company has no control over them. We encourage every reader to review the privacy notice of any site before providing personal information there.
This policy also does not cover information that has been fully anonymized so that it can no longer be connected to any individual. Such anonymous information may be used for planning routes, understanding seasonal demand and improving the services of the trading house, because it no longer identifies anyone.
3. Information We Collect
The Company collects several categories of personal information, always limited to what is genuinely needed for the trade. The main categories are set out below.
Contact and identity information
This includes names, business names, postal addresses, email addresses and telephone numbers. It is the minimum needed to open a trading account, confirm an order, arrange a delivery and answer a question. The Company also records the preferred language and the best time to call when a retailer or maker provides that detail.
Order and account information
This includes the goods ordered, grades requested, quantities, prices agreed, delivery windows, delivery addresses, payment arrangements and the running notes kept against a trading account. Order information is essential because the trading house promises to deliver goods that were sorted, weighed and recorded before they left the yard.
Correspondence information
This includes the content of email messages, written notes, call summaries and messages sent through the contact form on this website. The Company keeps correspondence so that a described order can be fulfilled and so that any later question can be answered against the original conversation.
Website technical information
When a visitor loads a page, the hosting service may record standard technical information such as the internet protocol address, browser type, device type, referring page and the time of the visit. This information is used to keep the website working, to protect it from abuse and to understand in general terms how the pages are used.
Delivery and route information
For retailers who receive deliveries, the Company records the delivery address, the route loop, the agreed window and the name of the handler who serves the shop. This information is used to plan efficient routes and to make sure the right person arrives at the right door.
4. How We Collect Information
The Company collects personal information in a small number of clearly defined ways. Most information arrives directly from the person concerned, either because a retailer places an order or because a maker offers goods for sale. A retailer may provide details by telephone, by email, in writing at the trading rooms or through the contact form on this website.
Some information is created by the Company as it conducts its trade. When an order is placed, the trading desk records the goods, the grades, the agreed price and the delivery window against the account. When a delivery is completed, the handler notes the time and any adjustment. These records are made by our own staff and form part of the account history.
A limited amount of technical information is collected automatically when this website is used. This happens through the ordinary operation of the hosting service and is described in more detail in the section on cookies and similar technologies. The Company does not buy personal information from data brokers, and it does not gather personal information from social media profiles for marketing purposes.
5. Why We Use Information
The Company uses personal information only for purposes that are directly connected to its trade. Each purpose below is tied to a real activity of the trading house rather than to speculation about future uses.
- To open, maintain and close trading accounts for county retailers.
- To take orders, confirm grades and quantities and agree a fair price.
- To sort, pack, weigh and record goods before a load leaves the yard.
- To plan delivery routes, set windows and assign handlers to shops.
- To answer questions, resolve shortfalls and settle account disputes.
- To send the market-day list and other operational notices to active retailers.
- To keep the website secure, available and working correctly.
- To meet accounting, tax and record-keeping duties that apply to the Company.
- To improve the services of the house by studying seasonal demand in anonymous form.
The Company does not use personal information for automated decision making that produces legal or similarly significant effects. Decisions about credit, routes and account terms are made by people who know the shop and the trade, and any doubtful case is reviewed by a member of the trading desk before it is acted upon.
6. Legal Bases for Processing
Where the law requires a legal basis for processing personal information, the Company relies on one or more of the following grounds. The performance of a contract covers the processing needed to take and deliver an order, because a retailer and the Company enter into a trading agreement each time goods are ordered. Compliance with a legal obligation covers record keeping, tax reporting and response to lawful requests.
Legitimate interests cover the operation of the trading house in a reasonable and expected manner, including route planning, account administration, fraud prevention, website security and the improvement of services. When the Company relies on legitimate interests it weighs those interests against the rights of the individual and limits the processing to what is necessary.
Consent is relied upon where a person has clearly agreed to receive optional communications, such as a general newsletter or a non-operational update. Consent may be withdrawn at any time by contacting the trading desk, and withdrawal does not affect the lawfulness of processing that took place before the withdrawal.
7. Trading Accounts and Retail Records
A trading account is the working heart of the relationship between the Company and a county retailer. The account records what was ordered, what was sorted, what was delivered and what was adjusted. It also holds the delivery address, the route loop, the preferred window and the name of the handler who serves the shop. This information is used to fulfill the order and to answer any question about it.
Account records are kept accurate because a wrong count or a wrong address wastes a market day. Retailers are encouraged to tell the trading desk when their details change, including a new shop address, a new telephone number or a new contact person. The Company corrects the ledger as soon as it is told, and it confirms the correction back to the retailer so that both sides hold the same record.
Access to trading accounts is limited to staff who need it to serve the shop. A handler sees the shops on the route being walked; the trading desk sees the accounts it is actively managing; accounting staff see the financial entries they must reconcile. No member of staff may browse an account out of curiosity, and the Company treats any such misuse as a disciplinary matter.
10. Delivery and Route Partners
Deliveries to county retailers are carried out by handlers and route partners who walk or drive an agreed loop. These partners receive the delivery address, the agreed window, the name of the contact at the shop and the list of crates to be handed over. They do not receive the wider account history, and they are instructed to use the information only for the delivery in question.
The Company expects every route partner to treat a shop address and a contact name as confidential business information. Handlers are told not to photograph delivery notes, not to share customer lists and not to use a shop address for any purpose after the route is complete. Where a partner works with the Company regularly, these expectations are written into the working arrangement between the parties.
A retailer who prefers a particular delivery arrangement may tell the trading desk. The Company will record the preference and pass on only what the handler needs to honor it. For example, a shop that wants deliveries left with a named neighbor can have that note entered against the account so that the handler sees it on the route sheet.
11. Workshop and Supplier Data
The Company buys from village workshops and small suppliers, and those relationships also involve personal information. The Company records the name of the maker, the location of the bench or yard, the goods the maker produces, the price agreed and the weighing notes from each sourcing run. This information is needed to pay the maker correctly and to plan future collections.
Workshop data is treated with the same care as retailer data. The Company does not disclose which workshop supplied which lot to any unrelated party, because that knowledge is the commercial asset of the maker. When a retailer asks about the origin of goods, the Company may describe the village and the general method of production without revealing the private details of a small family business.
A maker may ask the Company to correct or remove a contact detail at any time. The Company will make the change in the ledger and confirm it back. Where a maker stops supplying the house, the Company keeps only the records it must keep for accounting and legal purposes and removes the rest in the ordinary course of its record management.
12. How Long We Keep Information
The Company keeps personal information only for as long as it is needed for the purpose for which it was collected. Trading account records are kept for the period required by accounting and tax law, because the Company must be able to show the financial history of its trade. After that period the records are securely deleted or anonymized.
Correspondence that relates to a completed order is kept while the account is active and for a reasonable period afterwards, so that a later question can be answered. General enquiries that do not lead to a trading relationship are kept only for a short period and are then removed. Technical website information is kept for the short period needed to secure and operate the site.
When the retention period ends, the Company removes the information by secure means. Paper records are shredded, and electronic records are deleted from active systems and from backups as those backups rotate. The Company does not keep personal information indefinitely simply because storage is cheap, and it reviews its retention practice regularly.
13. How We Protect Information
The Company uses reasonable technical and organizational measures to protect personal information against loss, misuse and unauthorized access. These measures include limiting access to staff who need it for their work, keeping paper ledgers in a controlled area of the trading rooms, using password protection on electronic systems, and applying the same care to backups as to live records.
Staff receive guidance on handling personal information and are told to report any suspected incident at once. The Company investigates every report, takes steps to contain the problem, corrects the cause and notifies affected individuals and authorities where the law requires. The Company does not hide a security incident in the hope that it will go unnoticed.
No system can be guaranteed perfectly secure, and the Company does not pretend otherwise. It asks visitors, retailers and makers to help by keeping their own credentials private, by telling the desk promptly if a message looks unusual, and by contacting the Company through the known email address and telephone number rather than through an unexpected link or attachment.
14. International Transfers
The Company operates from China, and its records are kept primarily at its trading rooms in Banqiao Village. Some technical providers, such as the hosting service for this website, may store limited technical information on servers located in other countries. Where information is transferred across a border, the Company takes steps to ensure that it remains protected to a standard consistent with this policy.
These steps may include using providers that offer appropriate safeguards, limiting the information transferred to what the provider actually needs, and requiring the provider to protect the information and to use it only for the service supplied. The Company does not transfer account records across borders for marketing purposes, and it does not sell data across borders under any circumstances.
An individual who wishes to know more about where their information is held may contact the trading desk using the details in the final section of this policy. The Company will explain the general location of its records and the safeguards that apply to any transfer.
15. Your Rights and Choices
Individuals have rights in relation to the personal information that the Company holds about them. The Company honors these rights and makes it easy to exercise them. The main rights are described below, and a request may be made by email, by telephone or in writing at the trading rooms.
- The right to be informed about how personal information is used, which this policy provides.
- The right of access to a copy of the personal information the Company holds.
- The right to correct information that is inaccurate or incomplete.
- The right to request deletion where the information is no longer needed or was unlawfully used.
- The right to restrict or object to certain processing, including direct marketing.
- The right to withdraw consent where consent was the basis for processing.
- The right to complain to a supervisory authority about the handling of personal information.
The Company answers a rights request within a reasonable period and usually within thirty days. If a request is complex or a large amount of information is involved, the Company will explain the reason for any delay and will keep the individual informed. The Company does not charge for a single reasonable request, and it does not discriminate against anyone who exercises a right.
16. Marketing and Market-Day Lists
The market-day list is an operational notice sent to active retailers so that they can plan shelf space and orders. It is part of the trading service rather than an advertising campaign, and it is sent to shops that have a trading relationship with the Company. A retailer may ask to stop receiving the list at any time, and the trading desk will remove the address from the distribution while keeping the account in good order.
Any optional promotional message that is not part of the trading service is sent only where a person has agreed to receive it. Every such message makes it easy to withdraw consent, and the Company acts on a withdrawal promptly. The Company does not share a retailer email address with another organization for that organization own marketing.
The Company believes that a mountain trading house earns its name by being useful rather than by being loud. For that reason the amount of promotional communication is deliberately small, and the list that goes out every second morning remains a working document written for the shop floor rather than an advertisement.
17. Privacy for Children
This website and the services of the Company are intended for adult retailers, workshop makers, suppliers and business visitors. The Company does not knowingly collect personal information from children. If the Company learns that it has collected information from a child without the appropriate involvement of a parent or guardian, it will delete that information promptly.
A parent or guardian who believes that a child has provided personal information to the Company should contact the trading desk using the details at the end of this policy. The Company will investigate the matter, remove the information where it is appropriate to do so, and confirm the outcome to the person who raised it.
The Company encourages families to talk about privacy and to treat contact details as things to be shared carefully. This policy reflects that outlook, and the Company applies it to online enquiries, orders and any other interaction with the trading house.
18. Changes to This Policy
The Company may update this policy from time to time to reflect changes in its trade, its website or the law. When a change is made, the Company updates the date of the policy and, where the change is significant, provides a clear notice on the website or in its communications. The current version always governs the handling of personal information.
The Company encourages readers to review this policy occasionally so that they remain aware of how their information is protected. Continued use of this website or continued trading with the Company after a change indicates acceptance of the updated policy, to the extent that such acceptance is permitted by law.
If a change is material, the Company will take reasonable steps to bring it to the attention of active retailers and makers. The Company will not apply a new purpose to information that was collected under an earlier version of this policy without a lawful basis for doing so.
19. How to Contact Us
Any question, request or complaint about this policy or about the handling of personal information may be directed to the trading desk of Tongshan Gongfanfeng Trading Co., Ltd. Write to Group 225, Banqiao Village, Dafan Town, Tongshan County, Xianning, 437000, China (CN), send an email to hotline@gongfanpeak.buzz, or telephone +16416306796 during business hours.
The Company takes every concern seriously and will acknowledge a message within one working day. Where a matter cannot be resolved immediately, the Company will explain what is being done and when a further answer may be expected. The Company would rather hear about a problem early than learn about it after trust has been lost.
If a person is not satisfied with the response of the Company, that person may raise the matter with the relevant data protection authority. The Company will cooperate fully with a supervisory authority and will provide the information that the authority needs to review the matter fairly.