Privacy Policy

Pn29.com Privacy Policy

1. Platform Subject Information

• Official website URL: https://www.pn29.com (hereinafter referred to as “the Platform”)
• Contact information: Consultation email: [email protected]

This Privacy Policy is formulated in accordance with the Federal Trade Commission Act (FTC Act), California Consumer Privacy Act (CCPA, California Civil Code Section 1798.100-1798.199), California Privacy Rights Act (CPRA), and Payment Card Industry Data Security Standard (PCI DSS 4.0). It applies specifically to the collection, storage, use, transmission, and protection of personal data of users in the United States (including U.S. citizens, permanent residents, and natural persons residing in the U.S.) who use the Platform’s cross-border e-commerce services.

2. Scope and Purpose of Personal Data Collection

(1) Types of Collected Personal Data

1. Identity verification data: Full legal name, valid North American delivery address (including recipient name and contact information), real-name verified email, phone number, payment account details (e.g., last four digits of credit card number, PayPal account ID).
2. Transaction-related data: Order number, product details, payment amount, tax records, payment status, logistics tracking information, receipt confirmation.
3. Technical access data: Device model, browser type/version, operating system, IP address, access time, browsing history, shopping cart operations, logistics tracking number association data.
4. User-generated content data: Product reviews, uploaded images/videos, rating information.

(2) Sensitive Personal Data Processing Rules

The Platform does not proactively collect or store sensitive personal data (e.g., social security numbers, passport numbers, driver’s license numbers, health information, complete financial account details). Minimum necessary sensitive data will only be collected with the user’s written consent under the following statutory circumstances:

1. Identity verification required for customs clearance;
2. Data mandated by laws and regulations.

Sensitive data will be protected via AES-256 encryption, access permission classification, and full-process operation log retention, with only compliance officers authorized to access it.

(3) Legal Basis and Core Purposes

Legal Basis:

• User’s written consent (e.g., cross-border data transfer authorization, user-generated content usage permission);
• Fulfillment of service agreements (order processing, logistics, payment settlement);
• Compliance with U.S. federal/state legal requirements (tax filing, customs registration, consumer protection);
• Protection of users’ legitimate rights, platform operations, or public interests (fraud prevention, dispute resolution).

Core Purposes:

• Ensure cross-border e-commerce service delivery (order processing, payment, logistics, customs clearance);
• Provide after-sales service and consultation support;
• Safeguard account security and prevent fraud/theft;
• Optimize services and user experience (enhance interactions, recommend trending products);
• Comply with legal compliance requirements.

(4) Data Collection Methods

1. User-initiated submission: Voluntarily provided via registration forms, order pages, payment processes, reviews, or inquiry forms.
2. Automated collection: Technical data gathered via server logs, cookies, and web beacons (detailed in Article 6).
3. Third-party collection: Necessary data obtained from compliant third parties (logistics/payment service providers, customs agencies) with user’s written consent (detailed in Article 8).

3. Comment Feature Data Processing Rules

When posting product reviews, the Platform collects:

1. Publicly displayed data: Username, comment content, rating, uploaded media, publication time;
2. Backend verification data: Associated account ID and registered email (for authenticity verification only, not disclosed);
3. Linked data: Product ID and order number (if user chooses to link the order).

Users confirm that comments do not infringe third-party rights or contain illegal/non-compliant content. Users grant the Platform a free, non-exclusive, transferable, global license to use comments for legitimate purposes (platform operations, promotions). The Platform reserves the right to delete violating comments and retain relevant records.

4. Media File Upload Data Processing Rules

1. Uploaded product images/videos will be publicly accessible on product pages and comment sections, and may be shared per platform rules.
2. Media files may contain metadata (camera model, shooting time, location). Users must review and delete sensitive metadata before uploading; the Platform is not liable for metadata leakage.
3. Users guarantee uploaded media is original or legally authorized. Users shall bear full liability for intellectual property disputes; the Platform may remove infringing files and pursue liability.

5. Contact Form Data Processing Rules

When submitting inquiries, complaints, or applications via “Contact Us” or the ticket system, the Platform collects:

1. Identity information: Name, registered email, contact number (if provided);
2. Relevant data: Inquiry/complaint details, involved order numbers, product information, application items;
3. Process data: Submission time, handler, progress, feedback.

Data Retention: 24 months from submission date (for processing requests, dispute resolution, compliance checks, service improvement). Post-retention, data will be anonymized or permanently deleted.

6. Cookie Usage Rules

(1) Types and Purposes

(2) Cookie Management

• Users can manage non-essential cookies via browser “Settings-Privacy and Security” (Chrome, Safari, Firefox).
• Consent withdrawal does not affect data collected prior to withdrawal (processed per Article 9 retention rules).

7. Statistical Data Processing Rules

(1) Tools and Data Scope

The Platform uses Google Analytics for Firebase (compliant with CCPA/PCI DSS) to collect anonymized data:

1. Access data: Page views, unique visitors, visit duration, redirection sources;
2. Behavioral data: Browsing history, cart actions, order conversion paths, preferred logistics/payment methods;
3. Device/location data: Device type, browser/OS version, user’s U.S. state (no specific address linkage).

(2) Opt-Out Options

1. Enable browser “Do Not Track” (DNT) plugin to stop data collection;
2. Submit a written withdrawal request via [email protected]; the Platform will complete settings within 15 business days.

(3) Service Provider Compliance

The statistical tool provider complies with U.S. data protection laws (CCPA, FTC Act) and its privacy policy is publicly disclosed. Data will not be used for non-platform-related purposes.

8. Personal Data Sharing Rules

(1) Sharing Scope and Purposes

(2) Compliance Requirements

1. Principle of least necessary: Only minimum data shared for stated purposes;
2. Written consent: Registration/service use constitutes consent for necessary sharing; additional sharing requires separate written consent;
3. Security obligations: Third-party agreements mandate TLS1.3 encryption, secure storage, and prohibition of secondary sharing;
4. Withdrawal right: Submit written request via [email protected]; third parties will cease use within 15 business days (excludes legally required retention).

9. Personal Data Retention Period

Longer retention periods mandated by law shall apply. Users will be notified of extended retention via platform announcements or email.

10. User Rights and Exercise Methods

(1) User Rights (per CCPA/CPRA)

1. Data access: Access collected/stored/used personal data (categories, sources, recipients, retention periods);
2. Data correction: Request correction of inaccurate/incomplete/outdated data;
3. Data erasure: Request deletion (excludes legally required data);
4. Data portability: Request data in structured, machine-readable format for transfer to other compliant platforms;
5. Refuse marketing: Opt out of commercial marketing use (targeted advertising, promotional emails);
6. Right to know: Understand data processing rules, purposes, and legal basis.

(2) Exercise Methods

Submit a written application to [email protected] including name, registered email, and contact information. The Platform will process requests free of charge.