1. INTRODUCTION

Thank you for choosing to be part of our community at JS LOGISTICS, doing business as Elogistic (“Elogistic”, “Company” “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at DPO@ztn.com.

JS LOGISTICS and Shenzhen YKD Technology Co., Ltd. jointly determine the purpose and method of processing your personal information based on this policy, and jointly assume joint and several liability for the security of your personal information.

When you visit our website https://www.elogistic.com/fr, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

This privacy policy applies to all information collected through our website (such as https://www.elogistic.com/fr), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Services").

This Privacy Statement may be changed over time. This Privacy Statement applies since 9/16/2021. The last modifications to this Privacy Statement have been made on 7/19/2022.

2. WHEN DOES THIS PRIVACY STATEMENT APPLY?

This Privacy Statement is applicable to the processing by the Company of all personal data of its clients and business partners in France. This Privacy Statement does not address the processing of personal data of applicants or employees in the context of their employment relationship with the Company.

3. WHAT PERSONAL INFORMATION DO WE COLLECT?

In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information.

1.1 When you provide your personal information

We collect personal information that you voluntarily provide to us when registering at the Services expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:

Contact details We collect first name, maiden name, last name, nickname, phone numbers, email addresses, business email, and business phone number.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

1.2 When you provide third-party personal information

When you use our services, you provide us with personal information of a third party, including but not limited to (1) the personal information of the legal representative, director or authorized person when you registered an Elogistic account, including but not limited to the name, nationality, address, telephone number, e-mail address, government-issued ID card ; (2) the personal information of the recipients you provide when you use our services, including but not limited to the name, phone number and contact address of the recipients, and (3) When you entrust a third party to pay on your behalf, you provide us with the payment account number or bank information of the third party payer.

You guarantee that before you provide such personal information, you have obtained legal authorization of providing the personal information to us. And you guarantee that the third party also knows and agrees to be bound by this privacy policy. If the third-party damages due to the information you provide, you will be responsible for it. If the third party expressly does not accept this privacy policy, we will delete the relevant information.

1.3 Automatically generated information

Some personal data just gets generated automatically, such as IP address, or MAC address, and browser type.

Our services are intended for business users, the company name and social credit number we collected are not considered as personal data.

4. FOR WHICH PURPOSES AND ON WHAT GROUNDS DO WE PROCESS YOUR PERSONAL DATA?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

(a) To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.

(b) To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

(c) For the conclusion and execution of agreements

When you work together with us as our client, we process your personal data in order to further execute our agreement, send invoices and make payments per our agreement.

For this purpose, we process your contact details such as your address, personal details such as your name and payment information on the basis of the performance of our agreement with you.

(d) For business process execution and internal management

We process your personal data in the performance and organization of our business. This includes general management and management of our assets. The Company also processes your personal data for its internal management. We implement business controls and manage and use client directories. Also, we process your personal data for finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution.

For this purpose, we process your contact details such as your address and email address, personal details such as your name, payment information, payment history, correspondence with us and data generated during the performance of the agreement between you and the Company.

(e) When you interact with the Company (online or offline)

If you get in touch with us, we will use your personal data in order to reply to and answer your question. For this purpose, we process your name, contact details, your correspondence with us your question and all other personal data which are necessary to answer your question.

If you have contacted us, then your data will not be retained longer than necessary for the purposes described above.

(f) To comply with the law

In some cases, we process your personal data to comply with laws and regulations. This could, for example, be the case where tax or business conduct related obligations apply or when required for safety or security purpose. In order to comply with relevant laws and regulations, we may need to disclose your personal data to government institutions or supervisory authorities.

For this, we process your contact details such as your address, personal details such as your name, payment information, residence, payment history and tax details on the basis of the need to comply with a legal obligation that the Company is subject to.

5. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations.

We may process or share data based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

Public interest or official authority requirement: We may disclose your information where necessary for the performance of a task carried out in the public interest, or in the exercise of official authority vested in us.

More specifically, we may need to process your data or share your personal information in the following situations:

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.

Cloud Services Provider: We may store information on servers operated by a cloud service provider to us. Regardless of where you use our online services or provide data to us, the data may be transferred to and maintained on servers located outside the country in which the information was collected.

Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. As a global organization, information we collect may be transferred internationally throughout our worldwide organization. Your personal information may be exchanged with other group companies of Elogistic. We exchange your data for administrative purposes and so that we can have a complete overview of your contacts and contracts within the Company group. Our employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs.

Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies to provide advertisements about goods and services of interest to you.

Law enforcement, regulators and other parties for legal reasons: We may also disclose your personal data to third parties as required by law, or if we reasonably believe that such action is necessary (a) to comply with a subpoena or other legal proceedings, legal actions or government agency requests; (b) when we believe in good faith that a disclosure is necessary to comply with the law and the reasonable requests of law enforcement; (c) to protect and exercise our legal claims, rights and property; (d) to protect your rights, property or personal safety or that of others; and (e) to investigate fraud.

When third parties are given access to your personal data, we will take the required contractual, technical, and organizational measures to ensure that your personal data are only processed to the extent that such processing is necessary.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements), or for the purpose of litigations or investigations which arise in respect of our interactions with you. No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

The Company has taken adequate safeguards to ensure the confidentiality and security of your personal information in compliance with GDPR and the Amended FDPA. We have implemented appropriate technical, physical and organizational measures to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing. We promise that the adopted measures are compliant with the guidance on security issued by the Commission Nationale de l'Informatique et des Libertés (CNIL).

However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

8. HOW LONG ARE YOUR PERSONAL DATA RETAINED?

Your personal data will be removed or made anonymous when your personal data are no longer necessary for the purposes for which these personal data are processed. To determine the appropriate retention period for personal data, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes we process your personal data for, and whether we can achieve those purposes through other means.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may require access, rectification, erasure, restriction, objection rights regarding your account information at any time. In addition, you also have automated decision-making rights and data breach notification rights.

Account Information

If you would at any time like to review or change the information in your account, terminate your account, request to receive personal data you have provided in a structured, commonly used and machine-readable format or exercise any of those rights above, you can contact our Data Protection Officer at DPO@ztn.com

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Right to Object

You have the right of objection at any time to processing of your personal data based on Article 6 (1) lit. f GDPR (data processing based on our legitimate interest) or Article 6 (1) lit. e GDPR (data processing based on public interest). If you submit an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

Right to withdraw your consent

Where you have provided your consent to the collection, processing, or transfer of your personal data, you may have the legal right to withdraw your consent at any time. To withdraw your consent, if applicable, contact us at dpo@ztn.com.

Opting out of email marketing

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may contact our Data Protection Officer at DPO@ztn.com.

10. Data transfer to third party outside of the European Economic Area

Where permitted by applicable law, we may transfer the personal data we collect about you to China and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Notice.

European data protection laws generally allow for a free flow of information between different countries within the EEA. However, if data are transferred to countries outside the EEA or are accessible from outside the EEA, additional "adequate protective measures" in accordance with European data protection laws have to be taken. We have taken additional measures for the transfer of data outside the EEA to protect your data, including Standard Contractual Clauses. If you would like an overview of all the safeguards are in place, please contact our DPO.

11. Consent by Minors

In Short: Pursuant to GDR and the amended FDPA, We do not knowingly collect data from or market to minors under the age of 15.

We do not provide services directly to children or knowingly collect or use any personal data from minors without the consent from both the minor and the parent or legal guardian. Minor means any individuals who is under the age of 15(or the minimum legal age at which personal data is consented to be collected and processed where applicable law differs). We do not knowingly allow minor to use our services, communicate with us, or use any of our website service. By using the Services, you represent that you are at least 15 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If you become aware that a minor has provided us with personal data, please contact us as indicated in Section “How can you contact us”. We will take all reasonable measures to delete the information as soon as possible and to not use such information for any purpose, except where necessary to protect the safety of the minor or others as required by law.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

13. POLICY CHANGE

This notice will be reviewed annually or when necessary to ensure compliance with the data protection law. If significant changes have been made to this notice, or the way your Personal Data is processed, we will contact you immediately.

14. HOW CAN YOU CONTACT US?

If you have any questions about the way we process your personal data, please read this Privacy Statement first. For additional questions please contact our Data Protection Officer at DPO@ztn.com. You can also contact us by posting to:

RCS Pontoise

Avenue XXIème Siècle Bât.1, ZAC des Tulipes Sud

95500 Gonesse

FRANCE