Data protection notice for third parties (O_IS_CN2)

August 2026

 

This Data Protection Notice sets out the basis on which Technoform Bautec (Suzhou) Thermal Insulation Materials Co., Ltd. collects, uses, discloses or otherwise processes the personal information of third parties, in accordance with the Personal Information Protection Law (“PIPL”) and, where relevant, the Cybersecurity Law (“CSL”) and the Data Security Law (“DSL”). It applies to personal information in our possession or under our control, including personal information held by organisations we have engaged to process it on our behalf.

In this Notice, “third party” means an individual who is not our employee, customer, job applicant or business partner, but whose personal information we may process in connection with our business activities — including individuals who contact us, emergency contacts, authorised representatives, visitors, witnesses, complainants, or individuals identified in correspondence or contractual documentation. “personal information” means all kinds of information, recorded electronically or otherwise, related to an identified or identifiable natural person, excluding information that has been anonymised.

1  Data Controller 

The organisation responsible for the processing of your personal data is:

Technoform Bautec (Suzhou) Thermal Insulation Materials Co., Ltd.
283, Qing Qiu Street, Modern Avenue East, 
S.I.P. Suzhou 215024, P.R.C.

T +86 512 6283 3188
E info [dot] tesg [at] ap [dot] technoform [dot] com (info[dot]tesg[at]ap[dot]technoform[dot]com)

For any questions regarding data protection, you may contact our Data Protection Contact using the details set out in Section 5 at any time.

2  Purpose and legal basis

We collect and process personal information where permitted or required under the PIPL, including where necessary for the conclusion or performance of a contract, compliance with legal obligations, or where separate consent has been obtained. Depending on the nature of your interaction with us, the personal information we may collect includes your name, email address and telephone number.

Where we process sensitive personal information, we will only do so where there is a specific purpose and sufficient necessity, and in accordance with applicable legal requirements. Where required, we will obtain your separate consent.

We may collect and use your personal information for any or all of the following purposes: performing obligations in the course of, or in connection with, our provision of goods and/or services to our customers; verifying your identity; responding to, handling and processing queries, requests, applications, complaints and feedback from you; fraud detection and prevention; complying with any applicable laws, regulations, codes of practice, guidelines or rules, or to assist in law enforcement and investigations conducted by any governmental or regulatory authority; and any other purposes for which you have provided the information.

We process your personal information based on one or more of the following legal bases under the PIPL:

  • where necessary for the conclusion or performance of a contract to which you are a party;
  • where necessary for compliance with legal obligations or statutory duties;
  • where necessary to respond to a public health emergency or to protect the life, health or property of a natural person;
  • where your separate consent has been obtained; or
  • other circumstances permitted under applicable laws and administrative regulations.

3  Recipients of personal information

We will only disclose your personal information where necessary to fulfil the purposes set out above, and only to the following categories of recipient: affiliated companies within the Technoform Group; professional advisers; IT service providers; and government authorities where required by law. Where we entrust a third party to process personal information on our behalf, we enter into an agreement governing the scope, purpose and protection measures, consistent with the PIPL and this Notice.

4  Your rights

Subject to the PIPL and applicable exceptions, you have the following rights in relation to your personal information:

4.1  Withdrawal of consent

Where processing is based on your consent, that consent remains valid until withdrawn in writing. You may withdraw consent for any or all of the purposes above by submitting a written request to our Data Protection Contact, and we shall generally seek to process your request within ten (10) business days. Please note that, depending on the nature and scope of your request, we may be unable to continue providing our goods or services to you, in which case we will notify you before completing the processing of your request. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal, or our right to continue processing where permitted or required under applicable law.

4.2  Access and correction

Under the PIPL, you have the right to request access to, and correction of, your personal information held by us. Such requests should be submitted in writing to our Data Protection Contact. A reasonable fee may be charged for an access request, and we will inform you of the fee beforehand. We will generally respond within twenty-one (21) business days; if we are unable to do so within thirty (30) days, we will inform you in writing of the time by which we will respond.

4.3  Accuracy of personal information

We generally rely on the personal information provided by you (or your authorised representative). To ensure your personal information remains current, complete and accurate, please inform our Data Protection Contact in writing of any changes to your personal information.

4.4  Protection of personal information

To safeguard your personal information from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have implemented appropriate administrative, physical and technical measures. These include minimised collection of personal information, authentication and access controls, encryption, data anonymisation, up-to-date antivirus protection, regular patching, secure disposal of storage media, and the use of two-factor or multi-factor authentication, together with regular security reviews and testing. While no method of transmission or storage is completely secure, we continually review and enhance our information security measures.

4.5  Retention of personal information

We retain your personal information only for the minimum period necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable law. In general, third-party personal information is retained for up to three (3) years after the conclusion of the matter to which it relates, unless a longer period is required or permitted by law. We will cease to retain your personal information, or remove the means by which it can be associated with you, as soon as it is reasonable to assume that retention no longer serves those purposes.

4.6  Cross-border transfers

We generally store personal information within mainland China. Where a cross-border transfer of personal information is necessary, we will first satisfy one of the following conditions under the PIPL: (a) enter into the Standard Contract issued by the Cyberspace Administration of China (CAC); (b) obtain personal information protection certification; or (c) complete a CAC security assessment. Where personal information is transferred outside China, we will inform the affected individuals of the identity of the overseas recipient, the purpose of the transfer, the categories of personal information transferred, and how they may exercise their rights, and we will obtain your separate consent where required by law.

4.7  Data localization

Where applicable under the CSL, DSL and PIPL, organisations that are required to localise personal information or important data within mainland China will comply with the applicable localisation requirements.

4.8  Data breach notification

In the event of a personal information breach, leakage, tampering or loss, we will promptly take remedial measures and notify the competent authorities and the affected individuals where required under applicable laws and regulations.

4.9  Direct marketing

We do not use your personal information for direct marketing unless we have obtained your explicit consent where required by applicable law. You may withdraw such consent at any time by contacting our Data Protection Contact.

5  Your rights under the PIPL

Under the PIPL, you have the right to:

  • know about, and decide on, the processing of your personal information, including to limit or refuse its processing by others;
  • access and obtain a copy of your personal information;
  • correct or supplement your personal information where it is inaccurate or incomplete;
  • delete your personal information in the circumstances provided under the PIPL;
  • withdraw your consent where processing is based on consent;
  • request an explanation of our personal information handling rules; and
  • exercise any other rights conferred under the PIPL.

To exercise any of these rights, please contact our Data Protection Contact using the details in Section 5. We will respond in accordance with the PIPL, generally within twenty-one (21) business days; if we are unable to do so within thirty (30) days, we will inform you in writing of the time by which we will respond.

6  Data Protection Contact

You may contact our Data Protection Contact if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request in relation to your personal data:

Contact number: +86 512 6283 3188
Email: info [dot] tesg [at] ap [dot] technoform [dot] com (info[dot]tesg[at]ap[dot]technoform[dot]com)

All enquiries sent to this mailbox will be reviewed and handled by our designated compliance staff in accordance with the PIPL.

7  Validity and modification of this Notice

This Notice is currently valid (see date in the heading) and applies in conjunction with any other policies, notices, contractual clauses and consent clauses relating to the collection, use and disclosure of your personal information by us. Due to the further development of our offerings, or changes in legal or regulatory requirements, it may become necessary to amend this Notice from time to time. You may determine whether any revision has taken place by referring to the date on which this Notice was last updated. Where changes materially affect your rights and interests, we will notify you through appropriate means before such changes take effect, where required by applicable law. Your continued use of our services constitutes your acknowledgement and acceptance of any such changes.