TWYFORD PRIVACY POLICY

Last updated: September [], 2024

1. ABOUT THIS NOTICE

Twyford international group ("we" or "us" or “Twyford”) is committed to maintaining the privacy of users of this website and/or mobile application using our system.

This Privacy Policy provides information on how we collect and process your personal data when you visit our website and/or mobile application. By accessing and using this website and/or application, you consent to us collecting, using, storing, and processing your personal data in accordance with the terms of this Privacy Policy.

This is our main general privacy notice that applies across our business, although we may publish additional privacy statements that apply to:

• our operations in specific countries in order to help ensure our compliance with local data protection requirements

• specific services that we offer from time to time

If an additional privacy statement is relevant to you because of the way in which you engage with us and there is a conflict between the information set out in this notice and the additional privacy statement, then the additional privacy statement will take precedence over the information set out in this Privacy Policy.

2. WHO WE ARE

Twyford international group is one of the international trade enterprises that penetrate into overseas markets such as Africa and south America at the earliest. Our platform consists of our marketplace, which connects Twyford with buyers, our logistics service, which enables the shipment and delivery of packages from Twyford to buyers, and our payment service, which facilitates transactions among participants active on our platform in selected markets. This website and/or mobile application are operated by us. Any personal data provided or collected by Twyford is controlled by Twyford that the website and/or mobile application relates to.

3. COLLECTION OF PERSONAL DATA

Personal data means any information that can be used to identify directly or indirectly a specific individual. We collect your personal data to provide tailored products and services and to analyze and continually improve our products and services. We may collect, use, store, and transfer different kinds of personal data for marketing and personal data optimization purposes.

You provide us with your personal data when you register your personal details on our website and mobile platform and transact with the same.

The personal data we collect includes:

A. Information you provide to us: we receive and store the information you provide to us, including your identity data, contact data , delivery address, and financial data. These types of personal data may include:

Contact details (such as your name, postal addresses, phone numbers, and email addresses)

Online registration information (such as your password and other authentication information)

Payment information (such as your credit card information, billing address and transaction history)

Information provided as part of online questionnaires (such as responses to any customer satisfaction surveys or market research)

Competition entries/submissions

In certain cases, your marketing preferences

B. Information we automatically collect/generate or obtain from third parties: we collect and store certain types of information regarding your use of the Twyford CRM marketplace, including information about the date and time of your visit, your searches, views, downloads, and purchases, your IP address, your server address, your domain name, your geographical location (where you have not disabled this functionality), and information we may collect from various mobile apps and devices, including but not limited to information about vehicle speed, location and routes travelled, driving behavior data, photos, driver identification, and other RFID data. In addition, we may receive information about you from third parties, including our carriers, payment service providers, merchants/brands, and advertising service providers. We may also use analytics to collect device-specific information (device model, operating system).

These types of personal data may relate to your device (such as your pc, tablet, or other mobile device), your use of our websites and applications (as well as certain third-party websites with whom we have partnered), and/or your personal preferences, interests, or geographic location. Examples of these types of information include:

Name

Information about your device, operating system, browser, and IP address

Unique identifiers associated with your device

Details of web pages that you have visited

Which products you have looked at online (including information about products you have searched for or viewed, purchased or added to an online shopping basket)

How long you spend on certain areas of a website or application together with the date and time of your visit/usage

Personal data contained within user-generated content (such as blogs and social media postings)

• Social media username or ID.

Where do we collect your personal data from?

We collect your personal data from various sources, including:

you

our clients and our service providers

other third parties

credit reference agencies

anti-fraud databases, sanctions lists, court judgements and other databases

government agencies and publicly accessible registers or sources of information

by actively obtaining your personal data ourselves, for example through the use of website tracking devices

Which of the sources apply to you will depend on why we are collecting your personal data. Where we obtain your information from a third party we may ask them to provide you with a copy of this privacy notice (or a shortened version of it) to ensure you know we are processing your information and the reasons why.

We strive to provide you with choices regarding the personal data that you provide to us. Where required by law, if you wish to have your personal data used by us to provide you with a personalized experience/targeted advertising & content, you can indicate so through the relevant tick-box(es) located on the registration form or by answering the question(s) presented by our representatives. If you decide that you no longer wish to benefit from this personalization, you can opt-out or adjust your preferences at any time by contacting us. You can also close your account by clicking on this link and following the instructions. Once your account is closed, all products and services that you access through your account will no longer be available.

4. COOKIES AND OTHER IDENTIFIERS

We use common internet software solutions, including "cookies," which are stored on your browser, to hold the information specific to you from your browsing session. You can modify your browser settings to prevent this from happening, although this may in some cases preclude you from using, or negatively affect the display or function of this and other website and applications.

5. HOW WE USE YOUR PERSONAL DATA

We use your personal data to operate, provide, develop, and improve the products and services that we offer, including the following:

Registering you as a new customer; and

Processing and delivering your orders; and

Managing your relationship with us; and

Enabling you to participate in promotions, competitions, and surveys; and

Improving our website, applications, products, and services; and

Recommending/advertising products or services that may be of interest to you; and

Enabling you to access certain products and services offered by our partners and vendors; and

Complying with our legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties, including verifying your identity where necessary; and

• Detecting fraud, criminal activity, or misuses of our services.

6. DISCLOSE OF PERSONAL DATA

In certain circumstances we may provide your personal data to third parties:

• In certain case services provided by our authorized partner, to assist us in meeting business operations needs and to perform certain services and functions, we may disclose your personal data.

• We may disclose your personal data among our facilities only for specific purpose, and only in a necessary range.

• In case applicable laws require or in response to legal procedure, we may disclose your personal data to relevant law enforcement agencies or government agencies.

• If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your personal data and other data may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

• We may disclose personal data to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Twyford. Our affiliates may use the personal data we share in a manner consistent with this Privacy Policy.

7. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and used your personal data. In almost every case, the legal basis will be one of the following:

• Your consent when we ask for your consent to process your personal data for a specific purpose that we communicate to you.

• Performance of a contract with you: this would also apply where we need to take steps prior to entering into a contract with you. For example, where you have purchased a product from us and we need to use your contact details and payment information to process your order and send the product to you.

• Compliance with law: where we are subject to a legal obligation and need to use your personal data to comply with that obligation.

• Our legitimate business interests: where it is necessary for us to understand our customers, promote our services, and operate effectively, provided in each case that this is done in a legitimate way that does not unduly affect your privacy and other rights.

We do not generally process your personal data based on your consent (as we can usually rely on another legal basis). Where we do process your personal data based on your consent, you have the right to withdraw your consent at any time. To withdraw your consent please email us at gtleadinglope@Twyford.com.

8. DATA RETENTION

We will take every reasonable step to ensure that your personal data is processed for the minimum period necessary in order to provide our service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. Your personal data may be retained in a form that allows for identification only for as long as:

We maintain an ongoing relationship with you. This will enable us to improve your experience with us and to ensure that you receive communications from us

Your personal data is necessary in connection with the purposes set out in this Privacy Policy and we have a valid legal basis,

The duration of any applicable limitation period (i.e., any period during which a person could bring a legal claim against us), and

We will actively review the personal data we hold and delete it securely, or in some cases anonymize it when there is no longer a legal, business, or consumer need for it to be retained.

9. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. However, no internet is ever fully secure or error free. Therefore, you should take special care in deciding what data you send to us via the service.  

10. YOUR LEGAL RIGHTS

Under certain conditions, you may have the right to require us to:

• provide you with further details on the use we make of your personal data

• provide you with a copy of the personal data we hold about you

• update any inaccuracies in the personal data we hold about you

• delete any of your personal data that we no longer have a lawful ground to use

• where processing is based on consent, stop that particular processing by withdrawing your consent

• object to any processing based on our legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights

• restrict how we use your personal data whilst a complaint is being investigated

• transfer your personal data to a third party in a standardised machine-readable format

In certain circumstances, we may need to restrict your rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

11. DATA TRANSFERS

The global nature of our business means that your personal data may well be transferred across national boundaries. Where we transfer your personal data across national boundaries, we will protect your personal data by ensuring that those transfers are made in compliance with all relevant data protection laws. 

12. LOCAL DIFFERENCES

Whilst this Privacy Policy describes the data protection practices adopted by us generally across the world, local data protection laws vary and some countries may place restrictions on our processing activities. This means our actual data protection practices in certain countries may vary from those described here in order to help us ensure we comply with local requirements.

13. CHANGES

We may update or change this Privacy Policy from time to time by posting an updated Privacy Policy on the website and/or application.

14. DATA CONTROLLERS & CONTACT

If you have any questions concerning this Privacy Policy or the treatment of your personal data, please contact us by email at gtleadinglope@Twyford.com.

Twyford TERMS OF USE

TERMS OF USE - END USER LICENSE AGREEMENT

Last updated: September [], 2024

This terms of use-end user license agreement ("terms") sets out the basis upon which Twyford International Group ("we" or "our" or “us” or “Twyford”) will grant you, the customer, access and use of the CRM platform (the "service"). Please read this terms carefully before accessing or using our services including limitation of liability that exempts or limits the developer’s liability and the user’s rights(in case you are a miner, please make sure with your guardian’s accompany). By using our services, you agree to the following terms.  If you do not understand and agree to these terms, you should exit the service.

Your use of the CRM platform must also comply at all times with our published policies and procedures, including the Privacy Policy, which shall, for the avoidance of doubt, form part of these terms.

Twyford may update all or any part of these terms from time to time by posting an updated version on our website and applicaiton. You can monitor our website and application for any updates or changes, and your continued use of the service after updated terms have been posted on our website and application will constitute your acceptance of such updated terms.

AUTHORISED USERS

Users must complete the registration and verification process set out on our website and application and be verified as an authorized user in order to access and use the service. Should you at any time cease to be an authorized user, all rights granted to you under these terms will terminate with immediate effect.

RESTRICTIONS

Twyford owns all intellectual property rights for the service. You must not reverse assemble, reverse compile, reverse engineer, or otherwise attempt to derive the source code of any software; modify, enhance, or create derivative works of the software or any other component of the service; sublicense, sell, distribute, transfer possession, rent or grant other rights to access or use the service, or engage in service bureau work, application service provider services, or time-sharing arrangements with respect to the service, or permit or enable any third party to do the same.

AVAILABILITY

Twyford may make modifications or changes (hereinafter referred to as changes) to the service from time to time . We will give you an advance notice of changes to these terms that materially adversely impact you either via email or an in-product notification. All other changes will be effective as soon as we post them to our website and application. If you do not agree to the modifications or changes, you must stop using our services.

As you access and use the service, which relies upon us, you acknowledge that your ability to use the service may from time to time be affected by factors inherent in the use of Gtleadinglope and other circumstances outside. We are not responsible for any delay, interception, delivery failure, loss of data or use, or any other problem caused directly or indirectly by third-party products or services or other circumstances not wholly within our control.

SUSPENSION AND TERMINATION

We may decide to suspend or terminate our services, but if we do, we will give you an advance notice. Upon such termination, all rights granted to you under these terms will terminate, and you must immediately cease to use the service.

DISCLAIMER

Your use of, and any reliance upon, the service is at your own sole risk. The service is provided to you on an "as is," "as available," and "where-is" basis, without any warranties or conditions of any kind. Twyford provides no representations, warranties, or conditions in connection with or regarding the service, including but not limited to the suitability, accuracy, or completeness of any data, material, information, or services contained on or obtainable through the service.

All representations, warranties, and conditions, whether express or implied, statutory or otherwise, including, but not limited to, any implied warranty or condition of quality, merchantability, fitness for a particular purpose, or non- infringement of third party rights are hereby disclaimed. Specifically, Twyford makes no warranty regarding the availability of the service, including any data stored on or obtainable through the service, your access to the service, or the accuracy of any information either stored or provided through the service.

Twyford shall not be liable to you or to any third party for any loss or damages of any kind, including but not limited to, direct, indirect, incidental, consequential, or punitive damages, or lost profits or revenue or failure to realize expected savings arising from or connected with the service, including but not limited to, your use of or your inability to use the service or access any data, even if we have previously been advised of the possibility of such damages.

You alone are responsible for your actions related to the use of the service or the actions of any person accessing or using your user name and/or password to access the service. As such, you shall defend, indemnify, and hold Twyford harmless from and against any and all claims, demands, lawsuits, costs, damages, liabilities, and expenses (including legal fees) incurred, claimed, or alleged, relating in any way to: (i) your breach of these terms of use; (ii) your use of the service or the use of the service by any person using your user name and/or password; (iii) the entry, sufficiency, adequacy, accuracy, or timeliness of the data team submit or process through the service.

Twyford shall not be responsible or liable for the deletion, correction, corruption, destruction, damage, loss, or failure to store any data. Twyford reserves the right to withhold, remove, and/or discard customer data without notice, for any breach, including, without limitation, non-payment of any charges.

PRIVACY

We will deal with any personal data provided by you, whether directly or through your use of the service, in accordance with our Privacy Policy.

APPLICABLE LAW AND DISPUTES

These terms and conditions are governed by the laws of the People’s Republic of China. Any dispute arising from or in connection with this Privacy Policy shall be submitted to China International Economic and Trade Arbitration Commission(CIETAC) for arbitration which shall be conducted in accordance with the CIETAC's arbitration rules in effect at the time of applying for arbitration. The arbitral award is final and binding upon both parties.

GENERAL

Any failure or delay of Twyford to enforce any right or provision in these terms of use shall not constitute a waiver of such right or provision, nor shall any single or partial exercise of a right preclude any other or further exercise thereof or the exercise of any other right.

These terms of use constitute the entire agreement, arrangement, and understanding between the parties with respect to the service.

Should any part of these terms be held invalid or unenforceable, that portion shall be construed consistent with applicable law as nearly as possible to reflect the original intentions of the parties, and the remaining portions shall remain in full force and effect.

CONTACING US

If you are in doubt as to the accuracy and currency of any information posted on or downloaded from this website or application, or if you require any further information, please contact us at gtleadinglope@Twyford.com.