Privacy Policy

1. Introduction

2. Who We Are

Biliten (Hong Kong) International Trade Co., Limited is a company registered in Hong Kong that provides international trade and sourcing services under the Earthwise marque. Our registered place of business is Rm 19H MAXGRAND PLZ, 3 TAI YAU ST, San Po Kong, Hong Kong (HK). We are the data user, and where applicable the data controller, in respect of personal information described in this policy.

Our services include global sourcing programmes, supplier vetting and audits, freight and customs coordination, quality inspection services, private label development and trade compliance advisory. Each of these activities may involve personal information relating to client staff, supplier contacts and individual representatives of corporate entities. This policy covers all of those activities.

You may reach our privacy contact by email at sales@earthwise.lat or by telephone at +19147685515 during published office hours. Written correspondence may be addressed to the postal address given above.

3. Scope Of This Policy

This policy applies to the Earthwise website located at https://www.earthwise.lat/ and to personal information collected through that website, through email correspondence, through telephone calls and through the delivery of our trade services. It also applies to information collected during supplier audits, factory visits, inspection assignments and logistics coordination where individuals are identifiable.

This policy does not apply to websites operated by third parties, even where we link to them or where they link to us. It does not apply to information that has been fully anonymised so that no individual can be identified, and it does not apply to aggregated commercial data that contains no personal identifiers.

Where we act as a processor on behalf of a client, the client remains responsible for the lawful basis of processing and for providing notices to the individuals concerned. In those circumstances we process personal information only on the documented instructions of the client and only for the purposes the client has defined.

4. Information We Collect

We collect personal information that is necessary for the purposes described in this policy. The categories of information we may collect include the following.

4.1 Identity And Contact Information

This includes names, job titles, company names, business addresses, business email addresses, business telephone numbers, messaging identifiers and the country or region in which a contact is located. Where a person contacts us on behalf of a company, we may also record the nature of that persons role and the department in which the person works.

4.2 Enquiry And Correspondence Information

This includes the subject of an enquiry, the service of interest, the content of messages, attachments that a person chooses to send, records of quotations issued and received, and notes taken during meetings or calls. Correspondence may be retained so that we can answer follow up questions and maintain an accurate commercial record.

4.3 Transaction And Programme Information

Where a person is involved in a sourcing, inspection, freight or compliance programme, we may hold information relating to purchase orders, shipment schedules, supplier contacts, inspection findings, customs documentation and payment references. This information may include personal identifiers where a document names an individual representative, signatory or contact.

4.4 Technical And Usage Information

When a visitor loads the website, our hosting environment may record limited technical information such as the internet protocol address, browser type, device type, operating system, referring page and the pages viewed. This information is used for security, troubleshooting and general performance measurement.

4.5 Information You Send Voluntarily

We collect any other personal information that you choose to provide. Please do not send sensitive personal information, such as health data or financial account credentials, through the website or by email, because those categories are not required for the services we provide.

5. How We Collect Information

We collect information directly from you when you complete the enquiry form, send an email, call our office, attend a meeting, respond to a quotation or correspond with a coordinator during a programme. We also collect information when a supplier or client provides contact details for an individual who will act as a representative on a project.

We collect information automatically when you browse the website, as described in the technical information section above. This collection is limited to what the hosting environment requires in order to deliver pages securely and reliably.

We may receive information from third parties in the course of a programme. For example, a freight forwarder may confirm the name of a consignee representative, a customs broker may provide a declaration reference that names a signatory, or an audit partner may supply a report that identifies a factory manager. Where we receive such information we handle it in accordance with this policy.

6. Purposes Of Processing

We process personal information for the following purposes, all of which are connected to the services we provide or to the operation and protection of our business.

• To respond to enquiries and provide quotations, service scopes and programme plans.
• To deliver sourcing, vetting, freight, inspection, private label and compliance services.
• To maintain commercial records of orders, shipments, inspections and advice given.
• To communicate about active programmes, including milestone reports and document sets.
• To manage supplier relationships, audit scheduling and corrective action follow up.
• To protect the website, our systems and our commercial information from misuse and fraud.
• To meet legal, tax, customs and regulatory obligations that apply to international trade.
• To improve our services by understanding which pages and services are most useful.
• To establish, exercise or defend legal claims where a dispute arises.
• To send marketing communications where you have asked to receive them.

We do not sell personal information. We do not rent contact lists. We do not use personal information for purposes that are incompatible with the purposes listed above without first providing notice.

7. Lawful Bases For Processing

Where the law requires us to identify a lawful basis for processing, we rely on the following bases depending on the circumstances.

7.1 Performance Of A Contract

We process information as necessary to enter into and perform a contract with you or with the company you represent, including quoting, delivering services and handling payment matters.

7.2 Legitimate Interests

We process information where it is necessary for our legitimate interests in operating a commercial trade business, provided those interests are not overridden by your rights. This includes responding to business enquiries, protecting our systems, maintaining records and improving our services.

7.3 Legal Obligation

We process information where we must do so to comply with applicable law, including tax, customs, anti money laundering and record keeping requirements that apply to trade documentation.

7.4 Consent

Where we rely on consent, for example for certain marketing communications, you may withdraw that consent at any time by contacting us using the details in this policy. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

8. Cookies And Similar Technologies

A cookie is a small text file that a website may place on a visitors device in order to remember preferences or to measure usage. The Earthwise website is designed to work with minimal reliance on cookies. Any cookies that are set are used for essential site functions such as remembering a navigation state, or for basic measurement where enabled.

You can control cookies through your browser settings. Most browsers allow you to block cookies, delete existing cookies and receive a warning before a cookie is stored. If you block essential cookies, some parts of a website may not function as intended, although the Earthwise site is built to remain readable and usable without them.

Where a tool sets a cookie or a similar identifier, that tool is configured to respect the choices you make. We do not use cookies to build advertising profiles of visitors, and we do not permit third parties to use cookies on this site for cross site behavioural advertising.

9. Analytics And Site Measurement

We may use privacy conscious measurement to understand how visitors find and use the website. Measurement may record page views, referring sources, approximate region, device type and the time spent on a page. This information is used in aggregate to improve navigation, content and service descriptions.

Where analytics are used, we configure them to avoid collecting unnecessary personal identifiers, and we retain reports only for as long as they serve a genuine business purpose. We do not attempt to identify individual visitors from measurement data, and we do not combine measurement data with commercial records to profile individuals.

If you prefer not to be measured, you may block the relevant script through your browser or an extension. The website remains fully functional when measurement is blocked, and blocking has no effect on your ability to contact us or receive services.

10. Sharing With Service Providers

We share personal information with service providers that help us operate the business. These providers are engaged under contracts that require them to protect the information they handle and to use it only for the purposes we have authorised. Categories of providers include the following.

• Web hosting and information technology providers that operate our website and email systems.
• Freight forwarders and carriers that move goods and require consignee and contact details.
• Customs brokers that lodge entries and require declaration information.
• Inspection partners that attend factory sites and require site contact details.
• Audit and accounting firms that review our records for legal and tax compliance.
• Professional advisers that assist with legal, insurance or dispute matters.

We may also disclose information where we are required to do so by law, by a court order, by a customs or tax authority, or where disclosure is necessary to protect rights, property or safety. Where a disclosure is discretionary, we disclose only the minimum information necessary to achieve the purpose.

If our business is reorganised, merged or transferred, personal information may form part of the assets that move to the successor entity. In that event the successor remains bound by this policy in respect of information collected under it, and we will provide notice of any material change in ownership.

11. International Transfers

International trade is by nature cross border, and personal information may be transferred between the jurisdictions in which our clients, suppliers, providers and offices are located. Information collected through the Earthwise website may be stored on servers located outside your country of residence.

Where we transfer personal information across borders, we take steps to ensure that the information receives an appropriate level of protection. Those steps may include contractual commitments from the receiving party, limiting transfers to what is necessary for the purpose, and applying technical measures such as encryption in transit.

By providing personal information to us, you understand that it may be processed in a jurisdiction other than your own, and that the laws of that jurisdiction may differ. We select providers carefully and review their safeguards as part of our supplier management process.

12. Data Retention

We keep personal information only for as long as it is needed for the purposes for which it was collected, or for as long as the law requires. Retention periods differ according to the type of information and the context in which it was collected.

12.1 Enquiries And Quotations

Enquiry records and quotations are generally retained for the period during which a commercial relationship is active, and then for a limited period afterwards so that we can answer follow up questions and demonstrate the basis on which advice was given.

12.2 Transaction And Customs Records

Records relating to shipments, inspections, customs entries and compliance advice are retained for the period required by applicable trade, tax and record keeping law. These periods may be longer than those applied to general correspondence because authorities may review entries years after import.

12.3 Website Technical Data

Technical logs are retained for a short period sufficient for security monitoring and troubleshooting, after which they are deleted or aggregated so that no individual is identifiable.

When a retention period ends, we delete or anonymise the information. Where deletion is not immediately possible because information is held in a backup archive, we isolate it and delete it as soon as the archive cycle permits.

13. Data Security

We apply technical and organisational measures to protect personal information against unauthorised access, alteration, disclosure and destruction. Measures include access controls that limit information to staff who need it, secure transmission of website traffic, protection of email accounts with strong authentication, and periodic review of the systems that hold commercial records.

We train staff on the handling of confidential commercial information and on the importance of not sharing client or supplier details outside authorised channels. Access to programme records is granted by role, and access is removed promptly when a person leaves our organisation or changes responsibilities.

No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we work to reduce risk and we review our measures as threats and technologies change. If we become aware of a breach that affects personal information, we will investigate, take steps to contain it, and provide notification where the law requires.

14. Your Rights And Choices

Subject to applicable law, you may have the following rights in relation to personal information that we hold about you.

• The right to request access to personal information we hold about you.
• The right to request correction of information that is inaccurate or incomplete.
• The right to request deletion of information that is no longer necessary.
• The right to request restriction of processing in certain circumstances.
• The right to object to processing based on legitimate interests.
• The right to request portability of information you provided to us.
• The right to withdraw consent where processing is based on consent.
• The right to lodge a complaint with a supervisory authority.

To exercise a right, contact us using the details in this policy. We may need to verify your identity before acting on a request, and we may ask for further detail so that we can locate the relevant records. We will respond within the period required by applicable law, and where a request cannot be granted we will explain the reason.

You will not be disadvantaged for exercising a privacy right. We do not charge a fee for reasonable requests, although we may charge where a request is tallyly unfounded or excessive.

15. Marketing Communications

We may send occasional commercial communications about trade lanes, service updates and market conditions where you have requested them or where the law permits us to contact existing business contacts. These communications are intended to be relevant to the buyers and suppliers with whom we work.

Every marketing message includes a simple way to opt out. You may also opt out at any time by emailing sales@earthwise.lat or by calling +19147685515 and asking to be removed from marketing lists. Opting out of marketing does not prevent us from sending operational messages that are necessary to deliver a service you have requested, such as shipment notifications or inspection reports.

We keep marketing lists separate from transactional records so that an opt out is applied quickly and completely. We do not buy marketing lists from third parties, and we do not share your contact details with third parties for their own marketing purposes.

16. Privacy For Children

Our services are intended for businesses and professional buyers. The website is not directed at children, and we do not knowingly collect personal information from children. If you believe that a child has provided personal information to us, please contact us so that we can investigate and delete the information promptly.

Where a programme involves consumer products intended for children, we may review safety and labelling requirements as part of our quality and compliance services. That review concerns product standards and does not involve collecting personal information about children.

17. Trade Data And Confidentiality

Our clients and suppliers share commercially sensitive information with us, including pricing, volumes, product specifications, supplier identities and shipment schedules. We treat this information as confidential and use it only for the purpose for which it was provided.

We do not reveal one clients sourcing details to another client, and we do not use a suppliers cost information for the benefit of a competing supplier. Where a programme requires us to share information with a forwarder, broker or inspection partner, we share only what that partner needs in order to complete its task.

Our confidentiality obligations continue after a programme ends. Where a client or supplier has entered into a separate confidentiality agreement with us, the terms of that agreement apply in addition to this policy, and in the event of conflict the stricter protection prevails.

18. Third Party Links

The website may contain links to external sites, such as carrier tracking pages, regulatory resources or industry bodies. These links are provided for convenience, and we do not control the privacy practices of the sites to which they lead.

When you follow an external link, you leave our site and become subject to the privacy policy of the destination site. We encourage you to review the privacy notices of any external site before providing personal information to it.

We are not responsible for the content, security or privacy practices of external sites, and a link from our site does not imply endorsement of the destination or of its practices.

19. Changes To This Policy

We may update this policy from time to time to reflect changes in our practices, in the services we provide or in applicable law. When we make a material change, we will update the effective date shown at the top of this page and, where appropriate, provide additional notice.

The current version of this policy is always available on the website. We encourage you to review it periodically so that you remain aware of how we handle personal information.

Continued use of the website after a policy update indicates that you have reviewed the updated policy. If you do not agree with a change, you may stop using the website and contact us to discuss the records we hold about you.

20. How To Contact Us

Privacy questions, requests and complaints should be directed to our commercial office using the details below. Please include enough information for us to identify the relevant records and to respond substantively.

We take privacy concerns seriously and we will investigate any complaint promptly. If you are not satisfied with our response, you may have the right to refer the matter to the relevant supervisory authority in your jurisdiction.

21. Governing Law

This policy is governed by the laws of Hong Kong Special Administrative Region. Any dispute arising from or connected with this policy is subject to the exclusive jurisdiction of the courts of Hong Kong, without prejudice to any mandatory rights you may have under the law of your place of residence.

Where a client has entered into a separate services agreement with us that contains its own governing law provision, that provision applies to the services relationship, while this policy continues to govern the handling of personal information collected through the website.

22. Summary Of Commitments

For ease of reference, our core privacy commitments are summarised below. This summary does not replace the detailed provisions above, and the detail prevails in the event of any difference.

• We collect only the personal information needed to provide our trade services.
• We use personal information for the purposes described in this policy and no others.
• We do not sell or rent personal information to any party.
• We share information only with providers that help us deliver services, and under contract.
• We protect information with access controls, secure transmission and staff training.
• We retain information only as long as needed or as the law requires.
• We honour access, correction, deletion and objection requests where the law provides them.
• We keep this policy current and publish the effective date at the top of the page.