Privacy Policy

1.0 Introduction

Guangzhou Jinming Network Technology Co., Ltd. (referred to as Jin Ming, we, us, or our) is committed to protecting the privacy of individuals who interact with our website, services, and communications. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit jinming.hair or engage with our computer systems design and engineering services.

Jin Ming operates as a systems architecture and network engineering firm based in Guangzhou, China. We provide cloud infrastructure, cybersecurity, DevOps integration, and related consulting services to enterprise clients across Asia-Pacific. This policy applies to all information we collect through our website, email communications, client engagements, and any other interaction where this policy is referenced.

By accessing our website or using our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of our website and services.

2.0 Information We Collect

We collect information that you provide directly to us, information collected automatically through your use of our website, and information obtained from third-party sources. The categories of personal information we may collect include:

Information you provide voluntarily:

• Contact and identification details, including your full name, email address, phone number, company name, and job title when you submit a contact form, request a consultation, or correspond with us.
• Project and business information, including descriptions of your infrastructure requirements, technical specifications, and business objectives that you share during client engagements.
• Communication records, including emails, messages, and any attachments you send to us through our website or directly to hello@jinming.hair.

Information collected automatically:

• Technical data, including your IP address, browser type and version, operating system, device identifiers, and screen resolution when you access our website.
• Usage data, including pages visited, time spent on pages, referral sources, navigation paths, and interaction patterns with our website elements.
• Server logs and performance data that our hosting infrastructure records during normal operation.

3.0 How We Use Your Information

We use the information we collect for the following purposes:

• To respond to your inquiries, provide requested information about our services, and communicate with you about potential engagements.
• To deliver, maintain, and improve our computer systems design, cloud architecture, network engineering, cybersecurity, and DevOps integration services.
• To manage our client relationships, including project planning, service delivery, invoicing, and ongoing support communications.
• To analyze website usage patterns and improve the functionality, performance, and user experience of jinming.hair.
• To comply with applicable legal obligations, respond to lawful requests from public authorities, and enforce our Terms of Service.
• To protect the security and integrity of our systems, detect and prevent fraudulent or unauthorized activity, and safeguard our legitimate business interests.
• To send administrative communications, service announcements, and updates about changes to our policies or terms.

We do not use your personal information for automated decision-making or profiling that produces legal or similarly significant effects.

4.0 Legal Basis for Processing

For individuals located in the European Economic Area (EEA) or the United Kingdom, we process personal information under the following lawful bases as defined by the General Data Protection Regulation (GDPR):

• Consent: Where you have given clear consent for us to process your personal information for a specific purpose, such as receiving marketing communications or allowing certain cookie categories.
• Contractual necessity: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract, such as responding to a service inquiry or delivering agreed-upon consulting services.
• Legitimate interests: Where processing is necessary for our legitimate business interests or those of a third party, provided your rights and freedoms do not override those interests. This includes improving our website, ensuring network security, and managing client relationships.
• Legal obligation: Where processing is necessary for compliance with applicable laws, regulations, or lawful requests from government authorities.

Where we rely on consent as a legal basis, you have the right to withdraw that consent at any time by contacting us at hello@jinming.hair. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

5.0 Data Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties. We may share your information in the following limited circumstances:

• Service providers: We engage trusted third-party vendors to perform functions on our behalf, including website hosting, email delivery, analytics, and security monitoring. These providers access personal information only as necessary to perform their functions and are contractually bound to protect it.
• Professional advisors: We may share information with our legal, accounting, and compliance advisors where necessary for the operation of our business and compliance with legal obligations.
• Business transfers: In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, personal information may be transferred as part of the transaction, subject to applicable data protection requirements.
• Legal compliance: We may disclose information when required to do so by law, court order, or governmental authority, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

We require all third parties to respect the security of your personal information and to treat it in accordance with applicable data protection laws. We do not permit our service providers to use your personal information for their own purposes.

6.0 Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and understand where our visitors originate. Cookies are small text files stored on your device by your web browser.

Categories of cookies we use:

• Essential cookies: Necessary for the website to function properly. These cookies enable core functionality such as page navigation and access to secure areas. The website cannot operate properly without these cookies.
• Analytics cookies: We use Google Fonts for typography delivery, which may set cookies to optimize font loading and caching. We also collect aggregated, anonymized usage statistics to understand how visitors interact with our website.
• Functional cookies: These cookies remember choices you make, such as your preferred language or the region you are in, to provide enhanced and more personalized features.

You can control cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or alert you when cookies are being set. Please note that disabling cookies may affect the functionality and performance of our website. For more information about managing cookies, visit your browser's help documentation or www.allaboutcookies.org.

7.0 Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. Our retention periods are determined based on:

• The duration of our relationship with you and the period needed to complete the services you have requested.
• Legal obligations that require us to retain records for specified periods, such as tax, accounting, and commercial regulations under Chinese law.
• The establishment, exercise, or defense of legal claims, where information may need to be preserved for the applicable statute of limitations.
• Whether the information remains relevant to our ongoing business operations and service delivery.

When personal information is no longer required, we securely delete or anonymize it. Anonymized, aggregated data that cannot be linked back to an individual may be retained indefinitely for analytical and business intelligence purposes.

8.0 Security Measures

As a computer systems design and cybersecurity firm, Jin Ming takes data security seriously. We implement and maintain administrative, technical, and physical safeguards designed to protect your personal information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted to and from our website.
• Network firewalls, intrusion detection systems, and continuous security monitoring of our infrastructure.
• Access controls that limit personal information to authorized personnel who require it for legitimate business purposes, enforced through role-based permissions and periodic access reviews.
• Regular security assessments, vulnerability scanning, and penetration testing conducted by our cybersecurity team.
• Secure development practices, including code reviews, dependency scanning, and adherence to the principle of least privilege in system design.

While we strive to protect your information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we are committed to promptly notifying affected individuals and relevant authorities in the event of a data breach, as required by applicable law.

9.0 Your Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. We are committed to honoring these rights in accordance with applicable law.

For individuals in the EEA and UK (GDPR):

• Right of access: You may request a copy of the personal information we hold about you and information about how we process it.
• Right to rectification: You may request that we correct any inaccurate or incomplete personal information.
• Right to erasure: You may request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was collected.
• Right to restrict processing: You may request that we limit how we use your personal information in certain circumstances.
• Right to data portability: You may request to receive your personal information in a structured, commonly used, and machine-readable format and to have it transmitted to another controller.
• Right to object: You may object to processing based on legitimate interests or for direct marketing purposes.

For California residents (CCPA/CPRA):

• Right to know: You may request information about the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collection, and the categories of third parties with whom we share information.
• Right to delete: You may request that we delete personal information we have collected from you, subject to certain exceptions.
• Right to correct: You may request that we correct inaccurate personal information we maintain about you.
• Right to non-discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To exercise any of these rights, please contact us at hello@jinming.hair. We may require verification of your identity before processing your request. We will respond within the timeframes required by applicable law.

10.0 International Data Transfers

Jin Ming is headquartered in Guangzhou, China, and our data processing activities primarily occur within China. However, we may use service providers located in other countries to support our operations, which may involve the transfer of personal information across international borders.

When we transfer personal information from the EEA, UK, or other jurisdictions with data protection laws to countries that may not have equivalent protections, we implement appropriate safeguards to ensure that your information remains protected. These safeguards include:

• Standard contractual clauses approved by the relevant data protection authorities.
• Data processing agreements that impose binding obligations on recipients to provide a level of protection equivalent to the originating jurisdiction.
• Technical measures such as encryption and access controls to protect data during transit and at rest.

By using our services and providing your information, you acknowledge that your personal information may be transferred to and processed in countries outside your country of residence. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

11.0 Children's Privacy

Our website and services are not directed to individuals under the age of 16, and we do not knowingly collect personal information from children. Jin Ming provides enterprise-level computer systems design and engineering services to businesses and professional clients; our services are not intended for use by minors.

If we become aware that a child under 16 has provided us with personal information without verifiable parental consent, we will take steps to delete that information from our systems promptly. If you believe we may have collected information from a child under 16, please contact us immediately at hello@jinming.hair.

12.0 Third-Party Links

Our website may contain links to third-party websites, services, or resources that are not owned or controlled by Jin Ming. These links are provided for your convenience and reference only. This Privacy Policy does not apply to any third-party websites or services.

We are not responsible for the privacy practices, content, or security of third-party sites. We encourage you to review the privacy policies of any third-party services before providing your personal information. Your interactions with third-party websites are governed by their own terms and privacy policies, not by this document.

13.0 Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will post the revised policy on this page and update the Last updated date at the top of the document.

For significant changes that materially affect how we process your personal information, we will provide prominent notice on our website or notify you directly through the contact information we have on file, where appropriate and required by law. We encourage you to review this Privacy Policy periodically to stay informed about our data protection practices.

Your continued use of our website and services after any changes to this Privacy Policy constitutes your acknowledgment of the updated terms, subject to any requirements for explicit consent under applicable law.

14.0 Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us using the following details:

We will acknowledge receipt of your inquiry within five business days and aim to resolve any concerns promptly and fairly. If you are located in the EEA or UK and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local data protection supervisory authority.