Privacy Policy for 4supply
Last Updated: March, 2025
What does this Privacy Notice cover?
4supply (“us”, “we”) is committed to protecting your personal data and information. This Privacy Notice contains how 4supply and its affiliates (collectively “4supply”) legally collect and process your personal data through 4supply websites, devices, products, services, online and physical stores, and applications that reference this Privacy Notice (together “4supply Services”). By using 4supply Services, you are consenting to the practices described in this Privacy Notice.
This Notice also contains the content of your personal information, data and privacy protection rights, including the right to object to a number of the processing carried out by 4supply. More content of information about your rights, and how to process them, is set out in the “Your Choices and Rights” section.
The Services are provided or controlled by Lecangs Hong Kong Limited, with its residence at Room 1911, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong.
Residents in the United States might have additional privacy rights under related/applicable data protection laws, which are described in the Section of “Privacy Notice Addendum for US Residents”.
CONTENTS
- How We Collect and Use Your Personal Data?
- How We Share Your Personal Data?
- Cookies & Similar Technology
- Log Files
- Advertising/Direct Marketing
- International Transfer and Storage of Data
- Your Choices And Rights
- Children
- Security
- How Long Do We Retain Your Personal Data？
- Privacy Notice Addendum for US Residents
- Updates to This Privacy Notice
- Contact Us
How We Collect and Use Your Personal Data?
Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data does not include data that has been effectively irreversibly anonymized or aggregated so that it can no longer enable us or others, whether in combination with other information otherwise, to identify you.
In the course of providing and improving our products and services, we collect your personal data for the purposes described in this Privacy Notice. The following are the purposes and types of personal data that we collect:
Information that you provide
When you create an account, browse the Service, place an order at checkout, contact us directly, or otherwise use the 4supply Service, you provide some or all of the following information:To the extent that you disclose or submit personal data pertaining to any third party—such as (1) officers, directors, employees, personnel, partners, agents, or other authorized representatives of any corporate entity or organization on whose behalf you act; and (2) your own customers or clients (each referred to herein as a “Connected Person”)—you hereby represent and warrant that you have duly informed such Connected Persons of the terms set forth in this Privacy Policy and have secured their valid, informed, and explicit consent for the collection, use, retention, processing, and cross-border transfer of their personal data in accordance with the provisions of this Privacy Policy, including any subsequent amendments or updates thereto.
You further acknowledge and agree that we disclaim any liability or responsibility for any claims, damages, or losses arising from or in connection with your failure to obtain such requisite consent from any Connected Person prior to the disclosure or provision of their data.
You shall be solely responsible for ensuring that all information and data you submit is true, accurate, complete, and not misleading. For details on how you may access, review, or rectify your personal data, please refer to the section titled “Your Choices and Rights.”
| Purpose | The personal data we collect | Legal Basis for Processing |
|---|---|---|
| 1.To create an account with us and manage your account,to provide you with our services; 2.To facilitate the provision of the Services, including but not limited to account creation, configuration, maintenance of user profiles, provision of customer support, personalization of user experience, and verification of identity for purposes of security, fraud prevention, record keeping, and system backup. 3.For customer due diligence and onboarding procedures, including the conduct of background screening, Know-Your-Customer (KYC) assessments, anti-money laundering (AML) checks, and other verification processes relating to you, your business, or any Connected Persons. 4.To process and fulfill transactions on your behalf, which includes issuance of invoices, payment collection and settlement, order management, and logistics or delivery of purchased goods and services. 5.For the administration, operation, and renewal of products or services that you have registered for, subscribed to, or otherwise contracted. 6.For business operations and strategic planning, including the development, enhancement, and optimization of our Services; conducting customer feedback surveys and engagement activities; providing customized or tailored support; and analyzing data to verify, protect, and enforce our legal and contractual rights. 7.To evaluate and manage your financial standing, including creditworthiness and payment behavior in connection with our Services; to manage your account on an ongoing basis; and to recover outstanding sums through internal procedures or appointed third-party collection agents. 8.To measure, and enhance advertising, marketing, and promotional efforts relating to the Services. 9.To comply with applicable legal, regulatory, or governmental obligations, including but not limited to disclosure or reporting requirements under any 9.applicable jurisdiction (whether in or outside Hong Kong), and the disclosure of relevant information to regulatory bodies or competent authorities. 10.To protect our legal interests, including the detection, prevention, and mitigation of security breaches, fraudulent activities, misuse of our platform, infringement of intellectual property rights, and other unlawful conduct. 11.To operate, maintain, and upgrade our business infrastructure, which includes testing, administering, and improving technical systems, software, and platforms used in connection with the Services. 12.To identify, analyze, and remediate technical or service-related issues, including troubleshooting, diagnostics, and customer support activities necessary for service continuity and quality. 13.For any additional purposes mutually agreed upon, including those expressly provided in service-specific applications, supplemental terms and conditions, or any ancillary documents, as well as for purposes reasonably incidental or related to those outlined above. | - Contact information: The legal name of the corporate entity or any Connected Person, trade or business name, contact details including but not limited to registered mailing address, electronic mail address, principal place of residence or business, and telephone numbers (fixed-line and mobile); - Business information: Corporate registration number, registration type or classification, valid business license, certificate of incorporation or equivalent registration certificate, registered office address, place of principal business, particulars of legal representatives or authorized signatories, taxpayer identification number, value-added tax (VAT) registration number and certificate (if applicable), jurisdiction of incorporation, date of incorporation, and duration or validity of corporate registration; - Sales information: such as your (or Connected Persons’) resale authorization or permits, screenshots or records of third-party sales platforms or e-commerce stores, sales platform details; - Bank account information: including, without limitation, details of financial accounts held by you or any Connected Person, as well as designated recipient or beneficiary accounts, encompassing information such as banking institution name, primary and subsidiary bank codes, jurisdiction of the financial institution, type of account, and corresponding account numbers; - Transaction information: including, but not limited to, the date on which the transaction was executed, unique transaction reference or identifier, classification or nature of the transaction, details of the receiving financial account (comprising the name of the financial institution, relevant banking codes, branch or regional identifiers, type of account, and account number), the currency in which the transaction was settled, and the stated purpose or intended use of funds; - Know Your Client (KYC) information: including, without limitation, the current status of Know-Your-Customer (KYC) verification and the date on which the most recent KYC review or assessment was completed. | 1.Necessary for the performance of a contract or to take steps at your request prior to entering into a contract, and for provision of customer services. 2.We have obtained your explicit consent to process your personal information. 3.Processing is necessary to fulfill a legal duty that applies to us, such as tax reporting requirements or responding to a subpoena. 4.Protecting the vital interests of an individual or as part of public interest tasks. For example, processing data to provide emergency medical care if someone’s life is at risk, though this is less commonly invoked in typical business contexts compared to other bases. 5.Legitimate interest (e.g., detecting and preventing fraud, conducting internal analytics for business improvement) where such processing doesn’t outweigh the individual’s privacy rights and interests. |
Our platform, websites, and associated digital content may include hyperlinks or references to external services or websites that are owned, managed, or operated by third parties. Any engagement you may have with such third-party platforms—including the submission or provision of your personal data—is governed by the respective terms of use and privacy policies of those third parties. We strongly advise you to carefully examine such policies in order to understand how your personal data may be collected, processed, or otherwise handled by those external parties.
This Privacy Policy governs only the data and information collected directly by us through our own systems and does not extend to the data handling practices or services provided by any unrelated third party. We disclaim all responsibility and liability for the use, handling, or protection of any data voluntarily submitted by you to third parties, whether accessed through our platform or otherwise.
How we share your personal data
We do not sell any Personal Data to third parties and we never will.
We might share your data with the following recipients:
| The personal data we collect | Recipient | Purpose |
|---|---|---|
| Identification and Contact Information, Delivery Details, Order Information. | (a)Our business partners, professional advisers, representatives, agents, vendors, contractors, and third-party service providers, engaged to support or facilitate the delivery, administration, or enhancement of the Services. This includes, but is not limited to, providers of hosting services, transaction and payment processing, logistics and delivery of promotional or commercial items (e.g., rewards or vouchers), cloud computing infrastructure, electronic communications, marketing, analytics, survey administration, and research services; (b) Relevant financial institutions, payment networks, card-issuing institutions, credit agencies, credit information providers, credit assessment bodies, debt recovery agencies, and security service providers, to the extent necessary to process, verify, or enforce payment obligations relating to the Services; (c) Governmental, regulatory, judicial, or law enforcement authorities, bodies or agencies, or other entities having legal jurisdiction, to the extent disclosure is required or permitted under applicable laws, regulations, court orders, or other legal or regulatory directives; | Our legitimate interest and necessary to perform the contract and/or 4 Supply Services. |
Cookies & Similar Technology
A "cookie" refers to a small data file comprising a sequence of characters, which may be stored on your mobile device—including smartphones, tablets, or other wireless equipment—upon accessing our website or associated digital content. From time to time, we, together with our authorized third-party analytics or tracking service providers, may automatically collect certain information through the use of cookies and analogous tracking mechanisms, which may be recorded and retained as part of system-generated log data.
We may deploy cookies and comparable technologies across our digital platforms for multiple operational and functional purposes, including but not limited to:
(a) User recognition and session continuity – for example, cookies enable us to recognize returning users, identify individuals who have registered with our site, and retain user-configured settings or previously submitted data to streamline future interactions;
(b) System integrity and fraud mitigation – such technologies are also employed to support platform security, detect unauthorized access, and prevent fraudulent or malicious activities.
Log Files
We may collect certain technical and non-personally identifiable data automatically and record such information in server-generated log files. This data recognized by our web infrastructure upon your interaction with our digital platforms may include, without limitation, numerical Internet Protocol (IP) addresses (which serve to uniquely identify your device online), browser specifications, internet service provider (ISP) details, referring and exit URLs, operating system characteristics, timestamps of access, and navigation patterns or clickstream behavior.
Such system-generated information, which is not used to directly identify any individual user, may be utilized for the purposes of analyzing usage patterns, optimizing performance, maintaining system functionality, and administering the website or related online content. We do not associate or correlate this passively collected technical data with any information that directly identifies you as an individual.
Advertising / Direct Marketing
Where you have expressly opted in to receive direct marketing communications from us, we may utilize your personal data (or that of Connected Persons) for the purpose of disseminating promotional materials, marketing content, or informational updates regarding our organization and/or relevant offers. These communications may relate to products and services offered by us, our affiliated or subsidiary entities, and select commercial partners. The scope of such marketing may include, but is not limited to:
(a) services provided by us and by our affiliates, subsidiaries, and authorized business collaborators, particularly those related to payment facilitation, transaction settlement, or similar financial processing activities;
(b) offerings from third-party service providers engaged in areas connected to the above-mentioned services or other goods and services we reasonably believe may be of interest to you.
Such communications may be delivered through electronic channels, including but not limited to email newsletters and marketing emails. Your (or any Connected Person’s) data will be retained for marketing purposes only for so long as you continue to indicate your preference to receive such materials.
You may revoke your consent to receive direct marketing at any time by: (i) contacting our designated Privacy Officer at [service@4supply.com]; or (ii) following the opt-out mechanism included in our marketing messages.
Please note that your data will not be disclosed to external advertising entities without your prior explicit consent.
For the avoidance of doubt, your consent to receive marketing materials shall be treated as distinct from any consent provided in relation to your use of our Services. Accordingly, such marketing consent may be withdrawn independently and at any time in accordance with this Privacy Policy, and shall remain valid notwithstanding the termination or expiry of any service agreements entered into with us.
International Transfer and Storage of Data
We process and store your personal information on servers located in Hong Kong or other jurisdictions, depending on your location and how you use our services. By using our platform, you consent to the transfer of your data to locations outside of Hong Kong for the purposes described in this Privacy Policy, including those reasonably related to providing our services.
If you provide us with personal information about third parties (such as employees, agents, or other Connected Persons), you confirm that you have obtained their consent to share and transfer their information internationally as described here.
Any such transfers will comply with applicable data protection laws, including relevant obligations under U.S. privacy regulations where applicable.
We are committed to protecting your information and implement reasonable administrative, technical, and physical safeguards designed to secure personal data from unauthorized access, disclosure, alteration, or destruction. For example, we may use encryption technologies like SSL to protect sensitive data.
However, no security system is entirely foolproof. While we strive to protect your data, we cannot guarantee the complete security of information transmitted over the internet. External factors beyond our control may affect the security of networks and systems used to access our services.
Your Choices And Rights
You have the following rights:
| Right | Summary |
|---|---|
| The right to access information | Enables you to receive information regarding whether we are processing your personal data |
| The right to rectification | Enables you to correct any inaccurate or incomplete personal data we hold about you |
| The right to erasure | Enables you to ask us to delete your personal data in certain circumstances |
| The right to restrict processing | Enables you to ask us to halt the processing of your personal data in certain circumstances. You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request. |
| The right to object | Enables you to object to us processing your personal data on the basis of our legitimate interests (or those of a third party), including processing for direct marketing purposes - your objection will be upheld, and we will cease processing your personal data, unless the processing is based on compelling legitimate grounds or is needed for the exercise or defence of legal claims that may be brought by or against us |
| The right to data portability | Enables you to request us to transmit personal data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible |
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.
If you wish to exercise any of these rights, please contact us at the contact details set out below.
Wherever we rely on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. We may however have other legal grounds for processing your data for other purposes, such as those set out above.
Children
The Service is not intended for use by anyone who is under the age of 18 or a minor (as defined by applicable law). If you are a parent or guardian of a child about whom you believe we have collected personal data, please contact us directly. If we learn that we have collected personal data through the Service from a child or without the knowledge of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Security
We protect your personal data from loss, misuse, disclosure, alteration, unavailability, unauthorized access and destruction and maintain the confidentiality of your personal data. This is also ensured using appropriate technical and organizational measures. We choose our security measures taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons and continuously improve them.
The Internet is not an absolutely secure environment. We strongly recommend that you use a secure method and use a complex password to help us ensure the security of your account. We also strongly advise that you neither share your password with others nor re-use passwords on our Services that you use on other sites or apps, as doing so increases the likelihood of your being the victim of a credential stuffing attack or other malicious cyber behavior. If you feel that the security of your account or personal data has been compromised, please immediately contact us as described in the Contact Us section below.
Only duly authorized employees, agents, or subcontractors with a legitimate need to access such data will be granted access, and they shall be bound by obligations of confidentiality and data protection consistent with this Privacy Policy.
How Long Do We Retain Your Personal Data？
In accordance with applicable legal and regulatory requirements, we shall retain your data and that of any Connected Persons only for the duration necessary to achieve the purposes outlined in the section titled "How We Collect and Use Your Personal Data?" Once those purposes have been fulfilled, or where your account is closed or otherwise terminated for any reason, we will, subject to prevailing laws and any legitimate operational or archival obligations, implement appropriate measures to ensure that such data is no longer accessible via our Services or otherwise processed by us. This will be done within a timeframe that is commercially reasonable and consistent with our internal data retention protocols.
We only maintain the personal data we collect for as long as it is necessary for us to provide our services, for as long as it is required to fulfil the purposes of the processing of personal data, or as required by law.
We determine the retention period of personal data based primarily on the following criteria:
1. To fulfill the purposes described in this Privacy Notice;
2. Whether you have agreed to a longer retention period;
3. Based on the needs related to the statute of limitations for litigation;
4. Whether there are other special agreements or legal regulations concerning the retention period.
After exceeding the retention period, we will delete or anonymize your personal data in accordance with applicable laws.
Privacy Notice Addendum for US Residents
Residents of certain US states may have additional privacy rights under applicable state privacy laws. US users can learn more about which rights may be available to them and how to exercise those rights by reviewing US Privacy Notice Addendum for US Residents.
Updates to This Privacy Notice
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Contact Us
The data controller for your personal information is Lecangs Hong Kong limited, with address Room 1911, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong.
If you have questions about this Privacy Notice or wish to contact us for any reason in relation to our personal data processing, please contact us at[service@4supply.com. If you have any questions, you can also contact our data protection officer at[service@4supply.com.
Privacy Notice Addendum for US Residents
Last updated: March, 2025
This US Privacy Addendum (“US Notice”) supplements the 4supply Privacy Notice (“Privacy Notice”) and the Cookie and Similar Technologies Policy and provides additional detail for residents of certain US states on how we collect, use and disclose Personal Information, and the rights such residents may have with respect to that Personal Information. Because of differences in certain state laws, this supplement is broken into two sections, California Residents, applicable to California residents only, and Residents of Other States, applicable to residents of other states with consumer privacy laws requiring such information.
For purposes of this US Notice, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), as well the meaning given to “personal information” under other US state privacy laws. Unless otherwise specified, Personal Information includes “sensitive personal information” as defined by the CCPA and “sensitive data” as defined by other US state privacy laws.
Processing of Personal Information
The following chart describes our collection, use, and disclosure of Personal Information during the past 12 months. This chart summarizes the Personal Information we collect and the categories of third parties to whom we may have disclosed such information. The purposes for which we use these categories of Personal Information listed in the below table are described further in the “How We Collect and Use Your Personal Data” section of our Privacy Notice. Our relevant data retention practices are also addressed in the “How Long Do We Retain Your Personal Data” section of our Privacy Notice.
| Category of Personal Information | Categories of Third Parties to Whom Personal Information Has Been Disclosed for Business Purposes | Categories of Third Parties to Whom Personal Information Has Been Sold or Shared for Targeted Advertising |
|---|---|---|
| Identifiers, such as name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address or other similar identifiers. | logistics service provider; U.S. legal and other U.S. regulatory authorities | We do not sell and will not your personal information |
I. California Residents
If you are a California resident, this section applies to you in addition to the rest of the Privacy Notice. It provides more detail on how we collect, use and disclose Personal Information of California residents in operating our business, and their rights with respect to that Personal Information.
Sensitive Personal Information and De-identified Data
4supply does not use or disclose Sensitive Personal Information (as defined by the CCPA) for purposes other than those expressly permitted under the CCPA. Additionally, we do not to attempt to re-identify de-identified information that we derive from Personal Information, except for the purpose of testing whether our de-identification processes comply with applicable law.
The Sale of Personal Information
We do not and will not sell Personal Information we collect for the identified purposes.
Your California Privacy Rights
As a California resident, you may have the rights listed below in relation to Personal Information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
| Right to Know / Access | The right to request information about the categories of Personal Information we collect, the categories of sources from which we collect it, the purposes for which we process it, the categories of third parties to whom we disclose it, and the specific pieces of Personal Information we have collected about you. |
| Right to Delete | You can request that we delete personal information we collected from you and tell our service providers to do the same, subject to certain exceptions (such as if we are legally required to keep the information). |
| Right to Correct | The right to request that we correct inaccurate Personal Information we maintain about you. |
| Right to Opt Out of Sale or Sharing | The right to opt out of selling your Personal Information and sharing your Personal Information for targeted advertising. We cannot sell or share your personal information after we receive your opt-out request unless you later authorize us to do so again.For information on how we process opt-out preference signals, see the section above, The Sale and Sharing of Personal Information. |
| Right Against Discrimination | The right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising or requesting to exercise your privacy rights noted above. |
You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. For requests other than opting out of sales and sharing, we may need to collect information from you to verify your identity, before providing a substantive response to the request. You may also designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
II. Residents of Other States
If you are a California resident, please see the section above, California Residents, for information on your rights in relation to information that we have collected about you. If you are a resident of another US state, this section may apply to you in addition to the rest of the Privacy Notice. Depending on the state you live in, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law, including in the event you reside in a state that does not currently grant you these rights.
| Right to Know / Access | The right to request information about the categories of Personal Information we collect, the categories of sources from which we collect it, the purposes for which we process it, and the categories of third parties to whom we disclose it. |
| Right to Delete | The right to request that we delete Personal Information we collected from you. |
| Right to Correct | The right to request that we correct inaccurate Personal Information we maintain about you. |
| Right to Opt Out of Sale | The right to opt out of the “selling” (as defined under applicable law) of your Personal Information |
You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. For certain rights, we may need to collect information from you to verify your identity, such as your email address, before providing a substantive response to the request. Depending on your location, you may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
Colorado Privacy Act Profiling Disclosure.
4supply does not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under the Colorado Privacy Act.
Contact Us
Should you have any questions about our privacy practices or this Privacy Notice, please email us at service@4supply.com or contact us by mail at following address: Lecangs Hong Kong limited, with address at Room 1911, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong.