Privacy Policy

1. Introduction

This Privacy Policy explains how Zhongdu International Intellectual Property Agency Co., Ltd. ("we", "us") collects, uses, stores, discloses and protects personal information when you visit portal.mycntm.com (the "Site") or use our trademark services (the "Services").

We handle personal information in accordance with the Personal Information Protection Law of the People's Republic of China (PIPL), the Cybersecurity Law and the Data Security Law. Where you are located in the European Economic Area, the United Kingdom or another jurisdiction with its own data protection law, we also take that law into account in how we handle your information.

This Policy should be read together with our Terms of Service, which govern the Services themselves.

2. Who We Are

For the purposes of the PIPL, we are the personal information processor (and, in GDPR terms, the data controller) in respect of the information described in this Policy.

3. Information We Collect

We do not knowingly collect information about your race, religion, political opinion, health, biometric characteristics or sexual orientation, and none of it is required for the Services. Please do not send it to us.

4. Why We Use It

We use your personal information for the following purposes:

• To provide the Services — to run trademark searches, prepare and translate documents, file and prosecute applications, and report progress to you.
• To communicate with you — to answer enquiries, send quotations and order confirmations, and forward official correspondence from CNIPA.
• To take payment and keep accounts — to invoice you, reconcile payments and meet our accounting and tax obligations.
• To meet legal and regulatory duties — in particular the record-keeping and client-verification obligations that apply to a trademark agency filed of record with CNIPA, and our duties under anti-money-laundering and Know-Your-Client rules.
• To improve the Site — to understand how visitors use the Site and to fix faults.
• To protect our legal position — to establish, exercise or defend legal claims, and to keep evidence of instructions given.

Where the PIPL or another applicable law requires consent — for example for certain cross-border transfers, or for marketing messages — we will ask for it separately, and you may withdraw it at any time.

We do not use your personal information for automated decision-making that produces a legal effect on you, and we do not sell it.

5. Cross-Border Transfer to China

By instructing us or submitting an enquiry, you consent to that transfer and processing for the purposes set out in section 4.

We take the following steps to protect information transferred in this way:

• access is restricted to our own personnel and to translators and advisers who need it;
• documents are transmitted over encrypted channels wherever the receiving system supports it;
• we do not disclose your information to any overseas recipient except as described in section 6; and
• where a transfer requires a separate consent, a standard contract or a security assessment under Chinese law, we will put that in place before transferring.

You may withdraw your consent to cross-border processing by writing to us. If you do, we may be unable to continue providing the Services, because a Chinese trademark application must be filed by a Chinese agency through Chinese systems.

6. Who We Share It With

We do not sell, rent or trade your personal information. We disclose it only to:

• CNIPA and other authorities — because a trademark application cannot be filed without giving the applicant's name, address and the mark to the Trademark Office;
• our own personnel, and translators, notaries and professional advisers engaged on a need-to-know basis under confidentiality obligations;
• payment and banking intermediaries, to the extent needed to receive your payment;
• IT and hosting providers, including our email provider and website host;
• courier and postal services, where paper documents must be delivered; and
• courts, regulators or law enforcement, where disclosure is required by law, regulation or a binding order.

Where we engage a third party to process personal information on our behalf, we require it to process the information only on our instructions and to keep it secure.

7. Public Trademark Records

This disclosure is required by law and cannot be limited by us. It is the reason we ask you not to include information you would prefer to keep private in the specification or in supporting documents.

8. How Long We Keep It

We keep personal information only as long as we need it for the purposes in section 4, and for as long as Chinese law and professional rules require.

• Enquiries that do not become orders: normally deleted within 12 months.
• Client and filing records: retained for the life of the matter and for the retention period required of a CNIPA-filed trademark agency and under applicable accounting and tax law, typically at least 5 years after the matter closes.
• Accounting and tax records: retained for the statutory period.
• Technical and analytics data: retained for the period configured in our analytics tool, and in any event no longer than necessary.

Where you ask us to delete information that we must keep by law, we will restrict it to that legal purpose instead of deleting it.

9. Security

We take reasonable technical and organisational measures to protect your personal information, including access control on a need-to-know basis, password-protected accounts, encryption in transit where supported, secure storage of identity documents, and staff confidentiality obligations.

No system is completely secure. If a personal information security incident occurs that affects you and requires notification under applicable law, we will notify you and the competent authority as required.

You can help by sending documents over encrypted channels where available, and by telling us promptly at Hello@MyCNTM.com if you think any information we hold is wrong or has been compromised.

10. Your Rights

Under the PIPL, and subject to our legal retention obligations, you have the right to:

• know and access the personal information we hold about you, and obtain a copy;
• correct information that is inaccurate or incomplete;
• delete your personal information, where the legal conditions for deletion are met;
• withdraw consent you have given — including consent to cross-border processing;
• request an explanation of how we handle your information; and
• request transfer of your information to another processor, where the conditions under the PIPL are met.

If you are in the EEA or the UK, you additionally have the rights of access, rectification, erasure, restriction, portability and objection under the GDPR or UK GDPR, and the right to complain to your local supervisory authority.

To exercise any of these rights, email Hello@MyCNTM.com with the subject line "Privacy request". We will ask you to verify your identity before acting, and we will respond within the period required by applicable law (normally within 30 days).

We do not charge a fee for a routine request, but we may charge a reasonable fee, or decline, where a request is manifestly unfounded or excessive.

11. Cookies & Analytics

The Site uses cookies and similar technologies to make the Site work, to remember your preferences (for example your shortlist in the Class Finder), and to understand how visitors use the Site.

Strictly necessary cookies are required for the Site to function. Analytics cookies are used only to produce aggregate statistics. You can block or delete cookies in your browser settings; if you block strictly necessary cookies, parts of the Site — including the shortlist and quote tools — may not work.

If we introduce advertising or third-party analytics cookies that require consent, we will ask for your consent before setting them.

12. Children

The Site and the Services are intended for businesses and adults. We do not knowingly collect personal information from children under 14. If you believe a child has sent us personal information, contact us and we will delete it.

13. Third-Party Websites

The Site links to third-party websites, including the CNIPA official site and payment providers. This Policy does not apply to those websites, and we are not responsible for their content or their privacy practices. Please read their own policies before giving them any information.

14. Changes to This Policy

We may update this Policy to reflect changes in law, regulation, our Services or our systems. The updated version takes effect when posted, and the "Last updated" date above will change. Where a change materially affects how we handle information we already hold, we will take steps to tell you.

15. Contact & Complaints

If you have a question about this Policy, or you wish to make a privacy request or a complaint, please contact us. We will acknowledge your message and deal with it promptly.

If you are not satisfied with our response, you may complain to the competent authority in your jurisdiction, or to the cyberspace administration or market regulation authority in the People's Republic of China.

Related document: Terms of Service.