Privacy Policy

Last updated:

Data controller and privacy contact

Shenzhen Upcera Innovative Materials Co., Ltd.

5F, Block B, Tsinghua Information Port, No.1 Songpingshan New East Road, Xili Street, Nanshan District, Shenzhen, Guangdong, China

Privacy email: luo.fz@upcera.com

This policy explains how we handle personal information when operating our Chinese and international websites, receiving product inquiries, providing requested downloads, processing job applications and conducting related communication. The controller, contact address and privacy email are shown in the contact panel above.

1. Information we process

When you send an inquiry or contact us, we process the information you provide: your name, email, telephone number, company, country, product of interest and message, together with any attachments you choose to upload and their names, types and sizes. Fields vary by form. Required fields are marked with an asterisk; missing necessary information may prevent us from accepting or properly answering an inquiry. Optional details and attachments can be supplied as needed.

We also record the source page and submission time to understand and follow up on your inquiry. Website servers and hosting services may process technical information such as IP addresses, request times and paths, and browser details to deliver and protect the service. Please provide only information needed to assess your requirements.

For document requests, we process your name, company, country or region, business email and optional telephone number. We verify your business email and record the requested document and version, language, request time, source page and version of the privacy notice you acknowledged. Email verification codes and verified sessions confirm access to your mailbox and allow further requests during a valid session.

For job applications, we process your selected position, name, telephone number, email, subject of study, educational institution, CV and supporting attachments, together with submission time, language and privacy-notice acknowledgement. Please avoid unrelated sensitive personal information or information about others that you are not authorised to provide.

2. Purposes and legal grounds

We use inquiry information to respond, clarify requirements, assess technical feasibility, prepare quotations and follow up on related contracts and business matters. Necessary technical information supports website delivery, troubleshooting and security. Where the GDPR applies, processing needed for a contract with you or steps you request before entering one is based on Article 6(1)(b). Business contact communication, including where you represent a company, relies on our legitimate interest in assessing and responding to business inquiries under Article 6(1)(f), subject to your rights. Applicable legal obligations and processing requiring consent rely on Article 6(1)(c) and (a), respectively, where their conditions are met.

An inquiry does not automatically subscribe you to marketing. Replies and related business follow-up are separate from marketing subscriptions. If we introduce promotional communication, we will provide the relevant notice and, where required, obtain separate consent and offer a convenient way to opt out.

We use document-request information to verify email access, provide the requested material, retain a request record and handle related business follow-up. Application information is used to receive applications, assess suitability and contact candidates. Where the GDPR applies, requested pre-contractual recruitment steps rely on Article 6(1)(b), and business document requests and their follow-up on our legitimate interest in responding to business requests under Article 6(1)(f), subject to your rights. Security checks support our legitimate interest in preventing spam and abuse. Other legal obligations or consent-based processing require the corresponding conditions to be met. Requesting a document or applying for a job does not automatically subscribe you to marketing.

3. Recipients

Our sales, commercial and engineering teams assess inquiries within their responsibilities. Necessary information may be provided to partners or suppliers assisting with materials, manufacturing feasibility, delivery schedules or other project requirements. We use customer relationship management (CRM) systems and business email to retain or forward inquiries and correspondence; those service providers may process the information for these purposes.

Disclosure should be limited to what the relevant purpose requires. Where applicable law requires specific recipient information, consent or other conditions before sharing, those requirements must be met first. You can contact our privacy contact about recipients and processing relating to your inquiry.

Document-request records are handled by authorised personnel with a business need; applications by recruitment staff and others authorised to handle the matter. Infrastructure providers include Cloudflare for pages, public media and security verification, and Alibaba Cloud for the Hong Kong server and email delivery. Inquiry and recruitment notifications send contact details, messages or application details and uploaded attachments to designated company business mailboxes. Verification emails are sent to the business email you provide. Email delivery and receiving-mailbox providers process the corresponding message content.

4. Hosting and processing locations

The Chinese, English and German websites currently use Cloudflare Pages for hosting and delivery, and Cloudflare R2 for public website images and document files. All three languages share an Alibaba Cloud server in Hong Kong, China, which stores the CMS database, inquiries, applications, document-request and email-verification records, and private inquiry and application attachments. The Chinese website and inquiry database are not currently hosted in Shenzhen. Authorised personnel in Shenzhen access and handle information for the purposes in this policy.

Website email is sent through Alibaba Cloud's Singapore-region email delivery service. This includes verification emails and the information and attachments in inquiry and recruitment notifications. Receiving business mailboxes, CRM, collaboration and backups may involve other processing locations; Hong Kong is not necessarily the only location of information or its copies.

Cloudflare processes technical information for pages, public media and security verification through its service network, potentially outside your location. See Cloudflare's Privacy Policy. Cross-border disclosures or transfers must meet applicable legal conditions; any required specific notice, consent or other arrangements must be completed before the relevant processing. Contact our privacy contact for recipients, processing locations and applicable arrangements relating to your information.

5. Retention and protection

Retention is determined by whether an inquiry remains under assessment or follow-up, whether it leads to a contract, subsequent service needs, and applicable record-keeping or dispute requirements. An inquiry is not a reason to retain information indefinitely. Information no longer needed for these purposes should be deleted or anonymised unless continued retention is legally required. Attachments, CRM and email copies, and backups require corresponding retention handling.

Access to inquiries, applications and document-request records is restricted to authorised personnel. Private inquiry and application attachments are not displayed as public website media. You may contact the privacy email about retention or request deletion; requests are assessed in light of applicable law and the relevant business circumstances.

Retention of document-request records depends on delivery, related business follow-up and legal requirements; retention of applications depends on recruitment progress, further communication and applicable requirements. Business records are not automatically deleted when a code or verified session expires. Email verification codes are valid for 10 minutes and verified sessions for up to 24 hours. A scheduled task removes temporary verification records that have not been updated for more than 48 hours. This cleanup does not delete visitor details or document-request records.

6. Cookies, links and third-party content

Inquiries, document requests and applications do not require a website account. Forms use Cloudflare Turnstile security verification, which processes IP addresses and browser, device and request signals to distinguish genuine users and prevent abuse. A submission may not complete if security verification fails. See Cloudflare's Privacy Policy.

Document requests temporarily store your business email, verified-session token and expiry time in the current browser's session storage to support further requests within a valid session. This storage is not used for advertising tracking. The Chinese website does not load Google Analytics. The English and German websites load Google Analytics only after you allow analytics; you can withdraw consent through the footer's analytics cookie settings. Refusing analytics does not affect inquiries, document requests or applications. See the Website analytics section below for details.

When you follow a map or external website link, or play a third-party video on a page, your interaction with that service is subject to its privacy information. Using those services is your choice; links do not change our responsibility for personal information we have received.

7. Your rights

Subject to applicable law and its conditions, you may request information about processing, access or a copy, correction, completion or deletion, restriction of processing, or object to particular processing. Data portability may also apply. You can withdraw consent for consent-based processing without affecting the lawfulness of processing before withdrawal. You may lodge a complaint with a competent supervisory authority, including in your place of residence or work where the GDPR applies.

Please send requests to our privacy email with enough information to locate the relevant inquiry, document request or application. We may need proportionate identity verification and will respond within the applicable time limits. The current inquiry, document-request and application processes do not make solely automated decisions producing legal or similarly significant effects on you.

8. Changes to this policy

We will update this policy and its date when our purposes, service arrangements or applicable requirements change. Material changes requiring additional notice or consent will be handled accordingly; updating this page alone does not replace required consent.

Website analytics

Only after you allow analytics, we use Google Analytics to measure pages viewed, active engagement time, internal navigation, traffic sources, approximate regions and device information, and to understand inquiry and resource-request journeys. Cookies distinguish browsers. We do not send names, email addresses, phone numbers, company details, messages, verification codes or attachments entered in our forms to Google Analytics.

You can change your choice at any time using Cookie Settings in the footer. Rejecting analytics does not affect the website, inquiries or resource requests. Your preference is stored on the current domain for 180 days. Withdrawing consent stops further analytics and removes this website's Google Analytics cookies.

Google Privacy Policy

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