Privacy & Cookies Policy
Last Updated: 2023-12-01

Data Controller: INC (SHANGHAI) CONSULTING & MANAGEMENT LTD (“we,” “us,” or “our”)
Website: www.incinvestment.net
Business Registration: License Number 913101135707798613
Registered Address: Room 826, Building 3, Lane 1333, Xinlong Road, Vanke Hongqiao CBD, Min Hang District, Shanghai 201101, P.R. China.

1. Introduction
This Privacy & Cookies Policy explains how we collect, use, disclose, and protect your personal information when you visit our website www.incinvestment.net (the “Site”) or interact with us.

We are committed to protecting your privacy and handling your data in an open and transparent manner in compliance with the Personal Information Protection Law (PIPL) of the People’s Republic of China, the Cybersecurity Law, the Data Security Law, and other applicable regulations.

By using our Site, you consent to the practices described in this policy.

2. Information We Collect
We collect information that you provide directly to us and information collected automatically.

A. Information You Provide:

Contact Information: Name, email address, phone number, company name, job title when you submit forms (e.g., “Contact Us,” newsletter sign-up).

Communications: Records of your correspondence with us.

Inquiry Details: Information about your inquiries, requests, or project interests.

B. Information Collected Automatically (Cookies & Similar Technologies):

Device & Log Information: IP address, browser type, operating system, pages viewed, time and date of visits, and referring website addresses.

Cookies & Tracking Data: Small data files stored on your device. We use both session (temporary) and persistent (longer-term) cookies. For details, see the Cookies section below.

3. Legal Basis & Purposes of Processing
Under the PIPL, we process your personal information based on one or more of the following legal bases:

Your consent (e.g., for non-essential cookies or marketing communications).

The necessity for the conclusion or performance of a contract to which you are a party.

The necessity for compliance with a legal obligation.

The necessity for our legitimate business interests, provided such interests are not overridden by your rights and interests.

We use your information for the following purposes:

To respond to your inquiries and provide requested services or information.

To operate, maintain, and improve our Site and services.

To send administrative information, such as updates to our policies.

For security, fraud prevention, and to comply with applicable Chinese laws and regulations.

For marketing communications (only with your explicit prior consent).

4. How We Use Cookies
What are Cookies? Cookies are small text files placed on your device to collect standard internet log and visitor behavior information.

Types of Cookies We Use:

Essential/Strictly Necessary Cookies: Required for the Site to function (e.g., security, basic functionality). These do not require consent.

Performance/Analytical Cookies: Help us understand how visitors interact with the Site (e.g., Google Analytics). We anonymize this data where possible.

Functionality Cookies: Allow the Site to remember choices you make (e.g., language preference).

Targeting/Advertising Cookies: May be set by third parties to track across websites for marketing purposes. We do not currently use these cookies without explicit, separate consent.

Your Cookie Choices: Most web browsers allow you to manage your cookie preferences through their settings. You can set your browser to refuse cookies or alert you when cookies are being sent. Please note that blocking essential cookies may affect the functionality of the Site.

5. Sharing & Disclosure of Information
We do not sell, trade, or rent your personal information to third parties. We may share it only in the following circumstances:

With your explicit consent.

With service providers (e.g., IT hosting, analytics) who process data on our strict instructions under contractual agreements ensuring confidentiality and security (as required by PIPL Article 21).

If required by law, regulation, or legal process, or to protect the rights, property, or safety of our company, our clients, or others.

In connection with a corporate transaction, such as a merger or sale of assets.

Any cross-border transfer of personal information will be carried out in strict compliance with the cross-border transfer rules under the PIPL.

6. Data Security
We implement appropriate technical and organizational measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, and secure data storage protocols.

7. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law (e.g., for tax, accounting, or compliance purposes).

8. Your Rights Under the PIPL
As a data subject under the PIPL, you have the following rights regarding your personal information:

Right to Know & Access: To know and request a copy of your personal information we hold.

Right to Correct: To request correction of inaccurate or incomplete information.

Right to Delete: To request deletion of your personal information under certain conditions (e.g., when it is no longer necessary for the purposes collected).

Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.

Right to Explanation: To request an explanation of the processing rules.

Right to Portability: To request a copy of your information in a structured, commonly used format.

To exercise these rights, please contact us using the details in Section 10. We may need to verify your identity before processing your request.

9. Third-Party Links
Our Site may contain links to other websites. This policy applies only to our Site. We are not responsible for the privacy practices or content of third-party sites. We encourage you to read the privacy policies of any external sites you visit.

10. Contact Us
For any questions, concerns, or requests regarding this Privacy & Cookies Policy or to exercise your PIPL rights, please contact our designated privacy contact:

INC (SHANGHAI) CONSULTING & MANAGEMENT LTD
Data Protection Contact
Address: Room 826, Building 3, Lane 1333, Xinlong Road, Vanke Hongqiao CBD, Min Hang District, Shanghai 201101, P.R. China.
Email: [Insert dedicated privacy email, e.g., privacy@incinvestment.net]

11. Policy Updates
We may update this policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. The updated version will be posted on this page with a revised “Last Updated” date. We encourage you to review this page periodically.