Mulanhill Cross-border E-commerce Platform (hereinafter referred to as the “Platform”, official website:
www.mulanhill.co.uk) attaches great importance to user privacy and data security, and strictly complies with the UK Data Protection Act, the EU General Data Protection Regulation (GDPR), the Personal Information Protection Law of the People’s Republic of China, and other relevant laws and regulations. The Platform is committed to protecting the personal information provided by users when using the Platform’s services. This Privacy Policy clearly informs users how the Platform collects, uses, stores and protects personal information, as well as the relevant rights enjoyed by users. Please read and understand this Policy carefully before using the Platform’s services.
1. Scope of Application
This Privacy Policy applies to all service scenarios of the Platform, including but not limited to personal information processing involved in user account registration, product browsing, order placement and payment, logistics tracking, after-sales consultation and other operations. Where the Platform cooperates with third parties to provide services (such as payment institutions and logistics service providers), the third parties’ information processing rules shall be governed by their own independent privacy policies, for which the Platform shall not be liable. Users are advised to review the third parties’ privacy policies.
2. Information Collection and Use
(1) Types of Information Collected
Account registration and identity verification information
When registering a Platform account, users are required to provide their name, email address, mobile phone number, and account password. If users need to conduct cross-border payments or real-name verification (e.g., identity verification required for some orders to meet customs clearance requirements), they may be required to supplement their ID number, bank card number (only for payment verification; the Platform does not store complete bank card information) and other information. Such information is used for account creation, identity verification, account security protection, and compliance with legal requirements.
Shopping and order information
When placing an order, users are required to provide a delivery address (including province/city/district, detailed street, postal code), recipient name and contact information. The Platform will automatically record ordered products, order amount, payment method, order time, order status and other information. Such information is used to process orders, arrange logistics delivery, send order notifications (e.g., shipping reminders, delivery reminders) and provide after-sales service.
Browsing and usage behavior information
The Platform may collect users’ browsing records (e.g., product categories viewed, duration of stay), search keywords, device information (e.g., device model, operating system, browser type, IP address), network environment (e.g., Wi‑Fi/mobile network) and other non-identifying information through technical means. Such information is used to optimize Platform functions (e.g., personalized product recommendations), improve page loading speed, analyze user needs to enhance service experience, and is usually used in an anonymized and aggregated form without being linked to specific user identities.
Communication and feedback information
When users communicate with the Platform via online customer service, email, message or other channels, the Platform will record the content of communication, feedback issues and processing results. If users participate in Platform questionnaires or event registration, they may need to provide relevant information mentioned in the questionnaire (e.g., preferences, needs). Such information is used to resolve user issues, respond to demands and optimize services.
(2) Purposes of Information Use
The personal information collected by the Platform is only used for the following legitimate purposes and will not be used beyond the scope without the user’s explicit consent or as permitted by laws and regulations:
- To provide users with core Platform services (e.g., account management, order processing, logistics tracking, after-sales support);
- To ensure the security of transactions between the Platform and users (e.g., identifying abnormal logins, preventing fraud);
- To optimize user experience (e.g., recommending products based on browsing habits, simplifying operation processes);
- To send necessary notifications (e.g., account security alerts, order status updates, policy change notices, non-marketing information);
- To comply with laws, regulations and regulatory requirements (e.g., assisting customs clearance, tax declaration, responding to judicial inquiries);
- To conduct Platform operation analysis and service improvement (based on anonymized data, without involving personal identity information).
3. Information Storage and Protection
(1) Storage Method and Term
The Platform stores users’ personal information on servers that meet security standards, located in the UK and Chinese mainland (distributed according to business needs and regulatory requirements), and adopts encryption technologies (e.g., SSL/TLS encrypted transmission, encrypted data storage) to ensure information security.
The information storage period follows the principle of “minimum necessity”: stored for the period necessary to achieve the purpose of information use, or for a longer period as required by laws and regulations (e.g., order information shall be retained for 3 years after transaction completion to meet after-sales and compliance needs). Upon expiration, the Platform will destroy the information through anonymization or permanent deletion to ensure it is no longer linked to user identity.
(2) Security Protection Measures
Technical level: The Platform adopts firewalls, intrusion detection systems, data backup mechanisms and other technical means to prevent information leakage, loss, tampering or unauthorized access. Sensitive data such as payment information is only transmitted to compliant payment institutions, and the Platform does not store complete sensitive payment information.
Management level: The Platform has established a strict information security management system, restricts internal personnel’s access to user information (only authorized necessary positions), and provides privacy protection training for employees. It regularly conducts information security audits and risk assessments to promptly fix potential security vulnerabilities.
Emergency response: In the event of a security incident such as information leakage or loss, the Platform will immediately activate an emergency plan, take remedial measures, and notify users and regulatory authorities in accordance with legal requirements, informing them of the incident and response measures.
4. Information Sharing and Disclosure
The Platform undertakes not to sell or rent users’ personal information to any third party, and only shares or discloses it in the following limited circumstances, while ensuring that third parties comply with privacy protection requirements:
- Sharing with cooperative service providers: To realize service functions (e.g., payment institutions processing payments, logistics providers delivering goods, third-party customer service providing support), the Platform will provide necessary information to partners (e.g., logistics providers need delivery addresses, payment institutions need order amounts), and only provide the minimum scope of information required to realize services, while restricting partners from disclosing or misusing information through agreements.
- Legal requirements: The Platform may disclose user information to judicial authorities, regulatory agencies and other third parties in compliance with laws, regulations, judicial judgments or administrative orders, and will strictly provide information in accordance with requirements and record the disclosure.
- Protection of legitimate rights and interests: The Platform may disclose information within a reasonable scope to protect the legitimate rights and interests of the Platform or users (e.g., preventing fraud, resolving disputes).
- User explicit consent: The Platform may share information as instructed by users upon their active authorization or consent (e.g., users allow the Platform to use information for specific cooperative activities).
5. User Rights
In accordance with relevant laws and regulations, users enjoy the following rights with respect to their personal information, and the Platform will provide convenient ways for users to exercise such rights:
- Right to access and correct: Users may log in to their Platform account and view their personal information (e.g., account information, order records) in “Personal Center”. If information is found to be incorrect or incomplete, users may modify it by themselves (e.g., update delivery address) or contact customer service for assistance.
- Right to deletion: Users may apply to the Platform for deletion of personal information if the purpose of information use has been achieved, the storage period has expired, or users no longer use the Platform’s services (apply for account cancellation). The Platform will delete the information within a reasonable period after verification (except for information required to be retained by laws and regulations).
- Right to withdraw consent: Users may withdraw consent to information use at any time (e.g., cancel marketing information push), but withdrawal may affect the use of some non-core services (e.g., unable to receive product activity notices after cancellation, without affecting order processing).
- Right to account cancellation: Users may apply for account cancellation through Platform customer service, and shall ensure no pending orders or unpaid amounts before cancellation. After account cancellation, the Platform will delete or anonymize users’ personal information (except for information required to be retained by laws and regulations), and cancellation is irreversible.
- Right to objection and complaint: If users object to the Platform’s information processing or believe that information security is threatened, they may complain through Platform customer service channels (e.g., customer service email, online customer service). The Platform will reply with the processing result within 15 working days.
6. Protection of Minors’ Information
The Platform does not provide independent registration services to minors (under 18 years of age according to UK and Chinese mainland laws). If minors need to use the Platform, they must be accompanied by a guardian, who shall provide account information and assist in operations. The Platform only collects necessary information (e.g., delivery address) for minors’ shopping needs with the guardian’s consent, and strengthens protection to avoid leakage. Guardians may contact the Platform to access, correct or delete information related to minors.
7. Policy Update and Notice
The Platform may update this Privacy Policy from time to time according to changes in laws and regulations, business adjustments or user needs. The updated Policy will be posted in a prominent position on the Platform’s official website (e.g., “Privacy Policy” entrance at the bottom of the homepage), with the update date marked on the page. If the Policy undergoes material changes (e.g., adjustment of information collection scope or use purposes), the Platform will remind users to review it via account notice, email or other means. Users’ continued use of the Platform’s services shall be deemed as consent to the updated Privacy Policy.
8. Contact Us
If users have questions about this Privacy Policy, or need to exercise information-related rights or make complaints and feedback, they may contact the Platform through the following channels:
- Official customer service email: support@mulanhill.com
- Online customer service: log in to www.mulanhill.co.uk and enter “Help Center – Online Customer Service”
- Contact address: London, UK [fill in the actual address of the Platform]
The Platform will respond to user inquiries on working days (Monday to Friday, 9:00–18:00 GMT) to ensure timely resolution of issues.