Privacy policy
We are a cable factory, not a data business. This page explains exactly what personal data reaches us — from this website and from the Amazon Selling Partner API integration we run for our own seller account — what we do with it, how long we keep it, and how you can have it deleted.
1. Who we are
Dongguan Tong Lian Electric Wire & Cable Co., Ltd. is the controller of the personal data described in this policy. We manufacture and sell wire and cable from our plant in Humen, Dongguan, Guangdong, China, under our own brand LUCKY TL. We sell business-to-business: to distributors, contractors and OEM customers, and through our own seller account on Amazon.
- Legal entity: Dongguan Tong Lian Electric Wire & Cable Co., Ltd.
- Registered / business address: No. 3, Huai De DaKeng Middle Road, Humen Town, Dongguan City, Guangdong Province, China 523926
- Privacy contact: TongLianwire@outlook.com — write “Privacy” in the subject line
- Telephone: +86 769 8226 2323
- Response time: within 30 days, usually within 3 business days
2. Scope of this policy
This policy covers two things:
- This website (tonglianwire.com and its Chinese section) — a mostly static catalogue with an inquiry form, technical articles and a password-protected administration area that only our own staff can open.
- Our internal Amazon integration — a private application that connects to Amazon’s Selling Partner API (SP-API) to manage listings, inventory, orders and reports for our own Amazon seller account. It is not offered, sold or licensed to any other seller, and it is not available to the public.
Amazon.com and Amazon’s own apps are operated by Amazon, not by us. When you browse or buy on Amazon, Amazon’s privacy notice applies to that activity. This policy only covers what we do with data once it reaches us.
3. What we collect
3.1 Information you give us
The inquiry form on our contact page does not submit to a server. Pressing “Send an inquiry” opens your own email application with the text filled in, so you can review and edit everything before anything is sent, and nothing is stored on this website. If you do send it, or if you email, WhatsApp, WeChat or call us, we receive what you choose to include — typically your name, company, country, email address, phone or messaging handle, and the content of your message, drawing or specification.
3.2 Information collected automatically
Our web server records short-term technical logs: IP address, browser and operating system, the page requested, the referring page, and the date and time. These logs exist for security, abuse prevention and fault-finding only. They are not used to build visitor profiles. Log files rotate daily and are destroyed after 14 days.
3.3 Amazon data obtained through the Selling Partner API
Our integration is authorised by us, for our own seller account, through Amazon’s official OAuth consent flow. Within that authorisation we can access and store:
- Order and shipment records — order identifiers, purchase date, items, quantities, amounts, fulfilment and delivery status; for seller-fulfilled orders, the buyer’s name, delivery address and, where Amazon provides it, a masked contact number.
- Buyer messages — the correspondence a buyer sends us about an order through Amazon’s messaging system. Amazon gives us an anonymised buyer e-mail alias, not the buyer’s real e-mail address.
- Returns and refunds — return reason codes and status.
- Catalogue and listing data — ASINs, SKUs, titles, bullet points, images, prices and stock levels that we ourselves publish.
- Operational reports — inventory, settlement, fee and performance reports that Amazon generates for our account.
We never receive or store payment card numbers, bank credentials or Amazon account passwords. Amazon does not share those with sellers, and we do not ask for them.
Where the data comes from. Sections 3.1 and 3.2 describe data you give us or that our own server records. The data in this section 3.3 reaches us from Amazon, acting as the marketplace operator, under the authorisation you grant when you place an order there — not from anything we collect ourselves on Amazon.
4. Why we use it
- To answer inquiries and quote — replying to your message, preparing a quotation, confirming a drawing or sample.
- To perform contracts — producing, packing, shipping and invoicing the goods you order, and handling returns or claims.
- To run our Amazon shop — publishing and updating listings, keeping stock levels accurate, processing and dispatching orders, answering buyer messages, and reconciling settlements and fees.
- To meet legal duties — tax, accounting, export control, product-safety and certification record-keeping.
- To keep the site and the integration secure — detecting abuse, unauthorised access and fraud.
We do not use personal data for advertising to individual buyers, for building cross-site behavioural profiles, for automated decision-making with legal effect, or to train artificial-intelligence or machine-learning models. We do not sell personal data, and we do not share it for cross-context behavioural advertising.
5. Legal bases
- China (PIPL) — your consent where we rely on it (for example when you send us an inquiry), performance of a contract with you, and our obligations under tax, accounting and product-safety law.
- EU / UK (GDPR) — performance of a contract or steps prior to entering one (Art. 6(1)(b)), our legitimate interests in running a manufacturing business and keeping systems secure (Art. 6(1)(f)), compliance with legal obligations (Art. 6(1)(c)), and consent where required (Art. 6(1)(a)).
- California (CCPA/CPRA) — we collect and use the categories described above for the business purposes listed, and we do not sell or share personal information as those terms are defined by the CPRA.
Do you have to give us data? No law requires you to. You can read this site and ask general questions without giving us anything; if you choose not to give us a contact address, though, we cannot quote, ship or invoice an order for you.
6. Cookies and sessions
The public pages of this website set no cookies at all. There is no analytics, no advertising pixel, no social-media button, no chat widget and no third-party tracker of any kind.
The only cookie on the site is a session cookie issued when one of our own administrators signs in to the password-protected management area. It holds no marketing data and is not readable by any third party. It disappears when you close the browser, and the server-side session is discarded after 12 hours of inactivity.
7. Sharing and service providers
We do not sell, rent or trade personal data. We disclose it only in these situations:
- Hosting — this website and our internal database run on servers provided by Alibaba Cloud (Alibaba Group), located in mainland China.
- E-mail — business correspondence is handled through Microsoft Outlook (Microsoft Corporation).
- Amazon — order, listing and settlement data is exchanged with Amazon as the marketplace operator, on the terms of our seller agreement.
- Logistics and freight forwarders — the recipient name, address and phone number needed to deliver goods you have ordered.
- Professional advisers — our accountant and auditor, where necessary for tax and statutory reporting.
- Authorities — where we are legally required to disclose, or where disclosure is necessary to establish or defend a legal claim.
Every provider above is bound to use the data only for the purpose we engaged it for. We do not currently use any other sub-processor, and we will list any addition on this page before it is used.
8. Amazon data: our specific commitments
Because Amazon data can include information about buyers who never dealt with us directly, we apply stricter rules to it than to our own business correspondence:
- We use Amazon data only to operate our own seller account on Amazon — listings, inventory, order fulfilment, customer service for our own orders, and settlement reconciliation.
- We do not sell, rent, licence or otherwise disclose Amazon data to any third party, and we do not transfer it to any other seller or service provider.
- We do not use Amazon data to train, fine-tune or evaluate artificial-intelligence or machine-learning models, and we do not combine it with data from other sources to profile or target buyers.
- We do not contact buyers outside Amazon’s messaging system on the basis of Amazon data, and we do not use it for marketing.
- Amazon data is held on encrypted storage, transmitted over TLS 1.2 or above, and accessible only to the two staff members who fulfil orders.
- Order and buyer data is deleted or anonymised 90 days after the order’s return window closes; generated reports are deleted after 30 days.
- If our authorisation is revoked, if our seller account is closed, or if Amazon asks us to, we delete the data within 30 days and confirm the deletion in writing on request.
- We comply with Amazon’s Data Protection Policy, Acceptable Use Policy and the SP-API terms. We do not scrape Amazon pages or obtain data by any means other than the official API.
If you are an Amazon buyer and want to know what an Amazon order of yours shows on our side, you can write to us at the address in section 17 and we will help within 30 days. You can also exercise your rights directly with Amazon, which holds the complete record of the transaction.
9. International transfers
We are based in China and our servers are in mainland China, so data you send us from the United States, the European Union, the United Kingdom or elsewhere is transferred to and stored in China.
For transfers out of the EU/UK we rely on the European Commission’s Standard Contractual Clauses (and the UK Addendum where applicable), together with the technical measures described in section 11. For transfers covered by China’s PIPL we rely on your separate consent where required, and on the security assessment or standard-contract filing where the law requires one.
10. How long we keep data
We keep data only as long as we need it for the purpose it was collected for, or as long as the law requires. After that it is deleted or irreversibly anonymised.
| Data | Retention | Why |
|---|---|---|
| Inquiries and quotations that did not lead to an order | 24 months from last contact | So we can pick up the conversation where it stopped |
| Amazon order, shipment and buyer data | 90 days after the return window closes | Fulfilment, returns and claims handling |
| Amazon generated reports | 30 days | Operational reconciliation |
| Buyer messages | 24 months | Dispute and chargeback defence |
| Server logs | 14 days | Security and fault-finding |
| Invoices and accounting records (amounts, no buyer identifiers after 90 days) | 10 years | Required by PRC accounting and tax law |
| Administrator accounts | Until deleted, plus 30 days | Access control and audit |
11. Security
- The public website collects nothing. No page on this site posts data to our server — the inquiry form opens your own e-mail client — so simply browsing it transfers no personal data to us.
- Every channel that does carry your data is encrypted. E-mail is exchanged between mail servers over TLS; calls to Amazon’s Selling Partner API use HTTPS with TLS 1.2 or above; credentials are never placed in a URL or in the browser.
- The management area holds only our own catalogue content (product data, articles, images) — never customer or buyer data — and is protected by a password, rate-limited against brute force, and will be served over HTTPS only as soon as the domain certificate is issued.
- A single named administrator account is used, with a password of at least 10 characters that is changed whenever the person responsible changes; the account is removed when that person leaves.
- Amazon API credentials are stored server-side, never in the browser, and are rotated when staff change.
- Access follows least privilege: only the staff who fulfil orders can see order and buyer data, and access is logged.
- Backups of the site and database are kept in a location accessible only to the administrator, with the same retention as the live data.
- Staff are bound by confidentiality obligations and receive instructions on handling buyer data.
- If a breach affects your personal data, we will notify you and the competent authority without undue delay, and within 72 hours where the GDPR applies. If the incident involves Amazon data, we also notify Amazon within 24 hours of becoming aware of it, as its Data Protection Policy requires.
12. Your rights
Subject to applicable law, you may ask us to:
- tell you whether we hold personal data about you, and give you a copy;
- correct anything inaccurate or incomplete;
- delete your data (see section 13);
- restrict or object to certain uses;
- provide your data in a portable, machine-readable format;
- withdraw a consent you gave earlier, without affecting what we did before you withdrew it.
Write to TongLianwire@outlook.com with the subject line “Privacy” and tell us which right you want to exercise. We answer within 30 days and we do not charge for the first request. We will ask for enough information to verify that the request comes from you, and nothing more. We will not discriminate against you for exercising a right.
If you are not satisfied, you may complain to the Cyberspace Administration of China or the provincial communications authority, to your local data protection authority in the EU/UK, or to the California Privacy Protection Agency.
13. How to have your data deleted
- Send an email to TongLianwire@outlook.com with the subject “Data deletion request”.
- Tell us the e-mail address, company or Amazon order number the data relates to. We may ask one verification question.
- We confirm receipt within 3 business days and complete the deletion within 30 days, then confirm it to you in writing.
- We delete the data from live systems first, then from backups on their normal rotation, within a further 30 days.
Two exceptions apply, and we will tell you if either is relevant: records we must keep by law (for example invoices, which PRC tax law requires us to retain for ten years, though buyer identifiers are stripped after 90 days), and data we must keep to establish or defend a legal claim.
14. Children
This is a business-to-business website and is not directed at children. We do not knowingly collect personal data from anyone under 16. If you believe a child has sent us data, write to us and we will delete it.
15. Do Not Track and profiling
We do not track visitors across websites, so there is nothing for a “Do Not Track” or Global Privacy Control signal to switch off, and we honour both in any case. We carry out no automated decision-making and no profiling that produces legal or similarly significant effects.
16. Changes to this policy
If we change how we handle personal data — for example if we add a new service provider, start using a new Amazon API section, or begin using analytics — we will update this page and the date at the top of it before the change takes effect. Material changes affecting buyers or customers will also be announced on the home page for 30 days. Earlier versions are available on request.
17. Contact
- Company: Dongguan Tong Lian Electric Wire & Cable Co., Ltd.
- Address: No. 3, Huai De DaKeng Middle Road, Humen Town, Dongguan City, Guangdong Province, China 523926
- Privacy e-mail: TongLianwire@outlook.com
- Telephone: +86 769 8226 2323
- Contact person: the data protection contact named in our reply to your first message