China Privacy Notice (PIPL)

Effective: September 18, 2026
Updated: September 18, 2026
Version: 1.1

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This notice explains how Tanqory Inc. (“Tanqory”, “we”, “us”) collects, uses, discloses, transfers, and protects personal information of individuals subject to the Personal Information Protection Law of the People’s Republic of China (“PIPL”). It is written in a clear, practical format similar to our Shopify-inspired global policies and connects to our Data Processing Addendum. It covers our roles, legal bases, data subject rights, cross-border transfers, security controls, and governance so merchants can communicate confidently with customers in mainland China (excluding Hong Kong, Macao, and Taiwan).

Purpose, scope, and roles

This notice applies when personal information is processed in the context of offering goods or services to, or analyzing the behavior of, individuals in mainland China. It covers merchants and their teams, developers, end customers of stores, users of our apps and services, and visitors to our sites. For merchant customer data, the merchant is the Personal Information Handler and Tanqory is an Entrusted Party (processor) acting under contract. For direct services (e.g., merchant accounts, billing, payments), Tanqory is the Personal Information Handler. If a merchant outside China serves customers in China, this annex still applies. We identify purposes clearly and process only for disclosed, necessary purposes consistent with PIPL Articles 3, 4, and 21.

What we collect and why

Account and contact data (names, business contact details, login credentials, role): Used to create and manage merchant accounts, authenticate users, provide support, and issue invoices. Basis: contract or consent. Source: provided by you.
Transactions and payments: Orders, refunds, disputes, payment tokens passed through payment service providers, and tax/accounting metadata. Basis: contract and legal obligations (e.g., tax, AML). Sources: you, the merchant, authorized payment processors.
Technical and event data (IP, device/browser type, usage logs, necessary cookies/identifiers, language/time zone): Used for security, fraud prevention, performance analytics, and product improvement. Basis: legitimate interests and consent for non-essential cookies/trackers. Data is deleted or de-identified when no longer needed.
Merchant customer data: Order details, fulfillment, customer service, fraud/risk signals. The merchant is the Handler; Tanqory is an Entrusted Party processing only under the merchant’s instructions and contract.
Contextual sensitive information (e.g., identity/financial documents, precise location, biometrics): Collected only when legally necessary or for security/compliance, with separate consent and clear purpose statements. We perform PIPIA (Personal Information Protection Impact Assessment) when required under Articles 28 and 55.
Children’s data (<14 years): Collected only with guardian consent and subject to a separate child privacy approach. We verify age/guardian status appropriately and honor deletion upon request.

We process only what is necessary for stated purposes: delivering services, payments and logistics, support, fraud and abuse prevention, testing and improving features, and consent-based marketing. We do not expand purposes without notice. We share information with subprocessors (hosting, CDN, security, analytics, payments, logistics) under contracts that require technical and organizational safeguards, risk reviews, and purpose limitation. Government or court disclosures occur only when legally required and are limited to what is necessary. A current subprocessor list is available at https://legal.tanqory.com/legal/data-protection/subprocessor-list.

Cross-border transfers under PIPL

CAC Standard Contract: Primary mechanism with encryption in transit and at rest, access controls, logging, and periodic reviews of recipients.
Separate consent: Obtained before transfer, stating recipient name, purpose, data types, rights-exercise channels, and potential impacts (Articles 38–39).
PIPIA: Conducted for cross-border transfers and reviewed periodically or when purposes/recipients change (Article 55 and CAC guidance).
CAC Security Assessment: Performed when thresholds apply (e.g., cumulative transfer of personal information of >100,000 individuals, sensitive data of >10,000 individuals/year, Important Data, or Critical Information Infrastructure Operator). Records are maintained per CAC procedures.
Localization: We support data localization and China-based hosting where feasible to reduce cross-border transfers and comply with sectoral rules (e.g., payments).

Separate consent: Required for sensitive personal information, cross-border transfers, disclosures to unrelated third parties, and marketing where Chinese law mandates. We present distinct opt-in boxes, confirmations, and store evidence (Articles 29, 39).
Explicit opt-in: Required for SMS/email/push marketing, precise location, biometric processing, and heightened identity verification, with clear opt-out controls.
Withdrawal: You may withdraw consent anytime via account settings or provided links. We explain impacts and do not refuse core services unrelated to the withdrawn consent.
Other legal bases: Contract (service delivery/payments), legal obligations (tax/accounting/AML), public health or safety, and other legitimate interests permitted by Article 13 with balancing of individual rights. Consent/withdrawal logs and scope checks prevent processing beyond consented purposes.
Documentation: We maintain consent records, separate consent evidence, and PIPIA outcomes to demonstrate compliance and support audits or regulator requests.

Your rights under PIPL and how to exercise them

Right to know/access/copy: Request a copy or explanation of the data we hold and how we use it.
Correction/deletion: Correct inaccuracies or request deletion when data is no longer necessary or consent is withdrawn, subject to legal exceptions.
Portability: Request transfer where technically feasible and permitted by Article 45.
Object/restrict: Object to automated marketing; request limits on non-essential processing; opt out of profiling for marketing.
Explanations/appeals: Request reasons for significant automated decisions and appeal if dissatisfied.
Post-mortem rights: Close relatives may exercise access, correction, or deletion unless other instructions were recorded.

Submit requests to privacy@tanqory.com or dpo@tanqory.com. We aim to respond within 30 days per PIPL timelines and will notify if more time is needed. Identity verification steps are applied to protect your data, and appeals may be escalated internally before regulator review.

Automated decision-making and AI

We use automated systems for fraud detection, risk scoring, and product recommendations with human review for consequential decisions. You may opt out of automated marketing. We test for fairness and bias, tune thresholds, and log significant automated decisions to support explanations under Article 24. For high-impact cases, we offer human review and correction of outcomes.

Sensitive information and children’s data

We apply heightened controls to biometric, financial, health, belief, religious, precise location, and children’s data: separate consent, necessity assessment, clear purposes, impact notice, PIPIA, and role-based access.
We minimize collection, use encryption and pseudonymization, and log access to reduce risk.
For children under 14, guardian consent and a child-specific privacy approach are required, with easy rights channels and age-appropriate verification.
Guardians may withdraw consent or request deletion; we respond within legal timelines.

Security and retention

We use encryption in transit and at rest, role-based access controls, multi-factor authentication for sensitive access, logging, security testing, and security-by-design for new features. Staff receive privacy and PIPL training. Vendors are reviewed against standards such as SOC 2/ISO 27001, and contracts require equivalent safeguards. Access to sensitive data is logged and reviewed, and least-privilege is enforced. When deletion is triggered, we execute primary deletion, schedule purge from backups on a rolling cycle, and record completion for audit. Data is retained only as necessary for business and legal purposes (e.g., tax/finance) and then deleted or de-identified. Retention schedules are published at https://legal.tanqory.com/legal/data-protection/data-retention-policy, including backup and recovery practices and timelines for purging backup copies.

Incident response

If an incident may significantly impact rights or interests, we assess scope, affected data, likelihood of harm, and mitigation. We notify regulators (e.g., CAC) and affected individuals promptly with incident details, data categories, expected impact, remediation, and recommended risk-reduction steps. Merchants are notified within 24 hours to coordinate communications. If effective measures prevent harm and law permits, individual notice may not be required; we will comply with regulator instructions.

China representative and governance

Where required, we will appoint a China representative and publish contact details under Article 53. We maintain processing records and contact channels to support inspections. Merchants qualifying as Large Handlers should designate a Personal Information Protection Officer, prepare compliance reports, and perform periodic assessments per CAC guidance, and be ready for regulator inquiries.

Updates to this notice

We update this notice when PIPL requirements change, when services evolve, or when regulators issue new guidance. Material changes will be communicated in advance (e.g., dashboard or email) and reflected in the version and date above. Continued use after publication constitutes acceptance. We keep change logs for reference.

Contact

Privacy email: privacy@tanqory.com
Data Protection Officer: dpo@tanqory.com
China channel (inquiries/complaints): china@tanqory.com
Policy site: https://legal.tanqory.com/